Category: Banks

21 Sep 2020
Three Often Overlooked Elements of an Effective and Compliant Incident Response Plan (IRP)

Three Often Overlooked Elements of an Effective and Compliant Incident Response Plan (IRP)

Three Often Overlooked Elements of an Effective and Compliant Incident Response Plan (IRP)

In today’s security environment, it’s not if a cybersecurity incident will impact your institution, but when and how big? That’s why having an effective and compliant incident response plan (IRP) is so important to ensure your institution is prepared for the unexpected and equipped to recover.

When a financial institution experiences a cyber incident, the information security officer (ISO), along with the incident response team, must assess the situation and determine if this incident has resulted (or might reasonably result) in exposure of non-public personal information (NPI). If the answer is “yes,” then the team must activate the IRP to contain and control the situation and ensure quick and efficient response and recovery. When activating an IRP, there are three key elements that we sometimes see financial institutions overlook:

1. Incident Response Team Participation

When building your incident response team, it is important to include representatives from each functional unit of the institution. Too often the incident response team consists of IT personnel only. While an incident might seem to be isolated to a certain department (like IT), there could be residual effects impacting other parts of the organization.

For example, let’s say you have an incident that seems to be limited to a group of customers who received a phishing email appearing to be from the institution asking them to click a link to change their ebanking password.

In this situation, you may be inclined to simply involve IT and deposit operation teams. However, because there could be a ripple effect that goes beyond that one incident, you’ll want to include other departments such as lending, human resources, and accounting. For instance, the customer could have a lending relationship or home equity line with the institution that might be impacted as well. Or, the customer could also be a vendor. Furthermore, with the increased possibility of pretexting during a social engineering attack, the Human Resources department may want to use the incident as an opportunity to conduct refresher training to ensure employees know how to verify customer information. As such, it’s important to have all your bases covered and include all functional units on the incident response team.

2. Designated Spokesperson and Social Media Monitoring

Once you’ve activated your plan, it’s important to understand that you cannot simply hope to contain the incident within your organization. A cyber incident may involve key external stakeholders including the Board and senior management, regulatory agencies, law enforcement, third-party service providers, insurance, legal, customers, and may even attract the attention of the media.

When an incident occurs, it is important to have designated spokespeople pre-selected to communicate with each external stakeholder that needs to be informed. For example, you’d want to have your IT admin in contact with the point person at your outsourced IT company because they most likely have a direct relationship with this vendor. However, you probably wouldn’t want that same person reaching out to regulators or customers. A member of senior management would be the best choice for that. In addition, you should designate one or more individuals to be your media contact. Don’t forget to have someone monitoring social media channels to ensure news about the incident isn’t spreading online potentially exposing you to reputational harm.

When developing an incident response plan, designating spokespeople to communicate with external stakeholders and monitoring online social media channels often gets overlooked because the main focus is usually on how the incident happened and how to fix it quickly. The moment the incident response plan is activated it is critical for the incident response team to assign these roles and keep these individuals updated with any interactions they may have with stakeholders.

3. Detailed Incident Documentation and Log Retention

It is imperative that the incident response team creates detailed documentation outlining everything that occurred from the time the event was first identified, even before it became classified as an incident. Again, this is often overlooked as the team engages in containment and control activities. However, regulators, insurance companies, third-party forensics companies, the Board, law enforcement, etc., will need full details when and if they are drawn into the incident. The documentation should detail who responded, what actions were taken, when each action was taken, (the timeline), and why and how (if known) the incident occurred.

Equally important is the retention of any data logs that might assist with the response and recovery phase. Often insurance carriers will need this information if they are involved, and forensic firms will definitely need it if they are drawn into the investigation phase.

We’ll dive deeper into security event logging and best practices for responding to a cyber incident in a future blog post.

For more information, register for our upcoming webinar, “Not If, but When: Best Practices for Cyber Incident Response.”

09 Sep 2020
Why Security Solutions Fail and What Your Financial Institution Can Do to Stay Safe Featured Blog Image_Header Image

Why Security Solutions Fail and What Your Financial Institution Can Do to Stay Safe

Why Security Solutions Fail and What Your Financial Institution Can Do to Stay Safe Featured Blog Image_Header Image

From the beginning of the pandemic, the financial sector has seen a rising number of security threats. With more employees working remotely and increasing their online activity, cybercriminals are finding success using attacks like phishing and social engineering to take advantage during these uncertain times. These attacks have prompted financial institutions and other organizations to improve their cybersecurity posture and protect against future attacks.

Financial institutions make significant investments to protect their networks especially as their workforce has turned to digital channels for remote work. However, there are a few additional security measures that often get overlooked.

In this blog post, we discuss 5 reasons why security solutions fail and what you can do to keep your institution safe and combat malicious attacks.

Improperly configured spam filtering/web filtering solutions

Every financial institution uses some form of spam filtering and web filtering solutions. However, IT personnel often set these solutions up, configure them, and then may not test them again, which creates vulnerabilities over time. Financial institutions must check to make sure these solutions are configured properly and understand all of the security features available to them to use these tools at full capacity.

Lack of multi-factor authentication for ALL accounts

Multifactor authentication (MFA) is crucial for financial institutions to protect against unauthorized access to the network and email accounts. In fact, a report from Microsoft has determined that 99.9% of account compromises can be blocked with MFA, but the overall adoption rate remains low.

Financial institutions often experience difficulties implementing an MFA program for their staff because it can be a time-consuming project and often requires staff to use their own personal devices. It is important to understand the different types of MFA solutions available and identify the one that works best for your staff. While there is variance among MFA solutions in terms of strength and security, having at least some form of MFA greatly enhances your security posture.

Lack of security coverage enterprise-wide

Not just IT, but everyone within the organization, should be practicing cybersecurity best practices to keep the network safe. Employees are often the weakest link when it comes to security and cybercriminals prey on these individuals to gain access to non-public information. Without proper training, your staff may not have the skills and awareness to spot security threats and handle them in the appropriate manner. Investing in security awareness training can provide them with the knowledge and expertise to combat malicious threats and ensure that the entire enterprise is working towards this goal.

Accessing external resources (Gmail/Dropbox)

When employees use external resources like Google Drive or Dropbox for file sharing, it can be difficult for IT personnel to control “what” data is going “where.” Cybercriminals are also using these file sharing tools to trick users into clicking links to fake websites to steal login credentials and then slip by corporate security protections.

To mitigate these issues, financial institutions can use credential theft protection tools to block usernames and passwords from leaving the organization. Even if a user fails to recognize the threat, these tools provide protection on the backend to keep the information safe.

Utilizing corporate resources remotely

With many employees working from home during the pandemic, financial institutions must take extra care to ensure the network is protected. It is important to understand how employees are connecting to the network; what devices they are using; and ensure that those devices are secured. Some employees may be using personal devices or public Wi-Fi to access the network. These are high risk behaviors that can have detrimental impact on the institutions if attackers are able to exploit vulnerabilities through these entry points.

As employees continue to work remotely, they should be using corporate devices; avoiding public Wi-Fi; and accessing the network through a virtual private network or another secure remote access device. Ultimately, it will be staff’s ability to reference remote access policies and practice appropriate cyber hygiene on remote devices that helps keep their institution secure.

Keith HaskettKeith Haskett is the president and CEO of Rebyc Security and is responsible for executing their strategic plan. After several years leading the Risk and Information Security Consulting Services practice at CSI, he co-founded Rebyc to deliver offensive security solutions customized to meet the needs of the highly regulated, financial services industry. His teams have delivered over 2,000 engagements to financial institutions nationwide.

For more information on protecting your institution from security threats, view Rebyc Security’s recent blogs.

03 Sep 2020
The Peoples Bank Implements Virtual ISO Solution to Support Succession Planning for the ISO Role

The Peoples Bank Implements Virtual ISO Solution to Support Succession Planning for the ISO Role

The Peoples Bank Implements Virtual ISO Solution to Support Succession Planning for the ISO Role

The ISO is tasked with multiple simultaneous activities; supervising the financial institution’s business continuity planning, project management, vendor management, cybersecurity, exams and audits, and information security, which can be an overwhelming responsibility for one person to manage. This presents operational and compliance challenges for the institution if there is no second-in-command should the ISO become suddenly unavailable. For this reason, the Federal Financial Institution Examination Council (FFIEC) in their Management booklet outlines the importance of succession planning for key roles within the institution, including the ISO.

The Challenge

Effective succession planning involves proactively identifying alternate personnel and initiating proper cross-training for critical roles well in advance. A case in point is Billy Peele, who has worked with Iva, South Carolina-based The Peoples Bank for 45 years, and who has plans to retire by the end of 2020. Overseeing the bank’s IT and InfoSec departments, Peele has also functioned as the institution’s ISO. With a succession plan in place, the bank selected Jill Seymore and Addrian Wilson to jointly assume the title and responsibilities of the ISO in preparation of Peele’s departure.

Although highly skilled in banking operations, Seymore and Wilson initially lacked the level of ISO related experience necessary to fulfill the role. Specifically, the pair wanted a better grasp on the IT reports and to learn best practices in reviewing these reports from the ISO perspective. This learning curve could have been overwhelming for the new ISOs, but The Peoples Bank decided to implement a proven virtual ISO solution to give Seymore and Wilson the tools to become more confident in the new role.

The Solution

Too often, new ISOs do not receive a detailed hand-off document from the predecessor and may not know where to start to complete key responsibilities. Fortunately this was not the case for The Peoples Bank as Safe Systems’ ISOversight Virtual ISO Solution formalized all responsibilities into a structured framework for Seymore and Wilson, allowing for methodical review of all tasks on a monthly, quarterly, and annual basis to ensure continuity for the bank.

ISOversight serves as a risk management tool designed to support the role of the ISO by augmenting existing personnel and ensuring that all tasks and related activities are completed on time and properly reported to the various stakeholders. ISOversight helped ease Seymore and Wilson into the ISO position by grouping all of the various responsibilities into a unified platform to effortlessly manage compliance and security activities. Not only did this clearly outline key requirements of the ISO, but it also educated Peele’s successors on how to effectively perform the role.

The Results

ISOversight gave Seymore and Wilson the confidence that allowed them to trust the bank’s IT department while verifying all interrelated activities are running smoothly and securely. Reviewing reports and receiving alerts with the assistance of the VISO helps the new ISOs extract relevant, actionable information to determine if there are anomalies or exceptions that they should be aware of and act on.

The key to succession planning is to find ways to standardize and maintain the consistency and continuity of the responsibilities of the ISO. In this case, the bank can be confident that information is secure, tasks are being completed on time, and documentation is shared with auditors, examiners, and the board. At The Peoples Bank, ISOversight provided a seamless transition for Seymore and Wilson, while laying a solid foundation for future ISO activities.

For more information, download the full white paper, “5 Case Studies: Exploring Common Challenges Faced By The Information Security Officer.”

27 Aug 2020
Three Virtual ISO Delivery Models for Community Banks and Credit Unions

Three Virtual ISO Delivery Models for Community Banks and Credit Unions

Three Virtual ISO Delivery Models for Community Banks and Credit Unions

Management should designate at least one information security officer responsible and accountable for implementing and monitoring the information security program.
– FFIEC Information Security Handbook

Information security officers (ISO) have a wide range of responsibilities and navigating them can be quite challenging, especially with increased scrutiny from examiners on alignment of policies, procedures, and practices. Adding to that challenge is the associated element of accountability; the premise that unless your practices are properly documented and reported to the various stakeholder groups, there may be doubt in the mind of the examiner as to whether or not they actually happened.

As a result of this responsibility + accountability challenge, many financial institutions are turning to virtual information security officer (VISO) solutions to support the role of the ISO by augmenting existing personnel and ensuring all tasks and related activities are completed on time; are following approved procedures; and are properly reported to the various stakeholders.

In a recent webinar, Safe Systems outlined the three virtual ISO delivery models available to community banks and credit unions today and discussed key considerations when implementing each.

1. Outsource All Activities

In this model, the financial institution hires a third-party provider to take on all of the responsibility and accountability tasks of the ISO role. Outsourcing these activities minimizes your staff’s involvement, potentially freeing up time to focus on more revenue generating activities, but this approach is typically more expensive because the third-party provider is doing all of the heavy lifting.

Another important consideration is that outsourcing everything can also isolate key personnel from important procedures and practices. If the institution isn’t involved in the day-to-day information security activities, when IT auditors and examiners question your personnel, they may not have the necessary day-to-day procedural knowledge to answer their questions. For example, there will likely be activities the outsourced provider is doing that the ISO is unaware of or they are using procedures not familiar to your personnel. This could lead to audit and examination observations or findings, as the ISO is expected to have comprehensive knowledge and understanding of all information security activities

Outsourcing information security tasks is best for financial institutions with neither the time, expertise, nor inclination to perform the duties of the role. However, it comes at a higher cost, both in terms of capital outlay and also in the possibility of ISO disassociation from actual procedures and practices. The FFIEC Management Handbook uses terms such as “engaging with…,” and “working with…,” and “participating in…,” and “informing…,” to describe the typical responsibilities of the ISO. This level of involvement may be more difficult under the “outsource all” model.

2. Toolset only (Apps, Checklists, Templates, etc.)

Another option is to select a model where there’s a toolset provided to accomplish ISO tasks. The toolset could consist of applications, checklists, or templates that may be prefilled or partially filled. With this model, you’re given the tools to manage ISO responsibilities without the support. There’s less human interaction, which typically means the service is less expensive.

However, the toolset model requires more effort from staff and requires the financial institution to rely on internal resources for information security expertise and guidance. Without this guidance, this model may also introduce some inconsistencies between the institution’s policies and procedures. For example, if you specify something in one area of your policies and you reference something that may conflict with that in another area, auditors are likely going to notice and question you on it, and that could cause them to dig deeper into other areas. Policy/procedure consistency is one of the most important indicators of strong infosec governance.

This model may include access to compliance guidance and expertise, but it would be reactive instead of proactive. It is best for institutions that have the necessary internal expertise, but they just need the additional structure a toolset provides to ensure all activities are completed in a timely manner.

3. Hybrid (Toolset + Consultation)

Finally, a hybrid model combines the first two models to provide a toolset plus additional expertise, proactive guidance, and consultation. It typically has better integration between various ISO practices because it’s all under one umbrella. As a result, the institution gains consistency and better coordination within and among its policies for business continuity, vendor management, incident response, project management, and information security. However, because of the tight integration, financial institutions that do not adopt all of the tools that support this model may not see the maximum benefit. Also, because of the increased level of ISO engagement, it may be more resource intensive initially, especially if the institution is behind on key ISO tasks. However, once tasks are brought up to date, ongoing maintenance is simpler due to the integrated toolset. This model is also quite flexible and can easily adapt to the evolving needs of the institution.

This is the model we decided to adopt for our virtual ISO solution, ISOversight. We’ve found this model is best for institutions that desire the advantages of regular active involvement with outside expertise, plus a toolset and reporting to ensure the ISO remains fully engaged. The price point is somewhere between the other two models; less than a complete outsource, but a bit more than toolset only.

ISOversight is a risk management solution that provides accountability for all of the responsibilities of the ISO. We have monthly touch point meetings, and we tailor the service to meet each institution’s unique requirements.

To learn more about the information security officer role and the benefits of virtual ISO solutions, watch our recorded webinar, “ISO Requirements and Expectations: Accountability vs. Responsibility.”

20 Aug 2020
Banking Bits and Bytes

What You Need to Know About Securing Exchange Online

What You Need to Know About Securing Azure AD

Technical Level: Beginner/Intermediate
TLDR: Microsoft recently released the GA version of their Exchange Online V2 module for PowerShell. In order to configure some of the more advanced settings for Exchange Online, familiarity with PowerShell is going to be required. Knowing how to store variables, run commands, and connect to Exchange Online will be the bare minimum to get started.

Exchange Online Security

Exchange online security is another one of those huge areas that can be difficult to cover in just one sitting. Topics here can range from making sure offboarded employees cannot sign in, to disabling protocols per user, or preventing client access for the entire organization based on protocol, user, or public IP, and that is just the start of it. Our future posts will go into some of the more intricate details of securing Exchange Online but before we can do that, we need to make sure everyone is familiar with PowerShell (PS) at a base level.

The reason for this is three-fold. First, some information can only be gathered via PS. Second, some settings can only be configured via PS. Third, when you need to affect users at a large scale, you will need PS for some settings (unless you like clicking through the Exchange Admin Center a million times).

Practical PowerShell Basics

Disclaimer: We aren’t going to go over the finer details of the “internal machinations” of PS. Our goal here is practical use of PS for administration of Exchange Online. The terminology, definitions, and examples are all geared toward this purpose with an intended audience being those beginning to use PS.

Let’s go ahead and set the stage by opening PS and checking to see what our version is. You can do this by running the following command:


When you run the command, you will see your PS version information displayed on the screen:

Securing Exchange - Code Example

These results introduce us to a couple of core concepts: variables, shortcuts (aka Aliases), and command logic.


Variables are just another name for a container in PS. Think of a basket. You can place any number of objects, like say bread, cheese, and wine, into a basket and go have a picnic. You won’t have a picnic if you are working in PS but it can be just as fun!

With the example above, $PSVersionTable is our basket and it holds one object, a Hashtable. That Hashtable has Key/Value pairs that equate to what was displayed on screen. Just like a basket can hold multiple items, so too can a variable hold multiple objects. Let’s go ahead and try it out.

Note: The $ is what designates the start of a variable name and what ends that designation is a space. In the example above, we end the designation with a carriage return.
Run the following command:

$Basket = “Bread”, ”Cheese”, ”Wine”

Your results should look like this:

Securing Exchange - Code Example

What we have done here is create a variable named Basket and assigned it a set of string objects where a string is a set of characters. In other words, we stored those objects in the Basket container. The next command should look familiar. By typing the variable name with a $ in front of it, we tell PS to show us what the contents of the container are.

Note: Variable assignments will get much more complex from here on out and so will our use cases for variables. However, understanding how they fundamentally function is the first piece of this puzzle.

With both commands completed, we are ready to venture into some of the shortcuts available within PS and wouldn’t you know it, there is already some mastery of this topic, so congratulations!

Shortcuts (Aliases)

To introduce shortcuts properly, realize that all the commands we have run so far have been cut short from their original iterations. For example, if we wanted to do the same exact variable assignment for a variable named Basket2 and then show what the values of that variable are, this is what the long-form approach would look like:

New-Variable -Name "Basket2" -Value "Bread", "Cheese", "Wine"
Get-Variable -Name “Basket2”

Your results will look like this:

Securing Exchange - Code Example

Notice that the results from the Get-Variable command do not match what we get if we were just to show the variable by running $Basket2. This is because what is returned by the Get-Variable command is the variable, not the contents of that container. In other words, it is like picking up the entire basket, filled with items. While you can “see” inside the basket (the value column pictured above), to actually access the items inside you need to “open” the basket.

We will open the basket with the use of another core shortcut concept called piping. When we pipe in PS, we take all the results of a command and feed them into another command. For example, let’s run the following code to get the values of the Basket2 variable from the Get-Variable command:

Note: The | character is called a pipe. You can type a pipe by holding down Shift and pushing the Backslash button (usually found above the enter/carriage return key on a QWERTY keyboard).

Get-Variable -Name “Basket2” | Select-Object -ExpandProperty Value

The results of the command will now show the contents of Basket2:

Securing Exchange - Code Example

This brings us to the last topic for this post, command logic.

Command Logic

Command or script logic is the flow of the PS commands throughout a PS session. At a high level, command logic is read from top to bottom and left to right. More intricate scripts can get more ambiguous as preset groupings of commands, called functions, allow script logic to be reused throughout a script. For now, we can focus on how command logic can be used to pair multiple commands together to achieve desired results.

We mentioned earlier that the pipe command is a shortcut. So how else can we show the results of our Get-Variable command (“open” the basket) without the pipe? We could run the following commands:

foreach($picnicItem in $(Get-Variable -Name "Basket2").Value) { Write-Host $picnicItem}

Note: There is a bit of redundancy here since we started off with a variable assignment and now are having to do some variable assignments for each returned result. This is just an example of how else to open a container. The shortcuts exist for a reason, use them!

The results of the command will show that the output now matches what was previously generated from our other commands:

Securing Exchange - Code Example

From left to right, there are a couple of new concepts that need to be explained. First, is the concept of a foreach statement. The foreach statement is a templated function in PS that allows the iteration of the objects in a container, one at a time. The basic structure is as follows:

Foreach("New Variable" in "Existing Variable"){ "Command logic to run" }

Like all variable assignments, the names of new variables are entirely up to the creator. will be used throughout the command logic as a representative item from .

Note: In the logic above, wrapping our command logic in $() lets PS know that we expect it to evaluate every command contained within and use that output as our . We add on the .Value because we need to access the individual values of the as a collective set.

For the script above, if we translate the code to layman’s terms, what we are saying is as follows: For each picnic item in the basket, tell me what that item is.

When PS is handling the command logic, it follows those orders exactly. First it considers the foreach() parameters and grabs the first item in the basket and stores that item in the picnicItem variable. In this case it is “Bread”. Then PS looks at the command logic and sees the request to write the value of the variable onto the console, so it displays Bread on the console.

After the command logic is completely evaluated, PS will then take it from the top again, but this time will grab the next item from the basket, in this case “Cheese” and store it in picnicItem. Then PS will evaluate the command logic, which states to write the value of the object onto the console, so it displays Cheese on the console.

PS will continue to iterate through all the items in the basket until no more items are left and then the command’s run has ended. To start winding down, we are going to go over a little bit of a more complex assignment scenario. So far, we have kept things simple and manually assigned some strings to a variable but as we progress, the assignments are usually dynamically populated from the results of commands, so we need to get used to doing that. For example, if we wanted to store the objects representing all the running processes on our current machine, we could do an assignment variable like this:

$Processes = Get-Process

We could then manipulate the objects in that variable any way we see fit. For example, to show only the processes named chrome, we can pipe the results of the object to a Where-Object command that we can use for filtering:

$Processes | where-object {$_.ProcessName -eq “chrome”}

Securing Exchange - Code Example

Remember that when piping, the functional equivalent is a foreach statement. In this case, $_ is akin to the assignment of an iteration and we are accessing the ProcessName property.


We can only have so much fun in a day with PS before we start to lose focus, so this is a good stopping point. We went over variables, how to assign values to them, how to use shortcuts to cut down on our work, and how command logic is structured. Stay tuned for more PowerShell Basics as we dive into connecting to Exchange Online and using what we have learned to administer users and settings.

Microsoft Source:
Exchange Online V2 Module:

18 Aug 2020
Banking Bits and Bytes

What You Need to Know About Securing Azure AD

What You Need to Know About Securing Azure AD

Technical Level: Beginner
TLDR: Microsoft has decommissioned Baseline Conditional Access Policies and has replaced them with the new Security Defaults as of the end of February 2020. If you have been using Baseline Conditional Access Policies, Microsoft advises that you move to the new Security Defaults policy or to custom Conditional Access Policies.

Azure AD Security

Security within Azure is a huge topic covering a range of services offered by Microsoft. Everything from password protection, to data protection, to device protection, the list goes on and on. Our future posts will go into what you could be doing to protect your Azure instance. For this post though, we are going to go over what you can (and arguably should) be doing at a minimum to secure your Azure instance.

First, we will go over what the current system is and then what the new system will be.

Baseline Conditional Access Policies

Microsoft has recognized that customers of all licensing levels have security concerns. To help their customers, they released these free Baseline Conditional Access Policies. With this system, Microsoft basically said, here are some Conditional Access Policies that you don’t need to pay for that are going to help protect your Azure instance. There are four individual policies covering four important security vectors:

  • MFA for Admins
  • MFA for All Users
  • Legacy Authentication Block
  • MFA for Service Management

As you can tell by their names, the set of policies are largely focused around Multifactor Authentication. A recent blog by Melanie Maynes, Senior Product Marketing Manager, Microsoft Security, states over 99.9 percent of account compromise attacks can be blocked with MFA.

The remaining policy, governing Legacy Authentication, is also indirectly related to MFA in that the protocols that are used for Legacy Authentication (POP, IMAP, older Office desktop clients) can also be used to bypass MFA. The policies just don’t have the capability of utilizing more than a single factor for authentication, so it doesn’t provide as much security if you enable MFA for your users but then also allow them (or a bad actor) to bypass MFA with Legacy Authentication protocols.

What you should know about Baseline Conditional Access Policies is that the set of four policies can be enabled individually, independent from each other. This is important because you cannot modify the policies. If your organization has a use case for a single user, or small set of users, that needs a Legacy Authentication protocol you can’t just add exclusions like you would to a normal Conditional Access Policy. Instead you would have to leave the entire Baseline Conditional Access Policy disabled. Obviously, you would need to weigh the consequences of this action but at least you have the choice of keeping the other MFA related policies enabled and just keeping the Legacy Authentication policy disabled.

Security Defaults

In a recent article, Alex Weinert, Director of Identity Security at Microsoft, goes over the reasons for adding in Security Defaults. In the article, he goes over some of the attacks Microsoft sees and why they have been evolving their base security levels for customers. He also briefly mentions the Baseline policies with an indication that they were just one attempt at trying to secure customers but that they ultimately moved away from the Baseline policies based on customer feedback and their other learnings. Whatever the reason for the switch, at the end of February 2020, they got rid of the Baseline Conditional Access policies and replaced them with a new Directory property called Security Defaults. Really, it is just the same Baseline policies with one catch: it is an all or nothing switch. You won’t get to choose which of the policies you enable and which you don’t.

Enabling Security Defaults

The distinction is important for any organization that isn’t quite ready to invest in Conditional Access Policies for added security. If your organization has processes which utilize Legacy Authentication protocols (which include Basic Authentication for Remote PowerShell and SMTP for printers/scanners!) enabling the Security Defaults will break those processes. If you are a CSP using RPS with Basic Authentication for automated, non-interactive, connectivity to Exchange Online, you will need to make sure you have converted your processes to utilize Microsoft’s Secure Application Model. For your printers/scanners, you will need to utilize a relay capable of modern authentication or authentication via certificate or IP.


In lieu of paid for Conditional Access Policies, where you can customize policies and make exceptions, the new Security Defaults provide a simple and effective way of protecting your Azure AD instance. If you plan on enabling them, just be sure to understand that they block Legacy Authentication which could cause some issues with automated non-interactive connectivity or with your printers/scanners for those that utilize Basic Authentication with SMTP. If you utilize Exchange Online and have printers/scanners that fall into this category, consider setting up a relay with authentication based on certificate or IP (we will be going over this later as well).

If you are already using the Baseline Conditional Access Policies but picking and choosing among the four, be prepared to purchase licenses for Conditional Access Policies or be prepared to enable the entire set of them via Security Defaults.


13 Aug 2020
One Florida Bank Achieves Rapid Growth and Streamlines Information Security with ISOversight

One Florida Bank Achieves Rapid Growth and Streamlines Information Security with Safe Systems’ Virtual ISO Solution

One Florida Bank Achieves Rapid Growth and Streamlines Information Security with ISOversight

Mergers and acquisitions can present significant operational challenges for information security officers (ISO) who are tasked with ensuring a smooth transition of the information security program. Often, some key responsibilities of the ISO may be overlooked as other tasks related to the merging of the two institutions take precedence, overextending the ISO as they work to manage the information security program effectively and stay on top of regulations.

The Challenge

Eric Nadeau, chief financial officer at One Florida Bank, faced this very issue when his bank acquired another bank in Florida to expand the institution’s reach across the state. Nadeau wore many hats at the bank serving as the information security officer, chief financial officer, head of accounts payable, and director of both HR and IT. Although Nadeau understood the role and responsibilities of the ISO, he simply lacked the necessary time required to develop a formal program to efficiently complete all ISO-related tasks.

After acquiring the other bank’s charter and then merging the two institutions, Nadeau knew that his bank’s existing compliance management practices would not be enough to accommodate the rapid growth and continue to satisfy the regulators. While he needed assistance in managing the information security program, the institution was not yet ready to make the investment to expand personnel by adding a dedicated ISO.

The Solution

Following the merger, the bank needed a strong operational structure in place to get the now larger institution up and running and meet regulatory expectations quickly. During the acquisition process, Nadeau was introduced to Safe Systems’ ISOversight VISO (Virtual Information Security Officer) solution. The institution One Florida Bank acquired was already a Safe Systems customer using its network management services. After learning more about the VISO and compliance program, Nadeau performed his due diligence and made the decision to implement the ISOversight solution to streamline the bank’s information security processes.

A VISO serves as an extension of the in-house ISO by augmenting existing personnel and ensuring all tasks and related activities are completed on time and are all properly documented and reported to the various stakeholders. ISOversight’s integrated approach to vendor management, business continuity planning, cybersecurity, strategic planning, and information security influenced Nadeau to implement a VISO strategy.

“We had a very aggressive growth plan and I was wearing many hats. I couldn’t cobble together a bunch of Excel-based risk assessments and manual tasks into a formal process within an acceptable time frame,” said Nadeau. “I needed a support structure that I could leverage very quickly to sustain our bank’s strong and rapid growth plan and ISOversight provided that.”

The Results

While Nadeau expected the bank to grow, he did not anticipate that the bank would become a $690M institution in just 18 months. With ISOversight, Nadeau was able to quickly implement new operational structures for the institution amidst this rapid growth.

ISOversight combines all the various risk assessments into one centralized portal with ease, eliminating the use of multiple spreadsheets and numerous documents. The VISO enabled the bank to create a new compliance infrastructure with easy-to-read summaries of all ISO activities, as well as establish a new fully compliant business continuity management plan, a robust vendor management program, and comprehensive project and audit/exam tracking. ISOversight provides an integrated approach to all these initiatives as they all work hand in hand.

“The first year after the acquisition required a massive amount of work, but ISOversight allowed our bank to prioritize and complete tasks until we reached a smooth and successful integration,” said Nadeau. “Even examiners have commented on the progress we’ve made and recognized the value that the integrated platform provided to our management.”

For more information, download the full white paper, “5 Case Studies: Exploring Common Challenges Faced By The Information Security Officer.”

06 Aug 2020
Managing Information Security Requirements and Expectations: Accountability vs. Responsibility

Managing Information Security Requirements and Expectations: Accountability vs. Responsibility

Managing Information Security Requirements and Expectations: Accountability vs. Responsibility

Of the many roles within a financial institution, the information security officer (ISO) is the most critical for the protection of confidential and nonpublic personal information and maintaining compliance with federal regulations. In fact, the Federal Financial Institution Examination Council (FFIEC) goes so far as to mandate that all financial institutions have one or more individuals dedicated to the position of ISO.

Safe Systems held a webinar last week outlining the most common challenges for ISOs and some helpful ways that they can better identify, perform, and document their regulatory responsibilities. In this blog post, we’ll highlight two of the most important elements of the ISO role and outline 8 key regulatory responsibilities all ISOs should focus on to meet examiner expectations.

Key Elements

For ISOs, everything ultimately hinges on responsibility (specific tasks the ISO must perform) and accountability (specific documentation ISOs must provide to key internal and external stakeholders). In fact, these terms are referenced multiple times within the FFIEC guidance:

“The ISO is responsible for overseeing and reporting on the management and mitigation of information security risks across the institution and should be held accountable for the results of this oversight and reporting. – FFIEC Management Handbook

“Management should designate at least one information security officer responsible and accountable for implementing and monitoring the information security program.” – FFIEC Information Security Handbook

Individuals in the ISO role must effectively demonstrate both elements to adequately meet regulatory expectations.

Maintaining Compliance

The ISO must not only be able to perform key responsibilities of the role, but he or she must also provide proper documentation to specific stakeholders to satisfy the accountability requirements. The FFIEC’s Management Handbook outlines 8 key responsibilities of the ISO role including:

  1. Implementing the information security strategy and objectives, as approved by the board of directors, including strategies to monitor and address current and emerging risks
  2. Engaging with management in the lines of business to understand new initiatives, providing information on the inherent information security risk of these activities, and outlining ways to mitigate the risks
  3. Working with management in the lines of business to understand the flows of information, the risks to that information, and the best ways to protect the information
  4. Monitoring emerging risks and implementing mitigations
  5. Informing the board, management and cybersecurity risks and the role of staff in protecting information
  6. Championing security awareness and training programs
  7. Participating in industry collaborative efforts to monitor, share, and discuss emerging security threats
  8. Reporting significant security events to the board, steering committee, government agencies, and law enforcement, as appropriate

When performing these key responsibilities, the ISO must reference the institution’s policies (what you say you do); procedures (how you say you’ll do them); and actual practices (what you actually do and are able to document). In our experience, we’ve seen that there is often a gap between procedures and practices, which often results in the majority of audit and exam findings for financial institutions.

To address this issue, many community banks and credit unions are turning to virtual ISO solutions. A virtual ISO platform serves as a risk management solution that addresses the regulatory expectations and important tasks that the ISO must oversee. The solution helps financial institutions augment their internal ISO role, streamline responsibilities, and ensure the institution’s procedures and practices are properly aligned. Most importantly, a virtual ISO can make sure that all stakeholders; Board, committee, auditor, and regulator, have the appropriate reports to document that alignment.

To learn more about the information security officer role, the 3 virtual ISO delivery models, and the benefits of virtual ISO solutions, watch our recorded webinar, “ISO Requirements and Expectations: Accountability vs. Responsibility.”

04 Aug 2020
Maintaining Information Security to Combat Cyber Attacks

Maintaining Information Security to Combat Cyber Attacks

Maintaining Information Security to Combat Cyber Attacks

As banks and credit unions continue to work to keep all employees and customers/members safe during the pandemic, information security should be a top priority. Because many businesses and consumers have shifted towards digital channels, threat actors have launched a new wave of attacks specifically targeting financial institutions and other financial activities. According to VMware Carbon Black, attacks against the financial sector increased 238% globally from the beginning of February to the end of April. Protecting your institution’s nonpublic personal information is critical as we continue to move forward in a heightened security threat landscape. Here are a few things to keep in mind:

CIA of Information Security

Information security focuses on ensuring the Confidentiality, Integrity, and Availability of virtually all forms of information. It involves protecting digital and physical data from unauthorized access, use, disclosure, disruption, modification, inspection, recording, or destruction. Some of the most serious—and alarming—threats to information security are data breaches, malware, and phishing.

  • Data Breaches
  • With data breaches, sensitive, confidential, or otherwise protected information is accessed or inappropriately disclosed. The negative impact of such a breach can result in diminished customer loyalty, a tarnished brand image, and loss revenues and profits. These adverse effects can last for years—with some companies never recovering.

  • Malware
  • Malware is any piece of software that was written with the intent of damaging devices and/or stealing data. There are many different types of malware including, viruses, trojans, spyware, and ransomware. Fintech holds a special interest from the malware community-at-large. According to cyber threat intelligence company Intsights, 25 percent of all malware targets financial institutions.

  • Phishing
  • With phishing, cyber attackers use fraudulent emails and websites to solicit people’s credit card numbers, passwords, account data, and other personal information. Financial institutions are common targets of phishing scams that are engineered to trick victims into disclosing their information.

Best Practices for Information Security

Security threats can affect financial institutions through numerous weaknesses. So institutions should take a layered approach by using a combination of security measures, policies, and procedures. According to the FFIEC IT Handbook’s Information Security booklet, common layers in security controls should include:

  • Patch management
  • Asset and configuration management
  • Vulnerability scanning and penetration testing
  • Endpoint security
  • Resilience controls
  • Logging and monitoring

However, since humans are often considered to be the first—and best—line of defense for preventing cyber-attacks, employees need to receive the proper education and training on the latest scams and techniques. By teaching staff how to detect suspicious emails, links, and websites, financial institutions can significantly strengthen their security and avoid unnecessary trouble. The more user training an institution provides, the lower the success rate of phishing attacks against that institution. Ultimately, an institution’s approach to security will depend on the assets it is protecting, along with its unique vulnerabilities, operation, and strategic objectives.

For more information, download our complimentary white paper, “Top 10 Banking Security, Technology, and Compliance Concerns.”

23 Jul 2020
Securing Microsoft O365

Securing Microsoft 365: Using Multifactor Authentication to Combat Business Email Compromise

Securing Microsoft 365

In today’s security landscape, business email compromise (BEC) is one of the most prolific online crimes, and these attacks are often aimed at financial institutions. In a BEC scam, cybercriminals send email messages to bank staff that looks like a legitimate request in an attempt to gain access to non-public information. To mitigate this threat, community banks and credit unions should take advantage of the security settings offered in Microsoft 365.

Microsoft has multiple service offerings to secure against all kinds of attack vectors. However, the easiest security setting financial institutions often overlook is multifactor authentication (MFA), which requires more than one method of authentication to verify a user’s identity for a login or other transaction. The methods typically include something you know (pin); something you have (phone) and/or something you are (biometrics).

Microsoft’s analysis has determined that 99.9% of account compromises can be blocked with MFA, but the overall adoption rate is only 46%. Why is this the case? Financial institutions run into two key pain points that prevent them from implementing MFA:

1. Time

Many IT administrators are tasked with having to set up their users on MFA, and simply don’t have the resources to do this all on their own. Let’s face it, this can be a time-consuming task to complete in addition to the other daily IT activities IT admins have on their plate. One option is to identify who your early adopters will be and let them become technology champions. This can be branch managers or team leads across your locations that can offer assistance to less experienced users. Another option is to work with a third-party provider that can handle the implementation process, enabling IT staff to work on more pressing tasks for the institution.

2. Bring Your Own Device (BYOD)

Most organizations have a BYOD policy in place, but it is normally in regard to accessing company resources, like email, teams or SharePoint where it is clear that the user is attempting to access company data for business-related activity. However, employee-owned devices can make MFA trickier to navigate since IT administrators may find themselves in a position where they are asking users to complete the MFA process on a personal device in order to access these company resources. Regardless, when MFA is added to the BYOD policy, it can effectively make BYOD safer.

MFA Options to Fit Your Institution’s Needs
There are many MFA options and some of them do not require the use of a personal device to verify a user’s identity. Many employees do not like the idea of having to install a mobile app on their phone, but they have no issues with an occasional text message or phone call. When implementing MFA for your institution, the best thing you can do for your users is to go over all of the available options and highlight the option your institution prefers them to use. For instance, when setting up MFA for our customers, we recommend the Microsoft Authenticator App.

Here are a few options to consider:

  • Microsoft Authenticator App – A user will use a one-time passcode or simply approve logins using the free Microsoft Authenticator app.
  • Call to Phone – This option is for landline phones. If your employees have a direct line, this is a good option to try. If the user does not have a direct line, keep in mind you would have to work out a procedural system for whoever is answering the phone to give the MFA information to the intended target.
  • Text message to phone – Sends a text message to the user’s mobile phone number containing a one-time code whenever you sign in from a new device.
  • Notification through desktop – Allows users to have MFA one-time passcode generation on their work desktop which helps to avoid use of personal devices.
  • Verification code from hardware token –User uses a one-time passcode generated from a hardware token. Microsoft provides the technology to implement this method, but you have to buy the hardware tokens and manage them. This is the only MFA method that comes with direct costs.

Not all MFA options are the same in terms of strength of security. However, your overall security posture is still enhanced by enabling MFA with any of these options. MFA is a low-cost option that protects your financial institution from cyber-attacks and other malicious activity. If you’re interested in implementing MFA for your financial institution, please reach out to Safe Systems to find an option that fits best with your institution’s unique needs.