ransomware Archives - Safe Systems

14 Mar 2024

Banks, Compliance, Credit Unions The Safe Systems Compliance Team 0 comment

Strengthening Financial Cybersecurity: Navigating the Upgrades in RSAT 2.0

In today’s rapidly evolving digital landscape, cybersecurity remains a critical concern for financial institutions. With increasing reliance on technology and expanding risk of exposure through Third-party service providers and electronic banking services, the threat of ransomware attacks continues to pose significant risks to the security, confidentiality, and integrity of financial data. The Ransomware Self-Assessment Tool Version 2.0 (RSAT 2.0) emerges as an important resource for institutions seeking to strengthen their defenses against such cyber threats.

The updated version of RSAT is designed to reflect the latest developments and regulatory insights, incorporating feedback from previous ransomware victims to enhance industry-wide resilience. Key enhancements in RSAT 2.0 include a rigorous examination of cloud-based service provider relationships, an emphasis on multifactor authentication implementations, strategic employee cyber awareness training, and robust incident response testing.

Highlights of Key Enhancements:

These updates underscore the importance of a comprehensive approach in safeguarding against the dangers of cyberattacks and reflect regulatory expectations.

Cloud-based data management – The tool demands a broader understanding of cloud providers and data flows, especially concerning data housed in locations outside the U.S., as well as compliance with international privacy regulations like GDPR.
Multifactor authentication – Another notable emphasis is the expanded focus on multifactor authentication (MFA). RSAT 2.0 seeks specific details regarding the types of MFA in place, its application across systems, and plans for future enhancements. This reflects the increasing recognition of MFA as a critical defense layer against unauthorized access.
Employee cyber awareness training – A third area receiving heightened attention is cybersecurity awareness training. With human error being a significant factor in security breaches, RSAT 2.0 stresses the need for comprehensive and role-based cybersecurity training. Financial institutions are encouraged to tailor training to different audiences within the organization, ensuring relevance and effectiveness.
Incident response testing – The new version of the tool queries institutions on their incident response testing, particularly the involvement of executive management. This inclusion highlights the importance of leadership engagement in cybersecurity readiness and incident management. Additionally, procedures for validating clean data backups are underscored, emphasizing the role of data integrity and availability in recovery efforts.

Financial institutions are provided with a valuable opportunity to self-assess their readiness to deal with the threat of ransomware in the form of RSAT 2.0.

The enhanced RSAT 2.0 is not merely a checklist but a comprehensive framework that encourages financial institutions to delve deeper into their cybersecurity posture. This self-assessment can help institutions identify areas for improvement and make informed decisions about their cybersecurity management strategies.

For more information on the RSAT 2.0 and other critical factors of cybersecurity management, such as NIST CSF 2.0, Third-party Relationship Management, and more, download and watch our recent webinar, Protect, Detect, and Respond: Prioritizing Cybersecurity Management in 2024.

08 Mar 2024

Banks, Compliance, Credit Unions, Uncategorized The Safe Systems Compliance Team 0 comment

The Crucial Role of Cybersecurity Management in 2024

As we reflect on the challenges of 2023 and the growing reliance on cloud providers in the financial industry, it is clear that cybersecurity management is more important than ever. With the increasing threat of cyberattacks and the need to protect customer information and financial transactions, community financial institutions must prioritize cybersecurity to ensure the safety and trust of their customers.

In our recent webinar, our IT and Information Security experts discussed cybersecurity management with areas of emphasis on the importance of understanding third-party risk management, the new version of the Conference of State Bank Supervisors (CSBS) Ransomware Self-Assessment Tool (RSAT 2.0), and lessons learned from exams and audits in 2023. This post explores some of the key highlights.

NIST Framework and the Arrival of CSF 2.0

The National Institute of Standards and Technology’s Cybersecurity Framework (NIST CSF) is a valuable resource for organizations to manage and reduce cybersecurity risk. This framework continuously integrates lessons learned and best practices while retaining its core functions: Identify, Protect, Detect, Respond, and Recover. The recently updated CSF 2.0 includes the introduction of a sixth function, ‘Govern,’ underscoring the importance of clear role definitions, policies, and risk prioritization procedures within cybersecurity programs. It also provides improved guidance on implementation, ensuring that organizations are equipped to address the latest cybersecurity challenges.

Critical Third-party Relationship Management

Third-party risk management is crucial as financial institutions are increasingly relying on third and fourth parties. Interagency guidance underscores the importance of understanding the impact and interaction levels of these relationships on operations and customers. Financial institutions are encouraged to establish sound methodologies for comprehensive oversight of the activities surrounding third parties. This includes a thorough understanding of third-party business processes and systems as well as an understanding of the risks and benefits before contract execution. As financial institutions move forward with third-party relationships, they must also exert pressure on their service providers to ensure adherence to strong cybersecurity standards to effectively safeguard the interests of the financial institution and ultimately its customers.

Importance of the Ransomware Self-Assessment Tool (RSAT 2.0)

The Ransomware Self-Assessment Tool (RSAT) version 2.0 represents a significant step forward in helping financial institutions fortify their defenses against ransomware attacks. The latest version is developed through the integration of feedback from institutions that have been impacted by ransomware, ensuring that the tool remains relevant and effective as this type of malware continues to evolve. With a focus on cloud-based service providers, RSAT 2.0 emphasizes the importance of understanding the flow of data, particularly in environments outside the U.S., and how it is subject to various privacy regulations like GDPR. Furthermore, RSAT 2.0 places increased emphasis on multifactor authentication (MFA) and employee cyber-awareness, reflecting the industry’s recognition of the critical role these factors play in strengthening cybersecurity postures.

Key Lessons Learned from Exams and Audits

A few of the biggest areas of scrutiny that we’re seeing from recent IT exams and audits include:

Asset Management – paying attention to asset lifecycles and end-of-life risks as well as implementing robust authentication methods that govern customers who are logging into electronic banking applications
Change Management – establishing baseline standards and auditable procedures for change requests and appropriate reporting for project management and cost overruns
Data Recovery – periodically rotating through your critical servers and restoring data so that you can ensure the effectiveness, integrity, and availability of that data
Increased Incident Response Testing and Training – conducting testing as frequently as possible over different threat scenarios, documenting those tests, and training the employees who are going to be involved in the actual response

For more lessons learned and emerging trends, watch the full webinar recording.

Community banks and credit unions must prioritize cybersecurity management to protect customer information and maintain operational resilience. Enhanced cybersecurity strategies are imperative, urging institutions to adopt a multidimensional approach that incorporates people, processes, and technologies. Regular assessments, third-party risk management, and adherence to cybersecurity frameworks contribute to a proactive defense against cyber threats.

If you have any questions or want to learn more about our complimentary information security review, please visit safesystems.com/review.

09 Nov 2022

Banks, Credit Unions, Security Kai Xu 0 comment

Best Practices for Ransomware Prevention and Recovery

In the world of cybersecurity, an ounce of prevention is worth a pound of cure—especially when it comes to ransomware. Ransomware attacks hit a new target every 14 seconds, disrupting operations, stealing information, and exploiting businesses, according to the Cybersecurity and Infrastructure Security Agency (CISA). As a result of ransomware attacks, US Banks paid out nearly $1.2 billion in 2021, which is up by 188% from 2020 according to the Financial Trend Analysis report [PDF] on ransomware from the US Treasury’s Financial Crimes Enforcement Network (FinCEN). But banks and credit unions that consistently implement best practices can effectively prevent and recover from ransomware attacks.

Prevention Strategies

The ideal strategy is to keep ransomware assaults from happening in the first place, but prevention can be tedious and challenging. As a general practice, institutions should identify and address known security gaps that can enable a ransomware infection. (If there is a loophole, hackers will eventually find it.) Since human mistakes are the root cause of most security breaches, providing ransomware training for employees is a crucial step that institutions can take to reduce their cybersecurity risk. Ransomware awareness training can help staff identify, respond to, and circumvent attacks as well as test their knowledge in a safe environment. Institutions can also limit their security risk by adhering to the principle of “least access” to grant employees the minimum levels of access or permission needed for their job.

As another best practice, institutions can also take a stricter stance on the technical aspects of cybersecurity. They can employ intelligent network design and network segmentation to limit risk by restricting ransomware intrusions to a portion of the network instead of the whole system. Institutions should also have overlapping security solutions to provide layered protection for their systems and networks. Then if a single security element fails, another layer will be in place to compensate.

Response and Recovery Tactics

Even with multiple protective measures in place, there is only so much financial institutions can do to avert a ransomware attack. When a breach happens, the institution must respond immediately to mitigate the impact. This includes implementing pre-established processes for incident response, vendor management, business continuity, and other key areas. Bank management, for example, should have an incident response program to minimize damage to the institution and its customers, according to the Federal Financial Institutions Examination Council (FFIEC) IT Handbook’s Information Security booklet.

Having pre-defined procedures to declare and respond to an incident can be essential to effectively containing and recovering from a ransomware infection. While incident containment strategies can vary between different entities, they typically include the isolation of compromised systems or enhanced monitoring of intruder activities; search for additional compromised systems; collection and preservation of evidence; and communication with affected parties and often the primary regulator, information-sharing organizations, or law enforcement, according to the FFIEC.

In addition, restoration and follow-up strategies for incidents should address the:

elimination of the intruder’s means of access
restoration of systems, programs, and data to a “known good state” (using available offline or offsite backups)
the initiation of customer notification and assistance activities consistent with laws, regulations, and interagency guidance
monitoring to detect similar or further incidents

Another step in the recovery process might involve notifying an insurance carrier—if the institution has ransomware coverage. However, cyber insurance might not prove to be the ultimate remedy: A policy exclusion could keep the carrier from paying the claim. Or the settlement amount may not fully compensate for the institution’s intellectual property losses, revenue reduction, tarnished reputation, and other damages.

Augmenting Internal Resources

With the growing complexity of ransomware, it can be challenging for institutions to react to and recover from a cyberattack. However, those with limited internal resources can get help from a third-party cybersecurity expert to manage the process. Safe Systems, for instance, offers multi-layered security services that make it easier for community banks and credit unions to enhance their cybersecurity posture, so they can be better equipped to prevent, respond to, and recover from a ransomware attack. For more information about this critical topic, read our white paper on “The Changing Traits, Tactics, and Trends of Ransomware.”

20 Oct 2022

Banks, Compliance, Credit Unions, Security, Technology Jamie Davis 0 comment

Special Guest Speakers Share their Expertise on Key Banking Systems and Compliance Trends

Our first Customer Success Summer Series offered live webinars with special guest speakers who shared their industry knowledge to help our customers and other financial institutions enhance internal processes and key areas of their banking operations.

In August, we hosted Cary Parris, Co-Founder and CTO at iTransit Solutions who presented “The Evolution of Phone Systems: Which is Right for You?”.
In September, we presented “2 Guys and a Microphone: Matt and Tom Chat About Compliance Trends and Rumors” where Matthew Jones, Partner and Financial and Information Security Auditor at Symphona, and Thomas Hinkel, the Compliance Guru at Safe Systems discussed recent developments and trends in regulations and shared their insights on current findings from examiners and auditors.

The Evolution of Phone Systems

Today businesses are facing the acceleration of remote working—Voice over internet protocol (VoIP), Virtual Private Networks (VPN), virtual meetings, and dynamic routing of phone systems based on the user’s location—all have become must-have requirements. Legacy telephone services are becoming more obsolete as some telecoms decommission analog technologies in favor of fiber pots and other alternatives. The old telephone system is evolving into a more modern option: unified communications as a service (UCaaS), which merges communication channels into a single cloud-based system. UCaaS offers all the necessary infrastructure, applications, and resources businesses need in an easily scalable solution. Unified communications tools can include chat, VoIP, text messaging, and online video conferencing.

UCaaS gives institutions the benefit of advanced functionality which allows employees to work remotely more efficiently, including things like the ability to check other users’ availability, reach people whether they are in the office or out in the field, and access the platform from anywhere. Another evolving facet in telecommunications is call center as a service (CCaaS), which also streamlines omnichannel communication and allows remote employees to work together as a call center team.

Given its flexibility and efficiency, it is easy to see why UCaaS is moving to the forefront of communications. There is a wide range of unified communications features, equipment, and prices and it is important for your institution to clearly define its unique needs to find a solution that will satisfy its requirements. It is also important to continue to evaluate your equipment and services every few years as technology and pricing continue to change.

Watch the recording of this webinar to gain a better understanding of UCaaS and other options so you can make the right choice for your institution.

2 Guys and a Microphone

Matt and Tom have both spent most of their careers focused on risk and regulatory compliance for financial institutions. We recorded their recent conversation which spans many topics including increased scrutiny on vendor management, continued focus on ransomware, and more.

Recent audit and exam trends continue to have a strong focus on third parties and proper vendor management. Examiners are considering the preponderance of fintechs, how much the average financial institution is outsourcing, and the inherent risk that originates from third-party vendors. Interestingly, their increased scrutiny may extend to any significant sub-service vendors that institutions may have. In addition, we are seeing questions arise about vendor management in the context of insurance. Cyber liability insurance applications are requesting more details about the management of vendors and other third parties.

There have also been some interesting audit and exam findings. For instance, one institution was encouraged to complete a post-pandemic/walk-through test or “dry run” of their pandemic procedures. This is curious considering all institutions have been in a “live exercise” for the past few years with the pandemic. Regardless, there is a good chance that the pandemic verbiage in your disaster recovery plan needs to be updated based on what has or has not been done in response to the current pandemic. And it is important to consider that an annual pandemic test will be a part of examiner expectations going forward along with the traditional business continuity, natural disaster, and cyber incident tests.

On the regulatory front, the new Computer-Incident Notification Rule went into effect on April 1, 2022, which is designed to give regulators early awareness of emerging threats to banking organizations and the broader financial system, including potentially systemic cyber events. The rule has two components:

The first part requires a banking organization to promptly notify its primary federal regulator of any “computer-security incident” that rises to the level of a “notification incident.”
The second part requires a bank service provider to notify each affected banking organization customer as soon as possible when the bank service provider determines that it has experienced a “computer-security incident” that has caused, or is reasonably likely to cause, a material service disruption or degradation for four or more hours.

In March, we hosted an in-depth webinar on understanding the requirements, recognizing gray areas, and preparing for unknowns. To help intuitions meet these requirements, we also created a detailed flowchart to understand when an event is severe enough to activate your Incident Response Team (IRT) and when regulators and customers should be notified.

Another regulatory trend to keep your eyes on is the increasing focus on ransomware industry-wide is prompting some state banking organizations to require institutions to use the Ransomware Self-Assessment Tool (R-SAT). The 16-question R-SAT is designed to help institutions evaluate their general cybersecurity preparedness and reduce ransomware risks. The R-SAT supplements the Cybersecurity Assessment Tool developed by the Federal Financial Institutions Examination Council (FFIEC). It will be interesting to see if more states begin requiring this additional diagnostic tool.

Watch the recording to hear more insights about INTrex, SOC Reports, and SSAE 21.

01 Sep 2022

Banks, Credit Unions, Security Kai Xu 0 comment

Addressing the Growing Ransomware Problem

Ransomware has become the leading cyber threat to businesses today—and it is growing at an alarming rate. Threat actors, who often work in groups, continue to evolve and create different ransomware strains. They rebrand themselves and resurface under new identities, making it difficult to curtail their criminal activities. Ransomware has continued its upward trend with an almost 13% rise—an increase as big as the last five years combined, according to the 2022 Verizon “2022 Data Breach Investigations Report.” And the FBI’s Internet Crime Complaint Center Annual Report stated recorded 3,729 ransomware complaints in 2021 with adjusted losses of more than $49.2 million.

The pervasive nature of the ransomware problem affects all types of companies, sectors, and industries worldwide. Approximately 37 percent of global organizations were targeted by a ransomware attack in 2021, based on the IDC’s “2021 Ransomware Study.” And in February 2022, the Cybersecurity and Infrastructure Security Agency (CISA) reported that fourteen of the 16 US critical infrastructure sectors had ransomware incidents.

The Impact

Ransomware is malicious software or malware that locks victims out of their computing devices or blocks access to files until they pay a ransom. More sophisticated versions can encrypt files and folders on attached drives and even networked computers, raising the stakes even higher. (In all cases, the FBI does not support paying a ransom in response to a ransomware attack.)

Typically, ransomware gets installed on a workstation using a social engineering technique such as phishing. It tricks people into clicking on a link or opening an attachment and disclosing their login information or even financial data. Regardless of the threat vector used, a ransomware infection can wreak havoc on victims, causing extensive business interruptions, legal expenses, and reputational damage. According to IBM’s Cost of a Data Breach 2022 report, the average cost of a ransomware breach, not including the ransom payment, declined slightly, from USD 4.62 million to USD 4.54 million. However, the frequency of ransomware breaches has increased — from 7.8% of breaches in the 2021 report to 11% in the 2022 study. In certain industries, an attack may be considered a data breach and involve even more negative consequences. For instance, financial institutions and other critical infrastructure agencies may be required to pay fines for an attack due to their failure to protect clients’ data.

Cybercriminals are shifting away from ransomware attacks that merely demand a payment to unlock the victim’s data or device. They are focusing on more multidimensional extortion methods to extract a larger reward. IBM Security’s 2022 “X-Force Threat Intelligence Index” report indicates that virtually all ransomware assaults today are “double extortion” attacks that demand a ransom to unlock data and prevent its theft. Some attackers opt to exfiltrate sensitive data, so they can present additional ransom demands in the future. They may also sell personal data—credit card numbers, email addresses, online credentials, or bank account information—to make the fraud even more lucrative.

Best Practices

Security is a complicated issue, which makes staying on top of threats and vulnerabilities challenging. Financial institutions must complete a myriad of time-consuming and complex tasks to maintain a strong security posture. Addressing ransomware can be particularly difficult for community banking institutions with limited internal technical expertise and resources. And there is only so much an institution can do to stay vigilant against ransomware threats.

However, institutions can reduce their risk by implementing some key security strategies such as:

Having a well-trained staff because most ransomware intrusions are caused by human error.
Having overlapping security products and or services to cover the protection of systems and networks.
Having well-designed network infrastructure with security in mind.
Having a proper incident response plan that can be adhered to in the event of a breach.

Using a Managed Service Provider

Financial institutions that put mitigating systems, processes, and practices in place will be better positioned to prevent, detect, and recover from a ransomware breach. However, many smaller institutions may lack the resources and knowledge in-house to close security gaps and circumvent attacks. They can remedy the situation by employing the products and services of a managed service provider to strengthen their security posture.

Safe Systems provides a wide range of layered security solutions to help institutions address the risk of ransomware. Our security offerings include behavior-based vulnerability monitoring, advanced endpoint protection, vulnerable systems patching, next-generation firewalls, email software security, and staff training. These products and services deliver essential overlapping protection, and they are specially designed to meet the needs of community banks and credit unions.

Also, stay tuned for our upcoming white paper that will provide more data on the current state of ransomware and how banking institutions can better minimize the risks of an attack.

30 Dec 2021

Banks, Compliance, Credit Unions, Security, Technology Christine Ray 0 comment

Our Top Blog Posts of 2021

With a new year approaching, it’s a good time to review some of the key discussions from the past year. Read these highlights from our top blog posts of 2021, to help your financial institution refine key operational strategies for 2022 and beyond:

1. 2021 Hot Topics in Compliance: Mid-Year Update

Although the COVID-19 pandemic isn’t over, financial institutions have learned valuable lessons so far. Key impacts have been primarily operational, involving risks related to temporary measures taken to weather the crisis. In addition, there are important compliance trends and new regulatory guidance institutions should anticipate going forward. Ransomware cybersecurity has been a key area of focus for regulators, and given the recent high-profile cyber events affecting the industry, their scrutiny will likely increase in the future. This will be reflected, in part, by the number of (and types of) assessments that regulators might expect institutions to perform annually. These assessments from various state and federal entities include the Cybersecurity Assessment Tool (CAT), the optional Ransomware Self-Assessment Tool (R-SAT), the Cybersecurity Evaluation Tool, and the modified Information Technology Risk Examination for Credit Unions (InTREx-CU). In addition, there have been major shifts with cyber insurance, and the FFIEC released a new Architecture, Infrastructure, and Operations booklet in its Information Technology Examination Handbook series. Read more.

2. The 4 “R’s” of Disaster Recovery

Maintaining an effective approach to disaster recovery can help financial institutions satisfy regulatory requirements, better protect themselves from the effects of negative events, and improve their ability to continue operating after a disaster. There are four important “R’s” that institutions should concentrate on for disaster recovery: recovery time objective ( RTO ), recovery point objective ( RPO ), replication , and recurring testing .

RTO is the longest acceptable length of time a computer, system, network, or application can be down after a disaster happens. When establishing RTOs, prioritizations must be made based on the significance of the business function and budgetary constraints. The RPO is the amount of time between a disaster occurring and a financial institution’s most recent backup. Essentially, the RPO will be determined by the institution’s technology solution and risk tolerance. DR replication entails having an exact copy of an institution’s data available and remotely accessible when an adverse event transpires. The best practice is to keep one backup copy onsite and another offsite in a different geographic location that’s not impacted by the disaster. Recurring testing allows institutions to identify key aspects of their DR strategy and adjust as needed to accomplish their objectives. Regular testing can expose potential problems in their DR plan so they can address these issues immediately. Read more.

3. Segregation of ISO Duties Critical to Network Security and Regulatory Compliance for FIs

It’s crucial for financial institutions to maintain distinct duties between their information security officer (ISO) and network administrator to ensure network security, regulatory compliance, and the health of their operations. There should be at least one designated ISO who is responsible for implementing and monitoring the information security program and who reports directly to the board or senior management—not to IT operations management. The significance of segregating the ISO’s duties comes down to oversight: Separating ISO and network administrator tasks helps to create a clear audit trail and ensures risk is being accurately assessed and reported to senior management . It also allows the ISO to provide another “set of eyes” that help to maintain a level of accountability to management, the board, and other stakeholders. The ISO’s independent role primarily serves to ensure the integrity of an institution’s information security program . Financial institutions can also use a virtual ISO to create an additional layer of oversight on top of what they have in place internally. Read more.

Discover these and other key topics about banking compliance, security, and technology on the Safe Systems blog.

Or, subscribe now to be the first to receive the latest updates on banking trends and regulatory guidance directly to your inbox.

08 Dec 2021

Banks, Compliance, Credit Unions The Safe Systems Compliance Team 0 comment

5 Compliance Lessons Learned in 2021 to Bring into the New Year

As the challenges presented by the COVID-19 pandemic persist, there are important compliance trends and new regulatory guidance that financial institutions should consider to ensure they are well prepared to begin the New Year.

Accounting for Operational Risk

During the pandemic, banks and credit unions have made necessary adjustments that have increased their operational risk. Two prime examples are switching to a remote workforce and accommodating a more remote customer base. Having employees work remotely extends an institution’s network out to that endpoint and, in effect, broadens security considerations to that point as well. Serving a remote customer base—including expanding e-banking and implementing electronic signatures—creates a similar risk. Security implications multiply as more employees and customers access services electronically.

Rapid changes in operational practices and increases in fraud and cyberthreats can cause a heightened operational risk environment if not properly managed. Examiners will want an account of how institutions determined what changes were necessary, how those modifications were implemented, whether those changes were temporary or permanent, and if controls (primary and compensating) have been adjusted for any resulting operational risk increases. They will review the steps management has taken to evaluate and adjust controls for new and modified operational processes. For instance, for permanent changes, did the institution factor in the operational risk of downtime relating to the new processes?

As a measure of governance effectiveness, examiners will also very likely:

Assess actions that management has taken to adapt fraud and cybersecurity controls to address the heightened risk associated with the altered operating environment.
Review management’s post-crisis efforts to assess the controls and service delivery performance capabilities of third parties.
Consider how imprudent cost-cutting, insufficient staffing, or delays in implementing necessary updates impacted the control environment.

Temporary vs. Permanent Changes

For the most part, because we are still dealing with the impact of the virus and its variants, institutions have chosen to maintain many of the temporary measures they implemented during the pandemic. So, because they may have rolled out the changes anticipating an eventual rollback, it may be necessary to “backfill” some documentation to address what is now permanent. Examiners will want to know if the changes were properly risk-assessed prior to implementation, including any new processes and interdependencies. Institutions should be able to provide a report to regulators if they ask—and ensure their board is appropriately updated. This could be a matter of going back and reviewing previous board reports to ensure that any gaps in their risk management reporting were addressed and properly reported to the board.

Ransomware Self-Assessment Tool (R-SAT)

With the pervasive occurrence of cyberattacks, regulators are increasingly concerned about cybersecurity, particularly reducing ransomware. Consequently, regulators in some states are more aggressive than others about having institutions fill out the Ransomware Self-Assessment Tool (R-SAT), which is based on the National Institute of Standards and Technology (NIST) cybersecurity framework. However, most state regulators we’ve spoken with are not going to make completing the R-SAT compulsory—although they may recommend it. If they do, the majority of what is asked by the 16-question tool should already be in place in the institution’s existing incident response and business continuity plans. Your decision to complete or not should be based on a self-assessment of your existing efforts in this area.

Regulatory Updates

New Architecture, Infrastructure, and Operations (AIO) Booklet

Earlier this year, the Federal Financial Institutions Examination Council (FFIEC) revamped its Information Technology Examination Handbook series with a new Architecture, Infrastructure, and Operations booklet. The revised guidance provides examiners with fundamental examination expectations about architecture and infrastructure planning, governance and risk management, and operations of regulated entities. Credit unions, banks, and non-financial, third-party service providers are expected to comply with the new guidance, which replaces the original “Operations” booklet issued in July 2004.

The FFIEC indicates that the release of the updated booklet is warranted because of the close integration between institutions’ architecture, infrastructure, and operations. “Updates to the booklet reflect the changing technological environment and increasing need for security and resilience, including architectural design, infrastructure implementation, and operation of information technology systems,” explains a June 2021 FFIEC press release.

An important component of the new booklet is the resilience and proactive measures that must be built into an institution’s AIO components. Importantly, the handbook also recognizes special treatment for smaller or less complex entities, which is reasonable because examiners are starting to indicate that smaller entities will often implement these concepts differently from large, multinational, multi-regional financial organizations, while still achieving the same objectives. The refreshed guidance also takes a different approach to data classification; it factors in value, along with criticality and sensitivity. However, (and this is consistent with all FFIEC Handbooks released in the past 3 years) the new booklet states that it does not impose requirements on entities; instead, it describes principles and practices examiners will review to assess an entity’s AIO functions. (Of course, we have always found that anything an examiner may use to evaluate, or grade, your practices becomes in effect a de facto requirement.) A much deeper dive into the booklet is here.

New Cyber Incident Notification Rules

Another big update that will impact 2022 and beyond, the new cyber incident notification rules. Officially called “Computer-Security Incident Notification Requirements for Banking Organizations and Their Bank Service Providers”, they were proposed and submitted for comment in early 2021, approved in November 2021, and become effective in April 2022. Visit our partner site, ComplianceGuru.com, to read the latest post and gain an understanding of how these rules will impact both you and your third-party providers going forward.

To learn more about these and other critical compliance topics, listen to our webinar on “2021 Hot Topics in Compliance: Mid-Year Update.”

23 Nov 2021

Banks, Credit Unions, Security Brendan McGowan 0 comment

Importance of Security Layers

In the past, it wasn’t uncommon for organizations to maintain basic information security: a firewall, anti-malware software, and maybe a few other resources. But modern operating environments require financial institutions to go beyond limited measures and implement multiple security layers to protect their sensitive information, infrastructure, and other assets.

Today banks and credit unions have a variety of elements that comprise their computer networks, and these components require numerous security solutions for them to operate securely. There’s no such thing as having too many solutions—although some entities invest in more resources than they can competently manage. The most appropriate approach is for institutions to employ all the security layers they can afford to pay for and oversee effectively.

The security landscape has changed significantly over the years. With the evolution of technology, cybercriminals are launching more frequent and sophisticated attacks against organizations. (The bad guys have it easy; they only have to get it right once. Security professionals, on the other hand, have to get it right all the time.) Currently, the top security threats for financial institutions are a remote workforce, ransomware, and the Internet of Things devices like webcams, Amazon Alexa, and Google Chromecast.

Security Considerations

Financial institutions often select security products based on what their security posture requires to pass exams. But the emergence of new threats is motivating more institutions to select solutions not just based on examiner expectations, but to also consider what is essential for operational safety. Generally, the security products that institutions invest in are determined by their cost and ability to mitigate risk.

For the most part, the financial services industry is interested in solutions that require minimal management involvement and customization to be effective. The industry also tends to adopt solutions once they’ve reached a certain level of commoditization and are priced lower. For example, well-commoditized solutions like anti-virus agents and anti-ransomware tools allow institutions to protect against expensive threats for the minimum cost. An effective anti-malware agent—especially one with some specific anti-ransomware technology—is another essential layer for endpoint protection.

Ultimately, increased competition leads to technology innovation and consolidation. A good example of this is what’s happened with firewalls. Implementing a firewall used to equate to a simple router that separated public and private networks. Things evolved when people began adding dedicated appliances like intrusion detection and prevention systems, antivirus gateways, web content filters, and other technologies. Through commoditization, these different elements became consolidated into the firewall to create a unified threat management system. More recent innovations that allow institutions to inspect encrypted traffic and sandbox potentially hazardous traffic have ushered in the next-generation firewall.

Going Beyond Basic Requirements

A fundamental requirement for layered security is multi-factor authentication (MFA), which involves several elements for validating the identity of users. While some organizations have concerns about MFA negatively impacting user experience, the technology provides an advanced level of protection that strengthens security.

Transport Layer Security is now implemented to secure over 80% of web traffic. The TLS protocol is used to encrypt data between a web browser and a website. While this is great for user privacy, it prevents institutions from inspecting all user traffic for threats. Transport Layer Security (TLS) Inspection has become a more common—and critical—security tactic for financial institutions. TLS inspection allows institutions to decrypt and inspect TLS traffic, so they can filter out malicious information and protect their network.

The increased adoption of endpoint security and other innovative technologies is making it easier for financial institutions to implement a layered approach to security. Safe Systems offers a wide range of security solutions to help community banks and credit unions incorporate multiple levels of protection to enhance their security posture.

15 Jul 2021

Banks, Credit Unions Safe Systems 0 comment

Cybersecurity Shouldn’t Be Keeping You Up at Night

There’s been a notable uptick in cyberattacks in recent years, some of which have drastically impacted institutions’ overall security. At Safe Systems, we believe that proactively protecting customer data will always be more cost effective than falling victim to malicious activity.

From malware and ransomware to managing security needs, we’ve got you covered on how best to protect your financial institution against any type of cybersecurity threat. After all, that’s why we’re here, right?

Make sure cybersecurity isn’t your institution’s weakest link by taking a look at our original blog post on the matter here.

22 Apr 2021

Banks, Compliance, Credit Unions Marshall Jones 0 comment

Why a Comprehensive Disaster Recovery Service is Critical to Any Financial Institution’s BCM

As part of business continuity management (BCM), banks and credit unions must ensure they can maintain and recover their operations after a catastrophic event happens. Their BCM strategy should outline all the significant actions they intend to take after a natural disaster, technological failure, human error, terrorism, or cyber attack. The goal is to lessen the disaster’s impact on business operations, so the financial institution can continue running with minimal loss and downtime.

Disaster recovery (DR) is essentially the IT part of the business continuity plan. It should address the recovery of data centers, networks, servers, storage, service monitoring, user support, and related software needed to get operations back to normal, based on the Federal Financial Institution Examination Council (FFIEC) IT Handbook’s Business Continuity Management booklet.

The Need for a Comprehensive DR Solution

Financial institutions must have effective DR measures in place to ensure they can deliver the resources their employees need to continue serving customers after a disaster. That’s why having a comprehensive DR service is so critical. The simplest and most cost-effective way to accomplish this is with a cloud-based solution.

With DR in the Cloud, institutions are always prepared to respond to natural and man-made disasters as well as infrastructure and technology failures. The Cloud allows institutions to access their data—no matter what kind of disaster strikes. This could be crucial if a severe storm does damage to an entire city and multiple locations of a community financial institution. The institution would not be able to handle DR on-site, making the Cloud the most viable option. The March 25th outbreak of tornados in central Alabama is a good example of the potential need for cloud DR. The tornadoes tore into hundreds of miles of Alabama forest and neighborhoods, causing significant damage, according to the National Weather Service.

The Cloud provides major benefits in any DR situation, including ease, expediency, and efficiency. If institutions have been doing ongoing backups, they can leverage the Cloud to initiate DR right away. The process is quick; recovery can take minutes instead of hours or days as it did for older DR solutions. However, it’s important to set up DR processes so that they are not subject to issues that can impact the institution’s main system. Take, for instance, the rapidly increasing problem of ransomware. It’s important to have cloud DR services structured so that the DR backups cannot also be infected with the same ransomware.

Essential Aspects of a DR Service

Another essential element for a cloud DR service is testing. The test results should be documented and available for Management and the Board of Directors to scrutinize. This can help institutions ensure their expectations are being met by the DR service. Institutions that are not using a comprehensive DR service are more likely to delay the testing and validation steps that are critical to business continuity planning (BCP). It’s basic human nature: IT admins tend to prioritize addressing urgent day-to-day issues over doing routine testing.

So, either testing doesn’t get done regularly or it doesn’t happen at all. A third-party DR service with a team of experts available can make sure testing gets done at the proper time. Another important issue for institutions is having IT staff available with the appropriate knowledge when a disaster strikes. With an external service provider, someone with the right expertise will always be there to execute the disaster recovery. So, the success of the institution’s DR plan will not depend on the availability of just a few employees.

A comprehensive cloud DR service offers substantial redundancy, reliability, uptime, speed, and value. It can give financial institutions the best bang for their buck. Not using cloud DR can be cost-prohibitive for many institutions, considering the hardware and software requirements, maintenance, ongoing testing, and documentation required. Ultimately, a cloud DR solution from an external service provider can give institutions the comfort of knowing their DR plan is being adequately tested and will work during a real disaster.

01 Apr 2021

The Security Evolution Featured Blog Image

Banks, Compliance, Credit Unions The Safe Systems Compliance Team 0 comment

The Security Evolution: The Integration of Security and Technology in Your Bank’s Infrastructure

The Security Evolution Featured Blog Image

Financial institutions and other organizations face a head-spinning number of information security risks—and the threats are becoming more complex and difficult to detect. In 2020, the FBI’s Internet Crime Complaint Center received a record number of complaints: 791,790, with reported losses exceeding $4.1 billion. The complaints—many of which included sophisticated phishing emails, business email compromise, and ransomware—represented a 69-percent increase in total from 2019, according to the FBI 2020 Internet Crime Report. In almost every case, a financial institution was involved; either as the direct target, a payment intermediary, or the account holder (victims) source of funds.

Importance of Resilience

With IT security, one of the primary goals for financial institutions is to minimize operational risk by limiting downtime; a process also referred to as “resilience”. Formally defined as the “…ability to prepare for and adapt to changing conditions and withstand and recover rapidly from disruptions…”, resilience also includes the ability to withstand and recover from deliberate attacks or naturally occurring disasters.

Resilience extends beyond after-the-fact recovery capabilities to incorporate proactive measures for mitigating the risk of a reasonably anticipated disruptive event in the overall design of operations and processes, including IT infrastructure. Resilience strategies, including maintaining security standards, should extend across the entire business, including outsourced activities. Because of the constantly changing threat environment, banks and credit unions should be regularly refining their security strategies. But it can be challenging for institutions to effectively manage the resources required to create a resilient infrastructure, including the staff, hardware, software, facilities, utilities, and other resources required to support operations. This monumental task encompasses everything from technology and telecommunications infrastructure to the critical dependencies provided by third-party service providers.

With so much complexity, having integrated security controls that coordinate and communicate with each other can make it easier for institutions to detect and prevent an incident before it happens, and to respond and recover afterward. Integration involves blending separate technology and controls into a single system that simplifies the work of short-staffed, time-strapped IT departments. The integration of security technology can ensure that financial institutions have a more manageable—and sustainable—approach to addressing the increasing volume and sophistication of security threats that they encounter.

Compliance and IT Security Integration

Of course, the rationale for integrating security and technology goes beyond the practical need to safeguard an institution’s information, infrastructure, and other assets, as it’s also a matter of compliance.

Information security should be embedded within the institution’s culture, according to the Federal Financial Institution Examination Council (FFIEC), and an institution’s security culture contributes to the effectiveness of its information security program. In fact, the FFIEC IT Handbook’s Information Security booklet indicates that “an institution with a stronger security culture generally integrates information security into new initiatives from the outset and throughout the life cycles of services and applications.”

Financial institutions should have a robust and effective information security program that supports their IT risk management process, according to FFIEC guidelines. Based on the FFIEC IT Handbook’s Information Security booklet, an effective IT program should:

Identify threats, measure risk, define information security requirements, and implementing control
Integrate with lines of business and support functions in which risk decisions are made
Integrate third-party service provider activities with the information security program

Third-party Management

Integrating third-parties into your security program is not just accepted by the regulators, it’s expected. According to the FFIEC, “In many situations, outsourcing offers the institution a cost-effective alternative to in-house capabilities…without the various expenses involved in owning the required technology or maintaining the human capital required to deploy and operate it.” However, the FFIEC goes on to recommend that institutions who elect to outsource technology, line of business activities, and support functions, ensure the integration of these activities with their information security program through an effective third-party service provider (vendor) management program. The FFIEC IT Handbook’s Information Security booklet asserts that: “Effective integration of these programs is evident when the institution creates and enforces expectations that align with the internal information security program in such a way that the combined activities of the institution and its third-party service providers result in an acceptable level of risk.”

Security threats will always be a constant challenge, but successfully integrating security and technology within an institution’s banking infrastructure can help institutions win the fight. Safe Systems provides banks and credit unions with an array of compliance-focused IT services to help them improve their overall security posture. Our proven experience, paired with our compliance-focused technology and security solutions, enables financial institutions to significantly strengthen their resilience by seamlessly aligning compliance and security.

25 Feb 2021

Banks, Compliance, Credit Unions The Safe Systems Compliance Team 0 comment

Five Key Areas of Focus for Your Regulatory IT Exam

Key Areas of Focus for Your Regulatory IT Exam

We’re back with part two of our IT Exam Prep blog series.

Picking up where we left off, there are five key areas where we expect you’ll likely be scrutinized closely at your next exam cycle:

Cybersecurity
Business continuity management
Outsourcing and third-party vendors
Governance and management engagement
Strategic planning

Of these, the most challenging, and most important, for smaller institutions might be governance and management engagement; the CAMELS “M”. This is true because often smaller institutions may have a more informal reporting structure.

For example, relevant issues may be discussed in committees and may even be reported upstream—but they may not be sufficiently documented. The issue is not just a matter of how you engage and report to senior management and the board, but rather, how you document that the necessary practices are in place. This is important when discussing day-to-day operational matters, but even more important when addressing issues of long-term strategic significance.

Although documenting management engagement can be particularly challenging, institutions must focus on all areas when prepping for an exam. You may not have time to rigorously prepare for every aspect, but you cannot afford to be lax in any one area, as examiners expect all areas of information security to be addressed. However, even if you are not where you need (or want) to be in any particular area, knowing where you are will often buy you additional time.

Our experience is that examiners will often give you additional time to address an issue if they know A) you are aware of it, and B) you have a plan in place (including a timeline) to address it. In short, if you haven’t had the opportunity to conduct a BCM exercise in the past 12 months, at least acknowledge it and have one on the calendar for the near future.

Ransomware on The Rise

As we discussed here and here, both the pandemic and cybersecurity will continue to dominate the infosec landscape for the foreseeable future, and because of that, are sure to receive special consideration during your next exam cycle. In particular, ransomware is a hot-button issue for examiners as attacks have been accelerating and cybercriminals capitalize on the security vulnerabilities and disruption caused by more employees working from home.

These malicious destructive malware attacks are becoming more targeted, more sophisticated and more costly, according to the FBI. Even more disconcerting is the fact that modern ransomware variants can not only lock data in place so that it’s no longer available to the institution but also exfiltrate data, making a secondary data disclosure attack much more likely. Another recent variant locks your data and initiates a distributed denial of service (DDoS) attack against your website if you don’t respond.

Resiliency

One common denominator between all five areas of focus is the concept of “resiliency”, which is the ability to withstand and recover from unplanned and unanticipated events. Examiners increasingly want to see a proactive approach to resilience, and when institutions implement the proper measures ahead of time, this can reduce their risk of operational downtime during a cyberattack, pandemic, natural disaster or another event.

Simply put, once ingrained into your practices and procedures, the reactive measures taken today become the proactive measures of tomorrow. Also, don’t forget to build resiliency into all future initiatives. If the initiative is important enough to implement and maintain, it’s important enough to protect from downtime.

Today, banks and credit unions are taking advantage of a host of resources to mitigate ransomware and other IT security issues, including the Cybersecurity Assessment Tool (CAT), the National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF), and the Ransomware Self-Assessment Tool (R-SAT). In addition, consulting with a third-party IT expert can help institutions better prepare for assessments and respond to difficult questions from examiners.

The bottom line is that regardless of the format regulators require for an examination, you can expect them to address a wide variety of areas. So, focus on the areas outlined here and in part one of this series, but be prepared to discuss all the relevant actions your institution is undertaking.

23 Feb 2021

Banks, Compliance, Credit Unions The Safe Systems Compliance Team 0 comment

Financial Institutions, Know What to Expect at Your Next Regulatory IT Exam

Part 1 - Financial Institutions, Know What to Expect at Your Next Regulatory IT Exam

While sometimes the IT examination is separate, most of the time it’s incorporated into the Safety & Soundness exam. Regulatory examinations like Safety & Soundness are designed to assess the financial health and risk management practices of a financial institution, and the results are expressed as a number “grade” from 1 (highest) to 5 (lowest). An information technology (IT) exam is narrower in scope and utilizes four components to assess information management maturity: Audit, Management, Development and Acquisition, and Support and Delivery (AMDS).

With the twin challenges of the Pandemic and cybersecurity continuing into 2021, on top of an already full plate of regulatory expectations, it’s critical for institutions to be prepared to address all IT issues to meet regulator expectations and ensure their safety and soundness.

So exactly what should financial institutions expect at their next IT regulatory exam? We’ll break it down in a two-part IT Exam Prep blog series.

The Pre-examination Questionnaire

On one hand, anticipating the exam elements is relatively straightforward, as the examiner will provide a pre-exam questionnaire. This is somewhat akin to an open-book test where the questions are provided ahead of time.

However, there is no single standardized questionnaire that all regulators adopt—and there likely won’t be in the foreseeable future. (The InTREx was an attempt by the FDIC a couple of years ago to standardize the process, but it is not yet caught on universally.) So, when the examiner sends his or her pre-exam questionnaire, that essentially provides the framework you should follow to prepare for your examination.

Nevertheless, bankers should expect a certain amount of the unexpected. While you should expect examiners to closely adhere to the pre-examination questionnaire, there will most likely be “curveball(s)” included. Curveballs are deviations from the questionnaire that could trip you up if you’ve followed it too strictly.

But if you’ve done your job correctly and addressed all infosec matters adequately since your last exam, you are better positioned to pivot when you need to during the exam. In other words, treat the pre-exam questionnaire more as a starting point than a checklist. And if you find yourself presented with a difficult question, do not respond with anything you are not 100 percent sure of, and that you know you can document. It is perfectly acceptable – and advisable — to wait and answer the question later when you have the appropriate information available.

One final point about examiner interaction: we strongly advise that your ISO be the primary point-person for the exam.

In most institutions, the ISO has the broadest and deepest knowledge of your information security procedures and practices. The ISO can bring in others as needed (network admin, internal audit, external providers, etc.), but they should still stay very close to the conversation. We’ve seen many situations where someone other than the ISO is interviewed by the examiner, and because of the person’s comparative lack of knowledge, it has resulted in exam findings that otherwise could have been avoided.

To ensure your financial institution’s next regulatory IT exam is a success, stay tuned for part two of our IT Exam Prep blog series, where we will dive into the key areas of focus you can expect to be evaluated on.

11 Feb 2021

Banks, Credit Unions, Security Jordan Hendrix 0 comment

Using Advanced Firewall Features and Other Technologies to Strengthen Network Security

A traditional firewall can only do so much to protect a network against the invasive security threats that financial institutions are facing. Add to that, cybercriminals are becoming more sophisticated and creative with their schemes, meaning banks and credit unions need more advanced defensive measures in place.

Malware and other cyber threats have been steadily increasing—especially against financial institutions, which are 300 times more likely than other companies to be targeted by a cyberattack, according to research by Boston Consulting Group. Institutions can capitalize on next-generation firewall (NGFW) features and other advanced technologies to increase the likelihood of warding off attacks, including:

Antimalware Scanning

Malware is intentionally designed for a perverse purpose: to damage a computer, server, client, or computer network. To keep malware at bay, banks and credit unions can use antimalware to thoroughly scan their computer network and detect and remove malicious ransomware, spyware, and other software that might be lurking on the system. Taking this proactive step can help institutions keep their network from being damaged, disrupted or compromised and overall improve the delivery of their services in a safe and secure manner.

Dynamic Threat Feeds

Threat intelligence data feeds can provide institutions with constantly updated information about potential sources of attack. Industry-specific feeds deliver up-to-date information on the latest security threats in the banking industry. Dynamic threat feeds make it easy for institutions to permit “good” network traffic in and “bad” traffic out while ensuring critical processes continue to work.

Dynamic threat feeds, essentially, take valuable parts of the information related to establishing connections and find similarities within them to act on potential or current threats. A key type of threat intelligence feed that institutions can implement are GEO-IP threat feeds. With this technology, a bank can map an IP address to the geographic location of an Internet-connected computing device. Then, they can analyze the Geo-IP data to detect threats from high-risk locations to improve their security posture. This analysis can be accomplished with processing times equal to less than a few milliseconds.

Another effective threat feed that institutions can use is IBM X-Force Exchange. This cloud-based threat intelligence platform allows banks to consume, share, and act on a variety of threat intelligences. IBM X-Force enables users to quickly research the latest security threats, gather actionable intelligence, consult with experts, and collaborate with peers. They can also integrate other tools to facilitate configuring feeds, providing a major benefit for smaller institutions with fewer resources. With dynamic threat feeds, banks and credit unions can have greater peace of mind with their firewall and security posture.

TLS/SSL Inspection

NGFWs offer capabilities that go beyond traditional firewalls, including inspecting TLS/SSL encrypted traffic. TLS/SSL technology helps protect online traffic; it creates an encrypted link between a web server and browser, ensuring the privacy of the data being transmitted. TLS/SSL inspection is important because it allows firewalls to scrutinize this encrypted web traffic and close holes in security. These security gaps could be exploited by would-be cybercriminals who attempt to use encrypted traffic for malware to circumvent the firewall’s inspections.

TLS/SSL traffic inspection allows institutions to decrypt traffic, inspect the decrypted payload for threats, then re-encrypt the traffic before it enters or leaves the network. Such deep content inspection can better protect institutions from internal and external risks. This makes TLS/SSL inspection the ideal defensive weapon against menacing malware and other security issues.

Sandboxing

Sandboxing can also help institutions augment their network security efforts. Traditional firewalls evaluate traffic based on static factors like where it originated, it is destination going, and the port being used. However, these are no longer sufficient for combating modern security threats. Sandboxing—physically or virtually segmenting a system, network, or entire environment—creates a secure location to test and neutralize potential hazards. Having a safe space to “detonate” payloads for analysis results in less risk and damage to the production environment, and, ultimately, enhances network security.

For more information about using advanced firewall features and other technology to strengthen network security, read our “Improving Security Posture Through Next-Generation Firewall Features” white paper.

14 Jan 2021

Banks, Compliance, Credit Unions The Safe Systems Compliance Team 0 comment

Looking Ahead to 2021: A Regulatory Compliance Update

As we mentioned in our previous blog, the Pandemic dominated the regulatory landscape early in 2020, and cybersecurity dominated the last few months of the year. This double-whammy forced financial institutions to quickly make operational adjustments to their procedures and practices. In the previous post, we explored the Pandemic. In this post, we’ll summarize the regulatory focus on cybersecurity in 2020, and look ahead to 2021.

Focus on Ransomware

The escalation of ransomware attacks (also referred to as destructive malware) has prompted a greater focus on addressing this aspect of cybersecurity. On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory to alert companies about possible sanctions for facilitating ransomware payments. Financial institutions should be aware that they (and their cybersecurity insurance provider) could be in violation of OFAC regulations should they decide to pay a ransom to anyone on the Specially Designated Nationals (SDN) list. This would place the institution on the hook for payments made by themselves, or by any third-party on their behalf. Institutions should address this issue during incident response testing by including their cyber insurance company and making sure they know that paying a ransom could trigger penalties or sanctions.

The heightened emphasis on ransomware also led to the release of a new Ransomware Self-Assessment Tool (R-SAT) in October 2020. Developed by the Bankers Electronic Crimes Taskforce (BECTF), the U.S. Secret Service, and state bank regulatory agencies, the R-SAT follows established best practices to help financial institutions reduce their risk of ransomware. We have reports from several banks around the country that their State examiners are requesting completion of the R-SAT prior to their examination. Unlike the CAT, the 16-question tool only allows “Yes” or “No” responses, it does not give users the option to answer “Yes with compensating controls”. This lack of flexibility does not work in the favor of smaller, less complex financial institutions, which may have informal practices in place that still accomplish the same objectives as the more formal practices of the larger institutions.

Nonetheless, the yes/no response format should not be an issue if institutions have already taken steps to address ransomware and, more broadly, cybersecurity. They can simply point regulators to relevant supporting details, (completed CAT assessments and incident response plans and tests for example) and that should be sufficient to demonstrate compliance. It’s also important to note that what we’ve heard from state regulators is that they are not strictly requiring institutions to employ the R-SAT, only that they intend to use the assessment as a starting point for further discussion. Increased discussion surrounding shared cyber threats facing financial institutions is never a bad thing!

Finally, the OCC released their semi-annual Risk Perspective in November and singled out cybersecurity as a key operational risk. While they point out that overall banks have adequate cybersecurity systems, they have seen some weaknesses related to IT, change management, and information security. We can expect increased scrutiny in these areas, and cybersecurity generally, for the foreseeable future.

What to Expect in 2021

One common denominator between the Pandemic and cybersecurity is the concept of resilience. Resilience, or the ability to withstand and recover from unplanned and unanticipated events, is all about proactive as opposed to reactive measures. It equates to implementing procedures ahead of time—rather than just responding to past events—to reduce the risk of operational downtime. Granted, the impromptu procedures established during the COVID-19 pandemic, or following a cyber-attack, are reactive in nature. But, once firmly in place and tested in the real world, they become the proactive resilience measures ready for when the next event occurs.

One additional factor common to both Pandemic and cybersecurity is proper management and oversight of third-parties. We expect that examiners will scrutinize how institutions manage the third-party lifecycle; from the initial decision to engage the third-party, to assessing and controlling on-going risk, to disengagement at the end of the relationship. Among the elements attracting attention are whether you are tracking the complementary user entity controls for critical vendors. These are found in the SOC 2 reports and list the controls expected of you by the vendor. Be aware of these vendor expectations, and document how you’ve addressed them.

In summary, take extra precautions in 2021 relating to cybersecurity (particularly ransomware), another potential Pandemic event, and third-party management. Document everything you’ve done or plan to do (e.g., resilience measures), and most of all stay flexible. If we’ve learned anything from 2020, it’s to expect the unexpected!

22 Dec 2020

Banks, Credit Unions, Security Brendan McGowan 0 comment

3 Top Security Threats Financial Institutions Must Defend Against

Security remains one of the primary areas of concern for community banks and credit unions, according to our recent sentiment survey and based on responses, the top three security threats that keep survey respondents up at night are cybersecurity, information security and ransomware.

Here’s a synopsis of each of these security categories as well as some proven best practices that can help institutions address them:

#1: Cybersecurity

Cybersecurity is a broad area for financial institutions to truly master, especial smaller community banks and credit unions with fewer resources to devote to defending themselves – something that National Credit Union Administration Chairman Rodney Hood has even acknowledged.
In today’s world, cybersecurity threats are ubiquitous, with cyberattacks 300 times more likely to hit financial services firms than other companies, according to a recent Boston Consulting Group report. However, banks and credit unions can take advantage of a number of resources to strengthen their security efforts. Two valuable tools include the Cybersecurity Assessment Tool (CAT) from the Federal Financial Institutions Examination Council (FFIEC) and the Automated Cybersecurity Examination Tool (ACET) from the NCUA.

Institutions can also capitalize on the National Institute of Standards and Technology (NIST) Cybersecurity Framework to address cybersecurity issues. Not only can the Cybersecurity Framework help institutions properly evaluate their defensive capabilities, but it provides policies and procedures that can help them identify and even resolve security issues.

#2: Information Security

The goal of information security is to prevent electronic and physical data from unauthorized access, use, disclosure, disruption, modification, inspection, recording or destruction. More specifically, information security is a set of strategies for managing the processes, tools and policies that are necessary to defend data when it is being stored and transmitted between different machine or physical locations.

The three basic principles of information security are what are known as the “CIA” triad: Confidentiality, Integrity, and Availability. “Confidentiality” relates to being able to identify who is trying to access data and block attempts by unauthorized individuals. “Integrity” entails maintaining data in its correct state and preventing it from being improperly modified—either by accident or maliciously. “Availability,” like confidentiality, equates to ensuring data can only be accessed only by users with the proper permissions.

Today, institutions face a variety of threats to their data security, including breaches, malware, and deceptive phishing emails that trick victims into divulging their private information. These types of attacks can have a detrimental and long-lasting effect on companies, such as a loss of customers, reputation, revenues, and profits.

Financial institutions are common targets of malware, phishing scams, and data breaches. About 50 percent of all unique organizations impacted by “observed” phishing domains were from the financial services sector, according to Akamai Technologies’ 2019 State of the Internet/Security Financial Services Attack Economy Report.

As a defensive tactic, organizations should implement a layered approach to preventing information security threats. This means employing multiple security measures, policies, and procedures, from patch management to secure software development. However, people can be the first—and best—line of defense, so educating employees about potential cybersecurity threats is crucial.

#3: Ransomware

As the name implies, ransomware is malicious software that is designed to block access to a computer system until the victim pays a sum of money. The ransomware threatens to publish the data or deny access to it either temporarily or permanently.

Regardless of how the attack is initially perpetrated, ransomware presents a serious threat to all types of organizations. It typically begins when someone downloads a malicious email attachment or visits an infected website. The ruse is often undetectable, so most victims are not aware the data breach is happening—until it is too late. Unfortunately, ransomware is difficult to stop, and it can take a huge toll on consumers and organizations, causing frustration, disruption, data loss, and financial damage.

The problem with ransomware is that it is both widespread in nature and costly to address. And ransomware attacks—along with other cyber scams—began surging during the COVID-19 pandemic, according to the July 2020 McAfee COVID-19 Threat Report. A recent example is Ransomware-GVZ, which displays a note and demands payment in return for decrypting the company’s compromised computer systems and the data they contain.

Fortunately, there are actionable steps financial institutions can take to defend their data against ransomware attacks. Some of the most practical measures include keeping operating systems patched and maintaining up-to-date malware software to detect potential threats. Another good practice: keep files backed up, so the data can be replaced if a hacker ever holds it hostage. However, the time to implement defensive data security strategies is before a cyberattack happens.

For more insight about these top three security threats and best practices to defend against them, download our Top 10 Banking, Security, Technology and Compliance Concerns white paper.