Category: Banks

05 Aug 2022
The Importance of Succession Planning

The Importance of Succession Planning to IT and Information Security Resiliency

The Importance of Succession Planning

Change can be challenging—especially when it involves the transition of IT management and other key personnel. That’s why it’s imperative for banks and credit unions to be proactive about succession planning.

While regulators expect institutions to have a formal succession plan for key leadership roles, having a strategy for filling critical positions is a matter of practicality. If an IT administrator or information security officer (ISO) is not in place, or not available to complete the tasks, reports, and other responsibilities of these roles, then it could lead to cyberattacks and other security issues. This, in turn, can have dire consequences on a financial institution’s operations, risk-profile compliance, and reputation.

Succession Planning Strategies

Institutions can ensure IT and information security resiliency by having an effective plan for managing the absence of key security-related personnel. Depending on their size, type, and goals, they can adopt any of these approaches to succession planning:

  • Proactively assess internal talent and then orient the most suitable individual to serve as an alternate or backup for various IT admin or ISO responsibilities. The ISO alternate, for instance, should train with the existing ISO, attend ISO oversight meetings, and present appropriate information to executive management and the board. If the ISO leaves, the backup individual should be equipped to assume the role temporarily or even for the long term if necessary. Training a staff member to perform IT or information security duties is not only pragmatic, but it complies with regulatory guidance.
  • Implement an internal committee or team approach to managing IT and information security during a temporary or permanent personnel change. The committee can facilitate the IT and information security program in several ways. It can maintain processes until an outside replacement is installed or support an internal successor who is transitioning into the position. The committee can also provide coaching to keep the replacement from becoming overwhelmed by the complexity and assortment of tasks required.
  • Partner with a trusted third party to obtain the additional expertise needed to meet IT and information security benchmarks. This approach provides an accountability partnership role and a regular framework that clearly defines key responsibilities and streamlines processes. This strategy can ensure institutions have suitable resources to ease the transition of key personnel to enhance IT and information security resiliency.

Leveraging a Virtual ISO

A virtual ISO can be an ideal solution for institutions seeking to enhance IT and information security resiliency. This third-party service can not only support succession planning, but it can also serve as an extension of the internal ISO providing an external layer of oversight and an objective point of view — which allows institutions to approach risk more strategically and proactively.

ISOversight from Safe Systems, for instance, is a complete solution that makes it easier for community banks and credit unions to master information security and compliance online. This virtual ISO solution—which is especially for financial institutions—offers valuable access to applications and resources, cyber risk reporting, and compliance experts. With ISOversight, banks and credit unions can be confident that all their ISO-related requirements are completed on time, documented properly, and reported to the appropriate parties. Learn more about how to enhance your institution’s security posture during tough times. Read our white paper on “Building IT and Information Security Resiliency in Chaotic Times.”

27 Jul 2022
Learn How to Eliminate Compliance Pain Points with COMPaaS

Learn How to Eliminate Compliance Pain Points with COMPaaS

Learn How to Eliminate Compliance Pain Points with COMPaaS

Keeping compliance processes and information security up to date is crucial, especially with the ever-increasing risks and regulatory requirements that are facing financial institutions. Our compliance-as-a-service solution, COMPaaS, solves this problem. It offers community banks and credit unions an easy way to customize information technology and compliance services to match their institution’s needs.

What is COMPaaS?

COMPaaS is a collection of connected compliance applications combined with critical monitoring and reporting tools that institutions can customize to address their specific pain points. Regardless of type or size, any financial institution can use COMPaaS to build a unique package of services that are based on their specific compliance resources, expertise, and budget.

The full suite of services meets regulatory requirements in a range of areas from vendor and network management to cloud security, information technology, and business continuity management:

  • BCP Blueprint: An application that automates the building and maintenance of a business continuity plan.
  • CloudInsight M365 Security Basics: A reporting tool that provides visibility into security settings for Azure Active Directory and M365 tenants.
  • Cybersecurity RADAR: A user-friendly application to assess cybersecurity risk and maturity.
  • Information Security Program: A proven regulatory framework with applications that allow you to build a customized, interactive, and compliant infosec program.
  • Lookout: An event log monitoring solution that efficiently combs through daily logs and sends notifications for activities that need review.
  • NetInsight: A reporting tool that runs independently of existing network tools to provide third-party “insight” into IT controls.
  • Vendor Management: An application that tracks vendor risks, automates contract renewal reminders, and generates reports.
  • V-Scan: A security solution that scans a network, identifies vulnerabilities, and generates a comprehensive report.

How Does It Work?

The COMPaaS applications and services were built with our expert’s core knowledge and industry best practices to help your institution build a strong compliance foundation. Whether you choose one of the automated applications or a service that provides a dedicated compliance resource, COMPaaS can help you better manage your policies and procedures, implement effective controls, and fill in reporting gaps to meet examiner expectations. It is the ideal solution because it lets you select the exact products and services you need now and add more later as your requirements change. For example, if you are a smaller bank, you might begin with a vendor management application and then build from there to cover your cybersecurity risk and information security concerns.

Key Benefits

COMPaaS allows financial institutions to leverage the benefits of automation to streamline time-consuming processes related to regulatory requirements. It converts labor-intensive processes that often exist on paper into apps to create living documents that are more efficient and less likely to become outdated.

COMPaaS also uses technology to enforce verifiable controls and provide consumable reports so that institutions can implement the appropriate actions to maintain information security. This can make it easier to prove to a third party that critical issues are being addressed. In addition, all COMPaaS was designed with the regulatory needs of community banking institutions in mind. For example, the technology and security products cover the standards set by the Federal Financial Institutions Examination Council’s Cybersecurity Assessment Tool (CAT) or the National Credit Union Administration’s Automated Cybersecurity Examination Tool (ACET).

The COMPaaS Advantage

With COMPaaS, institutions have an effective way to target and eliminate their specific compliance and information technology weaknesses. They can save time by automating compliance tasks and save money by selecting only the options where they need help. Institutions also can expand COMPaaS’ services to support internal IT staff who may not be well-versed in a particular area or wearing multiple hats and juggling too many tasks. Or they can use COMPaaS to fill a void when an IT staff member takes a vacation, goes on leave, gets promoted, or retires. Whatever the situation, institutions can maintain continuity by having access to the same tools, reporting features, and experts through COMPaaS. And our solutions will grow with the institution, so it can implement various services at separate times based on its budget and needs.

14 Jul 2022
How to Always Be Prepared for a Cyberattack

How to Always Be Prepared for a Cyberattack

How to Always Be Prepared for a Cyberattack

Cybersecurity attacks have been ramping up nationwide, and the FBI expects the trend to continue. Americans reported 847,376 complaints in 2021, a 7-percent increase from 2020, according to the FBI’s Internet Crime Complaint Center’s 2021 Internet Crime Report. Many of the complaints filed in 2021 involved ransomware, phishing, data breach, and business email compromise. Financial services is one of the critical infrastructure sectors that are most frequently targeted by ransomware attacks.

However, here are five best practices that if effectively implemented, managed, and monitored can ensure that your financial institution is always prepared for a cyberattack:

1. Authentication

Passwords have become more complicated to create, remember, and maintain. Twenty years ago, passwords consisted of a simple string of characters. Now they are more complex, requiring a combination of numbers, symbols, and upper- and lower-case letters. Increasingly, user management tools allow institutions to take advantage of robust authentication options like multifactor authentication (MFA). MFA adds extra elements and more security to the sign-on process, which is why users should employ it whenever possible to log in to any network or system at your institution. This is especially important for higher-risk situations that involve network administrator accounts, virtual private network access, and critical management applications.

MFA is one of the most important cybersecurity practices to reduce the risk of intrusions. Users who enable MFA are up to 99 percent less likely to have an account compromised, according to a joint advisory issued by the FBI and Cybersecurity and Infrastructure Security Agency. “Every organization should enforce MFA for all employees and customers, and every user should sign up for MFA when available,” the advisory states.

2. Patch Management

Patching can be a constant and tedious process as it requires keeping up with updates from numerous sources and applications. This can entail patching a plethora of Microsoft products, along with banking and lending applications, PDF readers, virtualization applications, database applications, ATM software, and more. Not patching a security hole in any of these could lead to a massive security breach with catastrophic implications for institutions. It’s imperative to maintain a list of all approved applications and monitoring software on the network as well as have an update policy and a clearly defined process for each application. Major breaches have happened because a single patch was missing on a single device. Patch management cannot be ignored or treated as an afterthought.

3. Email Security and End User Best Practices

Understanding email, specifically phishing techniques, is one of the most critical aspects of being prepared for a cyberattack. While financial institutions are frequently targeted by phishing attacks, following these best practices can help to prevent business email compromise:

  • Augment your email solution with effective scanning software. This can help identify SPAM and phishing emails before they reach employees.
  • Train employees to recognize phony phishing emails, so they can “think before they click.” These bogus emails can be difficult to spot unless you know what you are looking for; e.g., poor grammar and spelling, links that don’t match the domain, unsolicited attachments, etc.
  • Test employees to see how well they respond to a realistic phishing attempt. Invest in a program that lets you send fake phishing messages and track which employees fail the test, so you can offer additional training to those who need it.

4. Backups

Backups play a crucial role in file recovery, disaster recovery, and ransomware attacks. To successfully bounce back from a cyberattack, institutions need to have all backup scenarios sufficiently covered, including file-level backups, disaster recovery backups, Veeam backups (for virtual servers), and SQL/database backups. While most institutions use a combination of different backup solutions, the key objective is to back up files offline or in the cloud, so they are not connected to your network. Then if a ransomware attack strikes the network, your offline and cloud backups will not be affected.

5. Vendor Risk Management

Vendor management can have a dramatic impact on the overall success of your information security plan. If you outsource to a vendor with inadequate security protocols, their weakness essentially becomes your weakness. The first step in vendor risk management is to perform a risk assessment to evaluate your level of inherent risk. This must always be done first so that you can then identify and implement the proper controls. If the controls selected do not completely offset the risks identified, then alternate or compensating controls would need to be identified to achieve a level of residual risk that is within your risk appetite.

There’s no silver bullet when it comes to resisting a cyberattack but focusing on the five areas above can significantly increase your institution’s cyber resiliency. Safe Systems offers a range of technology, compliance, and security solutions that are exclusively designed for community banks and credit unions. Contact us to learn how we can help you implement these five and other best practices.

23 Jun 2022
Tips for the Latest Microsoft Windows 10 Feature Update

Tips for the Latest Microsoft Windows 10 Feature Update

Tips for the Latest Microsoft Windows 10 Feature Update

Microsoft recently released the latest feature update for Windows 10, and financial institutions should upgrade the operating system as soon as possible. Installing the new update—Windows 10, version 21H2—sooner than later will give institutions access to important benefits, with a key advantage being enhanced security. The update will enable them to keep receiving security patches against malware and other vulnerabilities, so they can continue operating with the same level of safety and convenience. In addition, upgrading now will enable institutions to extract more longevity and functionality from the system, which will save them money in the long run. Implementing the current update will also keep them ahead of the curve and better prepared to meet the Windows 10 end-of-life date: Oct. 14, 2025.

Safe Systems Makes the Process Easy

Safe Systems can complete the upgrade for their network management, NetComply® One, customers using a proprietary solution designed by in-house technology experts. This advanced, automated method lessens the time and effort involved with installing version 21H2. We typically make one download per location instead of going from machine to machine—which can each take several hours to update. We can also employ file sourcing to reduce the amount of bandwidth consumed during the update. These streamlined tactics significantly minimize downtime, which can have a major impact on daily operations, personnel productivity, and other network utilization issues. If a machine has a problem with our automated process, customers will receive an email from Safe Systems notifying them that several failed attempts have occurred. At that point, they can decide whether to upgrade the machine themselves or submit a ticket requesting us to remediate the issue.

In addition, customers can run reports to gain insights, enhance decision-making, and optimize the upgrade process. For instance, they can:

  • identify which version of Windows 10 is currently running on their machines;
  • review results from the previous upgrade;
  • determine time of the next attempted upgrade;
  • detect which machines are excluded from upgrades; and
  • confirm that machines scheduled for the update are turned on and online.

By leveraging our network management solution and custom technology for feature upgrades, guesswork and human intervention are removed from the update process. This not only leaves financial institutions with more time to focus on other important issues, but it results in a more successful upgrade project. So, our customers get the best of two worlds: an efficient, computerized upgrade and support from technology experts.

A Specialized Network Management Solution

Completing Windows 10 21H2 updates for our customers means they will have one less thing to worry about. This supports our ultimate objective—to give financial institutions of all sizes a cost-effective way to leverage the best technology, compliance, and security solutions to serve the financial needs of their community. Our network monitoring and management platform, NetComply One, is designed exclusively for community banks and credit unions and provides them with a unique blend of services: automated ticketing, patch management, qualified alerting, custom reports, and quarterly advisement—all from an industry leader with more than 25 years of banking and IT experience.

So why run the security risk of not installing the new Windows update now when we’re making the process easy? Contact us today for questions about the upgrade or more information about NetComply One.

16 Jun 2022
Choosing a Virtual ISO (VISO)

Choosing a Virtual ISO (VISO)

The ISO’s role is becoming increasingly more complex and challenging due to growing cyber security threats, the ever-changing technology environment, and expanding regulatory expectations. It can be difficult for banks and credit unions to stay on top of information security issues. That’s why today even the smallest institutions often engage a trusted third party for help. A virtual information security officer (VISO) service can help institutions effectively manage information security so that nothing gets missed or falls through the cracks.

Common Types of VISO

The most common types of virtual ISO solutions available to institutions are the “do-it-yourself” (DIY), “hybrid,” and “offload” models. The DIY option is designed for institutions that have a solid grasp of the ISO’s job functions and just need some basic tools and limited consultation to enhance their efforts. This model is the least expensive but also requires more of a time commitment from your internal resources. The hybrid model may typically include an assortment of apps, templates, pre-configured reports, and other tools, along with a broader and deeper level of consultation. Resource requirements from the institution side are greatly reduced compared to DIY, but typically greater than offload. Accordingly, costs for a hybrid approach are somewhere between the two other models. The hybrid model also tends to be the most flexible and is designed to evolve with the changing needs of the institution. Finally, the offload approach attempts to provide a “turn-key” solution wherein the virtual ISO partner effectively assumes most or all the responsibilities of your internal ISO. This approach requires the least involvement from your institution (which could introduce other challenges…see the “Examiner Support” section below), but it is usually also the most expensive. As this model is the most inclusive, the knowledge and experience of the third-party provider are your most important consideration. The offload approach typically includes unlimited consultation, on-demand reporting, participation in committee meetings, etc.

Key Factors to Consider

When choosing a virtual ISO, there are some important aspects to consider to ensure your institution selects the best option. Keep in mind that each virtual ISO model comes with a certain level of flexibility and engagement for a specific price. The key is to carefully balance the service and costs against your specific internal resource gaps to determine the best solution for your situation. Ideally, whatever solution you choose should have the flexibility to dial up or down the level of service, depending on how your situation may change in the future.

Whatever virtual ISO solution you opt for, it should provide documentation and reporting in a form that the various stakeholders can understand. Each one of the many ISO responsibilities has one or more reports or documents that support the requirement to hold the ISO accountable for its responsibilities. The board of directors, the steering committee, the IT auditors, and examiners, all have different perspectives and comprehension levels and may require different degrees of detail for the same information. For instance, boards and examiners might require higher-level data, whereas steering committees and IT auditors might require more detailed documentation for their purposes. You should have access to on-demand reporting with relevant, actionable, up-to-date information that matches the level of engagement for the various stakeholder groups.

The regulatory guidance on ISO responsibilities includes terms such as “engaging with” and “working with” management in the individual lines of business to understand the risks of various initiatives. They also expect the ISO to “implement” the information security strategy as defined by the board, and to periodically “inform” the board and senior management on the status of the program. In the case of a virtual ISO, your hybrid or offload third-party partner needs to have an excellent understanding of enterprise-wide strategic objectives, and a good working relationship with management in all lines of business and within the different departments within your organization.

Remember, as with all outsourced activities, even though you can delegate some (or even most) of the heavy lifting to a virtual ISO, you cannot outsource responsibility. Your institution still must maintain a strong oversight effort to ensure that all ISO duties are completed, documented, and reported appropriately. Higher levels of third-party reliance require correspondingly higher levels of oversight. According to the Federal Financial Institutions Examination Council’s Outsourcing Technology Services booklet you are obligated to oversee all activities, whether you perform them, or a third-party performs them on your behalf.

Examiner Support

The examiner feedback we have seen to date strongly supports the idea of financial institutions implementing a virtual ISO solution “…as long as it’s done correctly.” That means focusing on all the responsibilities and accountabilities of the role and making sure sufficient documentation and appropriate oversight and reporting are built-in. Doing it correctly also means making sure the in-house ISO is not so detached from the processes and procedures that they cannot authoritatively explain them to a stakeholder, which can be the primary downside of the “offload” model. The decision-making process is the most important concern for regulators. Your solution should allow you to offload enough to make the ISO’s job easier and more organized, but not so much that they become disconnected and lose operational awareness of their current threat and control environment.

In conclusion, choosing the right type of virtual ISO service allows institutions to provide the appropriate level of insight and oversight for their in-house ISO. This can help them to be better equipped to manage information security activities, meet evolving industry standards, and adjust to tightening regulatory requirements, all in an increasing cyber threat environment.

At Safe Systems, we offer a virtual ISO service based on the above-described hybrid model. ISOversight™, is a VISO service that is flexible to accommodate the changing needs of community banks and credit unions. The ISOversight service includes a full suite of applications to manage everything from vendors to business continuity, along with all associated information security policies and risk assessments. This is a cost-effective, comprehensive, and flexible solution that makes information security management much more efficient. For more insight about the most common virtual ISO models and how to determine which one may be right for you, view our webinar on “Is a Virtual ISO Right for You?”

09 Jun 2022
Planning for Safety, Soundness, and Resiliency

Planning for Safety, Soundness, and Resiliency

Planning for Safety, Soundness, and Resiliency

With the rise in cybercrimes and increased regulatory scrutiny, having a board-approved IT Strategic is often not enough to ensure cyber resiliency. It’s essential for financial institutions to develop a robust IT management and information security infrastructure. The following excerpts from our recent white paper on “Building IT and Information Security Resiliency in Chaotic Times,” show how institutions can strengthen and support these key management roles to make better technology and security decisions, improve visibility, and reduce vulnerability. In addition, institutions can use strategic partners and risk management solutions to bolster resources they already have in place and enhance their overall cyber resilience.

1. Separating ISO Duties

Examiners have a strong interest in the IT administrator and ISO roles, which are interconnected and integral to an institution’s safety and soundness. However, many community banks and credit units still struggle with meeting the FFIEC requirements for segregating these positions. The importance of separating ISO duties relates to creating additional oversight to verify activities and maintain accountability to management and the board. Separating these functions also helps to build a clear audit trail to ensure risk is being accurately assessed and reported to senior management. While the ISO functions in an oversight capacity of the IT administrator, the ISO also relies heavily on the administrator to share data that can be used to recommend steps to improve the institution’s security posture. Therefore, the IT admin-ISO relationship must also be cooperative to ensure their daily activities support the organization’s policies and procedures.

2. Being Proactive about Succession Planning

Regulators expect financial institutions to have a formal succession plan for the ISO, IT administrator, and other key leadership roles, as indicated by the uptick in exam findings related to this issue. Depending on their size, type, and goals, institutions may employ different approaches for succession planning. They can identify and train someone to serve as an alternate or “backup” for various IT or ISO responsibilities, incorporate an internal committee or team approach for managing IT and information security, or use the support of a trusted third party to maintain IT and information security standards.

3. Partnering with a Trusted Third Party

An outside expert can provide an objective perspective that can help institutions think beyond the day-to-day issues and consider risk more proactively and strategically. Bringing in a technology partner on the front end—when things are going well—can also position institutions to be stronger and more successful in the future. For instance, a virtual information security officer (VISO) can expand an internal ISO’s capabilities and increase the likelihood that all ISO-related tasks are completed in a timely and efficient manner. A VISO can also provide an external layer of oversight to enable the required separation of duties.

ISOversight®, our virtual ISO service, makes it easier for financial institutions to master information security and manage compliance online. ISOversight is a comprehensive solution with a full suite of applications and resources, cyber risk reporting, and dedicated compliance specialists. It’s uniquely designed to help banking institutions enhance their strategies to improve IT management, information security, and compliance. With ISOversight, community banks and credit unions can ensure that no information security issues fall through the cracks—especially during challenging times.

For more information about how to enhance your institution’s security posture, read the full white paper on “Building IT and Information Security Resiliency in Chaotic Times.”

26 May 2022
Community Banks Use CloudInsight M365 Security Basics to Increase Security

Community Banks Use CloudInsight™ M365 Security Basics to Increase Security

Community Banks Use CloudInsight M365 Security Basics to Increase Security

To meet the challenges of escalating cyber threats and constantly evolving technology, organizations must have appropriate security measures in place to protect their network, data, and other assets. Financial institutions that use Microsoft Azure Directory and M365 can capitalize on CloudInsight™ M365 Security Basics to ensure they have the right security, identity, and compliance settings to keep their information safe in the Cloud. The product fills a critical need because Microsoft is always enabling and disabling features in Azure AD and M365, which can make it difficult for institutions to maintain the best security settings.

M365 Security Basics increases the visibility of potential security risks through three main services:

  • Reporting — The delivery of user-friendly Microsoft data
  • Alerting — Notifications of common indicators of compromise
  • Quarterly Reviews — Expert analysis and consultations

Here are two case study summaries to show how different institutions are using CloudInsight M365 Security Basics to gain better visibility into their cloud security and Microsoft settings:

Affinity Bank

Atlanta-based Affinity Bank wanted to get a better handle on potential security threats—particularly those relating to email. It implemented CloudInsight M365 Security Basics to prevent compromised user accounts, unknown users and forwarders, unapproved email access, and other risks. “Being able to receive alerts when attempted logins from outside of the country come through is a big reason why we were interested in the product,” said Senior Vice President and Chief Operations Robert Vickers. Just having the ability to put in preventative features blocking employees from sending or setting up a forward to an external email address was another plus for Affinity Bank. With almost $800 million in assets, three locations across Georgia, and a long-term relationship with Safe Systems, Affinity Bank anticipates significant improvement in its cloud security and overall security posture thanks to M365 Security Basics’ monitoring, alerting, and other tools. Aside from the tools that M365 Security Basics provides for Affinity Bank, the real advantage given to the bank is the relationship with Safe Systems. “The team at Safe Systems has been able to provide us with great expertise on exactly where we need to go, what we need to do, and best practices to get us there,” said Vickers. “Almost immediately after we signed on for CloudInsight, they gave us recommendations we could implement straight away.” Read more.

Franklin Bank & Trust Company

Since its inception in 1958, Franklin Bank & Trust Company has prioritized adapting to constant changes in technology to maintain its security. M365 Security Basics proved to be the ideal solution for the Franklin, Kentucky-based community bank, which has $700 million in assets and five branches across the state. Since implementing CloudInsight M365 Security Basics, the bank achieved improved efficiencies in its cloud security and settings. After the initial meeting with the new service, reports came back with deficiencies that the bank didn’t even know it had and that could expose them to potential data breaches and threats. They were able to tighten up privacy settings, including the bank’s Microsoft OneDrive, and impose conditional access policies to ensure data was protected. “Adding CloudInsight M365 Security Basics to our roster has really shone a light on our whole Microsoft cloud footprint. It has shown us which areas we need to shore up and, in turn, has made our bank more efficient and secure,” said IT Project Manager Aaron Miller. Read more.

Learn More

CloudInsight M365 Security Basics is a flexible, cost-effective solution that institutions can incorporate based on their specific priorities and requirements. While Affinity Bank used M365 Security Basics to primarily address email management, Franklin Bank & Trust Company wanted to gain better overall visibility into Microsoft security settings. In both cases, M365 Security Basics fit the bill. Depending on their license, financial institutions can use M365 Security Basics to customize a wide array of security settings in Azure AD, M365, and Exchange Online. This includes OneDrive and SharePoint Sharing; Teams and External Collaboration; and the Protection, Security, Compliance, and M365 Admin centers. Institutions can further enhance cloud security by adjusting the settings associated with Azure AD Premium P1, Intune, and Azure Information Protection. They can also apply conditional access policies, password protection, and a myriad of other security features.

For more information about how your institution can optimize Microsoft security settings to improve cloud security, download our white paper on “Azure and M365 Security Basics.”

19 May 2022
The Relationship Between the ISO and IT Administrator

The Relationship Between the ISO and IT Administrator

The Relationship Between the ISO and IT Administrator

IT administrators (IT admins) and information security officers (ISOs) have independent yet interdependent roles that are critical to their financial institution’s security, regulatory compliance, and overall success. Both individuals must maintain a separation of duties yet work closely together to achieve a common goal: ensuring their organization’s day-to-day activities appropriately support its policies and procedures.

ISO Responsibilities

ISOs oversee everything from network security (including cybersecurity) to vendor management, to strategic alignment of IT initiatives, to general information security regulatory compliance, all of which require having on-demand access to relevant, timely, and actionable information.

ISOs rely heavily on IT administrators to share data about the network, so they can translate that data into the information that will allow them to perform their duties effectively. Therefore, reports are an integral aspect of the IT admin-ISO relationship. ISOs depend on the data provided by IT admins to complete the enterprise-wide thinking and strategic planning that is needed to protect the bank’s information and other assets.

For example, an IT admin might extract data about the number of devices that have been updated with the latest patches and report this information to the ISO. The ISO would certainly be interested in the status of all devices but would most keenly be interested in the exceptions—the devices that have not been patched—as even a single unpatched device could represent a significant risk to the organization. In addition, the ISO must further evaluate the root cause behind the exceptions: do they represent a predictable lag between patch rollout and installation that will be resolved during the normal course of reboots; or do they represent a procedural deviation or deficiency? If the latter, the ISO could make a recommendation to revisit patch management procedures and practices

IT Admin Responsibilities

IT administrators are responsible for a variety of tasks, including managing computer systems, IT personnel, information systems, data backups, and network security—and providing ISOs with essential information on all those activities. Since IT admins may have a small staff—or might be the only IT person in the department—and have privileged access to the network, institutions must closely oversee their position. According to the FFIEC Information Security Handbook, Section II.C.7(c) Segregation of Duties:

“System administrators, for instance, have the most powerful role in the user access process and have unlimited access to an institution’s information assets and technology. Given this extensive access, management should evaluate the process for determining which individuals should be granted system administrator privileges. Such access should be appropriately monitored for unauthorized or inappropriate activity.”

The ISO in combination with the IT Steering Committee provides an important checks-and-balances process to ensure all systems are being effectively managed and maintained, and that status reporting is reliable.

ISO and IT Admin Cooperation

It’s important to remember that although the ISO and IT admin roles must be independent, they are also complementary since both entities are responsible and accountable for making sense of the vast amount of data flowing through their institution.

Because ISOs must utilize the information supplied by IT admins to produce the reporting necessary to periodically update senior management and the Board, and to authoritatively interact with IT auditors and IT examiners, this relationship must be cooperative. By maintaining a close working relationship, ISOs and IT administrators can make sure their actions support the institution’s IT strategic plan. Done properly, a successful ISO- IT admin relationship should in no way be adversarial, it should be mutually beneficial to both parties, as well as to the institution as a whole.

Obtaining Third-Party Support

Regulators place a high priority on the continuity and consistency of leadership for effective information security. At times, financial institutions will have ISOs and IT administrators leave their position either temporarily or permanently. When this happens, it can be beneficial to employ an internal committee/team or a trusted third party to help manage IT and information security.

A third-party partner can provide additional support while the ISO position is vacant, help a new employee transition into the role, or simply provide another set of eyes and an external layer of oversight to supplement what they already have in place. Collaborating with an external information security expert cannot only help the institution think more objectively, strategically, and proactively about risk during a time of transition but also when things are running smoothly. This can prevent problems later and position the institution to be stronger and more successful in the future.

Financial institutions can take advantage of a wide range of external resources designed to support the ISO and IT administrator roles. For example, ISOversight™, our virtual ISO service, offers community banks and credit unions a complete solution to help them master information security and manage compliance online. With ISOversight, institutions can make sure nothing gets overlooked, so they stay on track—which is vital with the complexities and constant changes in the technology and security environments.

22 Apr 2022
More Microsoft Azure and 365 Security Basics

More Microsoft Azure and 365 Security Basics

More Microsoft Azure and 365 Security Basics

Banks and credit unions today face an ever-increasing number of cloud security hazards. Here’s the good news: Financial institutions that use Microsoft Active Directory (Azure AD) and Microsoft 365 can lower their risk by modifying their security settings for these services. Not only can this help the financial institution minimize threats, but it can allow them to customize the features of Azure AD and Microsoft 365 (previously called Office 365) to their specific preferences and requirements.

Organizations are responsible for managing Azure AD and its security settings because when they purchased M365 licenses, they established a Microsoft tenant with Azure AD. From a compliance perspective, adjusting Azure AD’s settings is crucial since Microsoft automatically enables certain features that may violate or conflict with compliance policies for organizations in regulated industries.

Optimizing /M365 and Exchange Online Settings

Depending on your institution’s licenses, there is a wide range of security and compliance settings you can customize in Azure AD, M365, and Exchange Online such as:

  • OneDrive and SharePoint Sharing: Review the default level of sharing to control the flow of data based on what is appropriate for your institution.
  • Teams and External Collaboration: Review the platform’s default security and compliance settings, and if they are not sufficient, you can block all external domains to keep users from communicating externally.
  • Exchange Online: Control access, how emails are transmitted, the types of messages users can send to recipients in external domains, and the devices or apps that can connect.
  • Protection Center: Use the Basic Mobility and Security feature to manage and secure the mobile devices that are connected to your Microsoft 365 organization.
  • Security Center: Optimize email management by employing anti-spam policies for inbound emails, blocking automatic forwarding of outbound emails, using phishing simulations, quarantining potentially harmful messages, and blocking messages from fake senders.
  • Compliance Center: Implement a retention policy to manage the data by proactively choosing how to retain or delete content.
  • M365 Admin Center: Use modern authentication‎ in ‎Exchange Online‎ to enhance your institution’s security with features like conditional access and multifactor authentication. (Microsoft‎ strongly recommends turning off basic authentication for your organization.)

More Ways to Boost Security

You can further enhance cloud security by modifying the settings related to Azure AD Premium P1, Intune, and Azure Information Protection (AIP) licenses. With Azure AD Premium P1, for instance, you can include your institution’s logo, color scheme, and other branding elements on your Azure AD sign-in pages. You can also employ the hybrid Azure AD joined devices, conditional access policies, and password protection features. Microsoft Intune integration lets you configure policies to control how your institution’s devices and applications are used, including smartphones, tablets, and laptops. And AIP allows you to use deep content analysis to minimize data loss and enhance the labeling capabilities of Microsoft 365 to protect documents and emails.

M365 Security Basics Can Help

There are countless security settings that can be adjusted in Azure AD and /M365, and Microsoft is always introducing new features. This can make it difficult for institutions to ensure they have the most appropriate security, identity, and compliance settings—but our CloudInsight™ M365 Security Basics solution can make the process easier. M365 Security Basics is a collection of services designed to give community banks and credit unions a cost-effective way to manage their M365 settings. It offers reporting, the delivery of Microsoft data in a user-friendly format; alerting, notifications of the most common indicators of compromise; and quarterly reviews, expert analysis of M365 Security Basics reports, and explanations of the risk visible on the report and ways those risks may be mitigated.

To learn more about how to customize your institution’s Azure AD and M365 settings to bolster cloud security, access our “Microsoft Azure and M365 Security Basics” white paper.

30 Mar 2022
Get Prepared for the New Computer-Security Incident Notification Rule

Get Prepared for the New Computer-Security Incident Notification Rule

Get Prepared for the New Computer-Security Incident Notification Rule

As of April 1st, financial institutions are expected to comply with new cyber incident notification requirements for banking organizations and their third-party service providers. The Computer-Incident Notification Rule, as it’s officially called, is designed to give regulators early awareness of emerging threats to banking organizations and the broader financial system, including potentially systemic cyber events. The final rule—approved last November by the Federal Deposit Insurance Corporation (FDIC), Federal Reserve, and Office of the Comptroller of the Currency (OCC)—takes effect on April 1, 2022, with full compliance extended to May 1, 2022. (To date, the NCUA has not adopted the new rule, although it’s possible they may at some point. Credit Unions should check with their regulator for notification expectation specifics.)

Understanding the Regulations

To meet the upcoming deadline, financial institutions need to be well versed in the intricacies of the new rule. The rule has two components:

  1. The first part requires a banking organization to promptly notify its primary federal regulator of any “computer-security incidentthat rises to the level of a “notification incident.”
  2. 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.

Focusing on the financial institution expectations under the final rule, a couple of definitions must be understood.

  • A computer-security incident” could include almost anything: a hardware or software failure, an innocent mistake by an employee, or a malicious act by a cybercriminal. However, the incident must result in actual or potential harm to the confidentiality, integrity, or availability of an information system or the information the system processes, stores, or transmits.
  • A “notification incident” is defined as a significant computer-security incident that has materially disrupted or degraded a banking organization in at least one of these areas:
  • its ability to carry out banking operations, activities, or processes, or deliver banking products and services to a material portion of its customer base in the ordinary course of business
  • its business line(s), including associated operations, services, functions, and support that, upon failure would result in a material loss of revenue, profit, or franchise value
  • its operations, including associated services, functions, and support, as applicable, the failure or discontinuance of which would pose a threat to the financial stability of the United States.

In the event an incident rises to the level of a “notification incident,” the banking organization’s primary federal regulator must receive this notification as soon as possible, and no later than 36 hours after the banking organization determines that a notification incident has happened.

Recognizing the Gray Areas

The words “material” and “materially” are key terms; so much so that they are used 97 times in the 79-page guidance about the ruling. But beyond an “enterprise-wide” impact, the regulation does not precisely define these concepts, so financial institutions will need to specify what this term means to their organization as a whole. And since a determination of materiality is a prerequisite to starting the 36-hour “clock” for notification, they should do so ahead of time. The undefined nature of “material” to each organization creates a gray area open for interpretation that not only allows institutions some flexibility in this area but also opens the door for differences in opinion between an institution and its regulator.

In another gray area, the rule does not impose any specific recordkeeping requirements, which is a reduced burden. However, we strongly recommend keeping at least basic documentation in case the examiners ever question why your institution did or did not decide to escalate an event from a computer-security incident to a notification incident, and why it started the “clock” when it did.

Preparing for the Unknowns

At this stage, there are some unknowns about the implications of the new cyber incident notification requirements. One of the unknowns discussed in our recent webinar was related to an official contact person and method for each primary federal regulator. This has since been addressed and we recommend incorporating the following verbiage into the regulator notification section of your Incident Response Plan:

FDIC institutions:

  • Notification can be made to the case manager (primary contact for all supervisory-related matters), to any member of an FDIC examination team if the event occurs during an examination, or if the primary contact is unavailable, the FDIC may be notified by email at: incident@fdic.gov.

OCC Institutions:

  • Notification may be done by emailing or calling the OCC supervisory office. Communication may also be made via the BankNet website, or by contacting the BankNet Help Desk via email (BankNet@occ.treas.gov) or phone (800) 641-5925.

Federal Reserve Institutions:

  • Notification may be made by communicating with any of the Federal Reserve supervisory contacts or the central point of contact at the Board either by email to incident@frb.gov or by telephone to (866) 364-0096.

Another unknown as of the date of this post: Will the State banking regulators also require notification if a federal regulator is notified? The unofficial initial indication we have received is ‘Yes,’ but it would be good practice for institutions to check with their state regulator. Chances are regulators will request this, but whether or not it will be a requirement is still unknown.

Steps to Take Now

There are additional steps financial institutions can take now to be better prepared to address the requirements of the computer-Security Incident Notification Rule.

  • Our primary recommendation is for institutions to expand the notification section of their incident response plan to include the criteria for determination of a notification incident, and to add the regulator contact information above.
  • Institutions should also define “materially” for their organization and predetermine the meaning of “materially disrupted or degraded,” or what constitutes a “material portion” of their customer base.
  • Third-party contracts should contain verbiage obligating them to notify your institution under certain circumstances as required by the new rule. We also strongly advise designating an official contact person within your institution — whether it’s the CEO, CIO, or ISO — who should receive incident notifications from your third parties. It’s also prudent to specify a backup contact person—and make sure vendors know who the primary and alternate contacts are to ensure a smooth notification process.

For more information about this important topic, access our webinar on “New Cyber Incident Notification rules: How to Get Prepared”, or this recent blog post from Compliance Guru.

09 Mar 2022
Microsoft Azure and 365 Security Basics Continued

Microsoft Azure and 365 Security Basics Continued

Microsoft Azure and 365 Security Basics Continued

When your institution acquired Microsoft 365 (also known as M365 and formerly called Office 365), it automatically created a Microsoft tenant with Azure AD. Since that tenant belongs to your organization, you are responsible for managing Azure AD and its security settings. Microsoft Azure services enable various default features that could be incompatible with the security, identity, and compliance requirements of your institution. it’s essential to customize the settings in Azure AD, M365, and Exchange Online (or Azure AD Premium P1, Intune, and Azure Information Protection) to fit your organization’s needs.

Customizing Azure AD Defaults

  • Security Defaults — Turn on security defaults to make it easier for your institution to thwart cyberattacks by using preconfigured security settings. (If your tenant was created on or after October 22, 2019, security defaults may already be enabled in your tenant.)
  • Password Policy — Configure the password policy applied to every user account that is created and managed directly in Azure AD. (Institutions with on-premises AD password policies governing password expirations should expect to manually synchronize their Azure AD password policy and their on-premises AD password policy.)
  • Azure AD Device Registration — Prevent users from joining devices on their own and require multi-factor authentication (MFA) to register or join devices with Azure AD.
  • Enterprise and Registered Apps — Keep non-administrator users from arbitrarily adding enterprise or registered applications, which can significantly increase risk. Afterwards, make sure to review every enterprise and registered application.
  • External Collaboration — Restrict regular users from inviting guests for collaboration and keep guest users from signing into your apps and services with their own work, school, or social identities.
  • Hybrid Identity with Password Hash Synchronization — Employ a hybrid identity architecture to synchronize users from on-premises Active Directory to Azure AD to minimize the number of identities users have across various platforms.
  • Azure AD Administration Portal — Limit regular users’ ability to read data in the Azure AD Administration Portal.
  • Administrator Review — Grant administrators only the specific permission they need to do their job and limit the number of static Global Administrator role assignments to fewer than five people.
  • Partners – When working with Microsoft-certified solution providers (partners) to purchase and manage solutions for your institution, they could be granted Global/Helpdesk admin roles giving them delegated administrative capabilities to your Azure instance. Make sure to review all partners and their delegated rights regularly.

Altering M365 and Exchange Online Settings

In M365, you can customize a variety of settings. In OneDrive, SharePoint Online, and Teams, look at configuring external collaboration capabilities of users. For Exchange Online, there are many settings to review but one to start with is the current forwarding capabilities and settings for users both globally and per-user. Modifying or reviewing these settings is highly advisable since they are inherently designed to facilitate interaction and external collaboration. In addition, you can use the Protection Center to secure mobile devices that are connected to your Microsoft 365 organization; the Security Center to refine email management; the Compliance Center to implement an effective data retention policy; and the M365 Admin Center to enhance security with modern authentication, which encompasses MFA. (According to Microsoft, 99.9 percent of account compromises can be blocked with MFA.)

And with the proper license, you can further enhance cloud security by optimizing the settings for Azure AD Premium P1, Intune, and Azure Information Protection.

M365 Security Basics Solution

Once your institution has sufficient settings in place to support your policies, it is essential to monitor for exceptions with reporting and alerting features such as those provided with Safe Systems CloudInsight™ M365 Security Basics solution. Financial institutions that partner with Safe Systems can gain critical visibility into their security settings helping them successfully navigate the complexities of optimizing M365’s features..

For more information about how your institution can optimize Azure AD and O365/M365 settings to improve cloud security, download our white paper on “Azure and M365 Security Basics.”

Important Disclaimer

The security settings that are discussed in this paper can have a dramatic impact on end-users and/or service functionality and should only be employed if deemed appropriate and after careful consideration. There are a variety of security options available, but organizations should strive to implement these technology services strategically and, ideally, through planned phases of objectives over potentially several months or even years. The recommendations, statements, and other concepts contained within this paper are provided primarily for the consideration of IT Administrators of financial institutions.

01 Mar 2022
Managing Security, Identity, and Compliance within the Microsoft Azure and M365 Ecosystem

Managing Security, Identity, and Compliance within the Microsoft Azure and M365 Ecosystem

Managing Security, Identity, and Compliance within the Microsoft Azure and M365 Ecosystem

It can be challenging for financial institutions to manage security, identity, and compliance within Microsoft Azure Active Directory (Azure AD) and Microsoft 365 (also known as M365 and formerly branded as O365). Understanding the services and settings of the Azure AD and M365 ecosystem can make the process easier for IT administrators.

Some of the basic security settings that apply to most organizations fall under the free license level for Azure AD. These are also some of the low-hanging fruit that institutions can easily implement to make a dramatic difference in their security.

Security Defaults

One of the settings that can have the biggest impact is security defaults, which can be enabled to enforce a set of non-configurable conditional access policies. The policy set in Azure includes the ability to require multifactor authentication (MFA) and MFA registration for all users. It also offers the capability to block legacy authentication, which should be a high-priority goal for any organization.

Hackers can exploit basic authentication to effectively bypass MFA, which is a fundamental security service we recommend that every institution implement. If your institution has gone through the effort of enforcing MFA for users—but you’re not blocking basic authentication explicitly—there’s a major security gap. That gap should be addressed immediately, especially given Microsoft’s plans to decommission basic authentication protocols in Exchange Online in October 2022.

Identity Considerations

It’s also crucial to review the identity architecture for your financial institution. Any user, device, or app connecting to Azure should have an identity, whether it’s a guest user, mobile device, Mac OS device, or a Windows computer, so it can be assigned data access rights or even take on administrative capabilities. Every identity outside of Active Directory—which is the primary identity for users in many institutions—is another attack vector in a different system. An effective way to manage different identities is to consolidate them by sourcing them at the AD level and then synchronizing users and their password hashes to Azure AD. You should also review the level of access for all administrators as well as partners as they represent a huge risk downstream. Reviewing the level of access for partners goes beyond security; it’s also a matter of regulatory compliance.

Additional Considerations

Depending on your institution’s license level, there are additional Azure and M365 settings you can adjust in the areas of protection, compliance, and administration. For example, global auditing is an essential setting that should be enabled to augment security and facilitate troubleshooting after attacks. You should also block settings allowing for open collaboration and outbound email forwarding to avoid data loss and minimize cyberattacks.

If your institution is at the M365 level, it also needs the mobile device management (MDM) platform that offers sufficient protection. Exchange Online has built-in MDM capabilities but these capabilities do not extend to all M365/O365 apps.

Conditional access policies govern sign-ins and attempts. They can enable the enforcement of MFA and are the highest control layer for determining who has access to the data within Azure’s security ecosystem.

Since data lives outside of Exchange Online in the M365 world, if your institution has specific compliance requirements for retention, your retention policies will generally need to extend to all data.

M365 Security Basics

Adjusting all the security settings of Azure AD and M365 can be a daunting task, especially since Microsoft is constantly updating the features of its technology services. Our CloudInsight™ M365 Security Basics solution provides insights into security settings for Azure AD and M365 tenants. It helps IT administrators navigate the complexities of customizing their institution’s security settings through three services: reporting, alerting, and quarterly reviews.

The reporting service provides ongoing Microsoft data and packages it into a readable format that shows security settings at a glance, allowing institutions to easily see irregularities, such as when users sign in from Outside of the USA. Alerting sends a notification when an activity indicates that a potential compromise has occurred. With the quarterly reviews, trained experts analyze the settings, reports, and alerts and review them with administrators so they can speak with confidence to their board, steering committees, and auditors about their institution’s technology services and cloud security.

If you need help understanding how M365 Security Basics can support your financial institution’s risk mitigation or strategic planning efforts, contact us. You can learn more about this topic with our “How to Manage Security Identity and Compliance within the Microsoft Azure and M365 Ecosystem” webinar.

Important Disclaimer

The security settings that are discussed in this paper can have a dramatic impact on end-users and/or service functionality and should only be employed if deemed appropriate and after careful consideration. There are a variety of security options available, but organizations should strive to implement these technology services strategically and, ideally, through planned phases of objectives over potentially several months or even years. The recommendations, statements, and other concepts contained within this paper are provided primarily for the consideration of IT Administrators of financial institutions.

02 Feb 2022
Compliance Review and Tactics

2021 Compliance Review and Tactics for Staying Ahead of Regulators in 2022

Compliance Review and Tactics

With 2021 in the rearview and 2022 well underway, it’s a good time to consider some compliance issues from last year, and current trends and tactics for keeping ahead of regulators this year. In 2021, we saw a number of compliance-related changes from the Federal Financial Institutions Examination Council’s (FFIEC) and Federal Deposit Insurance Corporation (FDIC). One important development, especially for smaller community banks and credit unions, was the FDIC’s new Office for Supervisory Appeals. The office—launched in December to operate independently within the FDIC—considers and decides appeals of material supervisory determinations. It replaces the existing Supervision Appeals Review Committee.

The Office of Supervisory Appeals will “enhance the independence of the FDIC’s supervisory appeals process and further the FDIC’s goal of ensuring consistency and accountability in the examination process,” according to the FDIC. There’s a broad range of material supervisory determinations that institutions can appeal through the office, including CAMELS ratings under the Uniform Financial Institutions Rating System; IT ratings under the Uniform Rating System for Information Technology (URSIT); and Trust ratings under the Uniform Interagency Trust Rating System. This new appeal process isn’t a guarantee that supervisory findings will be changed but may prove useful as a last resort for FDIC institutions facing downgrades in scores where there is a material disagreement between the FI and the FDIC.

Another significant FFIEC development last year involved amendments to the Bank Secrecy Act (BSA) and anti-money laundering (AML) regulations. The BSA amendments included certain provisions to the USA Patriots Act to detect, deter and disrupt terrorist financing networks. This would appear to be an area of focus going forward, as 3 of the 10 most substantive (i.e., non appointment-related) FFIEC releases in 2021 were related to BSA/AML.

In June, the FFIEC issued a new Architecture, Infrastructure and Operations (AIO) booklet as part of its Information Technology Handbook. With this logical move, the FFIEC replaced its July 2004 Operations Handbook with a single booklet that merges three interconnected areas. In August the FFIEC also enhanced its guidance on authentication and access to services and systems—advocating for the widespread use of multi-factor authentication (MFA)—and released guidance on conducting due diligence on fintech companies.

One additional item of note in 2021; the FDIC’s tech lab, FDITECH, launched an initiative to challenge institutions to measure and test bank operational resiliency. Ultimately, a set of metrics may be applied to financial institutions—perhaps community banks in particular—to determine whether they are adequately resilient against operational disruptions. We’re keeping a close eye on this as it may lead to a universal formula for grading or ranking resilience. Anything that reduces subjectivity also reduces uncertainty, and that is a good thing when it comes to regulations.

Tips, Tricks, and Tactics

One of the main tactics to apply now to enhance compliance is to focus on the concept of resilience in all areas of the financial institution. Incorporate this concept into your business continuity management plan, vendor management program, third-party supply chain management, and information security. The key is to prepare in advance for a disruption—to put processes in place to reduce the possibility of disruption, and to minimize the impact of disruption should it occur.

Here’s another way to stay ahead of regulators: Financial institutions can connect the concept of risk appetite to the acceptable risk in their risk assessments. This goes beyond merely asserting that whatever residual risk you may have is deemed acceptable, which is highly subjective. Inherent risk less controls establish residual risk. However, residual risk levels must be compared to pre-determined risk appetite levels to determine acceptability. Only if the residual risk is less than or equal to their risk appetite can residual risk be considered acceptable. This process also reduces subjectivity and uncertainty—which should leave examiners and auditors much less room for interpretation, and result in a better audit/exam experience for you.

What to Consider in 2022 and Current Trends

Another area we’ll definitely be watching in 2022 involves the new incident notification rules that were issued late last year. All financial institutions will need to update their incident response plan and possibly their vendor management program and business continuity plans to accommodate these new regulations. These changes, while not necessarily difficult, can be pervasive in that they will cross over into multiple policies and procedures. In short, the rule requires institutions to notify their primary federal regulator as soon as possible—no later than 36 hours—after they determine that a notification incident has occurred. There are also new requirements for third parties to notify you if they experience a similar event, which could require changes to the vendor contract. The effective date of the new rule is April 1, 2022, with compliance expected to begin on May 1, 2022. There may be a grace period, but financial institutions should be prepared for examiners to ask questions about your adherence to these new rules at your next Safety and Soundness exam.

Regarding trends, we believe the focus on third-party risk management will continue in 2022 and into the future. Currently, there’s growing support for the idea of having the FDIC, Federal Reserve, National Credit Union Administration (NCUA) and other agencies coalesce around a single set of standards for third-party management. This would create more consistency with the rules concerning how regulators and others define third parties and vendors, and expectations for effective risk management. The outcome of the discussions around this topic may not manifest until Q3 or Q4 of this year, but institutions should work on formalizing their process for conducting due diligence when dealing with fintech companies and other critical vendors.

Safe Systems has been serving financial institutions for more than 25 years. To get more of our experts’ views on this topic, listen to our webinar on “Compliance Review and Tips, Tricks, and Trends for Staying Ahead of Regulators in 2022.”

19 Jan 2022
Balancing Strategy and Compliance

Balancing Strategy and Compliance: Addressing the Strategic Needs of Your Institution While Remaining Compliant

Balancing Strategy and Compliance

Banks and credit unions require a complex interconnected infrastructure to support their employees, serve customers, and maintain their operations. This entails an array of owned and outsourced elements: hardware, software, controls, processes, and evolving technologies such as cloud, artificial intelligence (AI), machine learning, and more. In addition, effective data governance and data management are fundamental to maintaining the confidentiality, integrity, and availability of information. The data management process is highly regulated and financial institutions are under increasing pressure when trying to balance the strategic needs of their organization with the increased demands for remote employees and online customers.

Evolving Remote Workforce and Customer Base

Over the past couple of decades, advancements in communication and technologies have allowed for a more mobile workforce and customer base, and the ongoing COVID-19 pandemic quickly intensified this trend. During the first year of the pandemic, Gartner conducted a survey that found 82% of businesses intended to allow remote work at least part of the time, with 47% of companies allowing it full time. Although 2o20 represented a significant increase in remote work and digital engagement, the trend seems to be continuing for the foreseeable future. According to Upwork’s Future Workforce Report 2021, 40.7 million American professionals, nearly 28% of respondents, will be fully remote in the next five years, up from 22.9% from the last survey conducted in November 2020.

This trend requires adding more technology and devices to enable online access to financial services, and to enable secure access to the information and other resources needed for remote workers to perform their duties away from the office. Banking customers want convenient access to financial services, whether through a physical location, the internet, or a mobile app, and institutions need the tools and techniques to keep them secure. With more devices in the hands of employees and customers, there are many more vectors for cyberattacks and way more endpoints to secure. Even institutions that have been trying to avoid the risks that come with enabling remote engagement are forced to reevaluate the costs and benefits.

Increasing Regulatory Requirements

Privacy and data security have become key compliance issues for financial institutions as they adapt to accommodate employees and customers who prefer to work and bank remotely. From a regulatory standpoint, the Federal Financial Institution Examination Council (FFIEC) has always expected financial institutions to have data management controls in place to protect data in physical and digital forms wherever the data is stored, processed, or transmitted. This includes any data relating to the organization, its employees, and its customers. “The data management process involves the development and execution of policies, standards, and procedures to acquire, validate, store, protect, and process data,” states the FFIEC IT Handbook’s Architecture, Infrastructure, and Operations booklet. “Effective data management ensures that the required data are accessible, reliable, and timely to meet user needs.”

The FFIEC requires institutions to follow a wide range of other guidelines and procedures, which are reflected in various FFIEC booklets and include:

  • Governance – Management should promote effective IT governance by establishing an information security culture that promotes an effective information security program and the role of all employees in protecting the institution’s information and systems.
  • Know-your-customer – Financial institution management should choose the level of e-banking services provided to various customer segments based on customer needs and the institution’s risk assessment considerations.
  • Resilience – Financial institutions are responsible for business continuity management (BCM), which is the process for management to oversee and implement resilience, continuity, and response capabilities to safeguard employees, customers, and products and services.

Strategic Compliance Solutions

With so many compliance issues to address, it can be difficult to balance the needs of your financial institution, your remote workers, and your customers. Safe Systems has a team of compliance experts and a broad range of compliance solutions to help you manage government regulations, information security, and reporting efficiently. Our team of compliance experts are trained in banking regulations, hold numerous certifications, and are laser-focused on delivering the tools and knowledge to give you compliance peace of mind.

30 Dec 2021
Our Top Blog Posts of 2021

Our Top Blog Posts of 2021

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.

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28 Dec 2021
Cybersecurity Insurance and Multi-Factor Authentication

Cybersecurity Insurance and Multi-Factor Authentication

Cybersecurity Insurance and Multi-Factor Authentication

Financial institutions are increasingly embracing cybersecurity insurance as an important aspect of their information security program. Cyber insurance can offer vital coverage to protect businesses from various technology-related risks. Data breach insurance, for example, helps companies respond if personally identifiable information gets lost or stolen from their computers—whether intentionally by a hacker or accidentally by an employee. Cyber liability insurance offers expanded protection to help businesses prepare for, respond to, and recover from cyberattacks.

As cybercrimes continue to intensify, more cybersecurity insurance companies are calling for organizations to employ multi-factor authentication (MFA). Some carriers are even refusing to provide insurance quotes to companies that are not using this authentication method. From their perspective, MFA adoption makes perfect sense; it keeps unauthorized individuals from accessing sensitive information, reducing ransomware, data breaches, and other cyberattacks. This, in turn, minimizes insurance claims and saves carriers money.

For insurance providers, MFA is appealing because it lowers cyber risk by requiring users to verify who they are. The individual must furnish valid identification data followed by at least one other credential: a password, one-time passcode, or physical characteristics like their fingerprint or face. This strict authentication system allows organizations to certify people’s identity—before granting them access to sensitive information, an account, or other assets—and this can significantly strengthen their security.

While MFA is heavily promoted by many cyber insurance companies, an institution’s regulators may not require financial institutions to use multi-factor authentication. However, implementing MFA for a whole internal network may not be a simple task. Depending on the solution, it may require installing agent software to all the endpoints requiring MFA and configuring appropriate “break-glass” accounts for emergency use, which creates more infrastructure to be monitored and managed.

MFA Implementation Tips

To simplify MFA implementation, Banks and credit unions can apply a sequenced strategy instead of jumping straight to the internal network. As a first step, institutions can ensure MFA is turned on for all remote-access users, including creating endpoint control policies for their devices. The next logical step would be to lock down MFA for cloud applications. This includes Microsoft Online services like M365 (formerly Office 365) and Azure Active Directory (Azure AD). These solutions come with a variety of free security features that organizations can customize to their business requirements. Even at low licensing levels, these products allow MFA to be turned on for all users—which can be highly effective for averting business email compromise and ransomware attacks. But institutions will need higher-level licensing if they want to make conditional access policies based on the specific location, identity, or device of users. Azure AD Premium P1 and M365 Enterprise E3, for example, have a variety of advanced features that allow conditional access policies to be established to enhance security.

MFA is just one layer of security for banks and credit unions to consider. We hope this post provided some insight into applying MFA for both security and insurance purposes. To learn more about this topic and other security layers, listen to our recent “Ransomware, Cybersecurity, and MFA” webinar, hosted by our Chief Technology Officer, Brendan McGowan.

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

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

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.”

06 Dec 2021
How Layered Security Can Address Growing Cyberthreats

How Layered Security Can Address Growing Cyberthreats

How Layered Security Can Address Growing Cyberthreats

With the increasing complexity of cyberattacks, financial institutions need to implement more effective—and comprehensive—security measures. They need a variety of elements to create a layered approach to secure their data, infrastructure, and other resources from potential cyberthreats.

Many organizations rely on a castle-and-moat network security model where everyone inside the network is trusted by default. (Think of the network as the castle and the network perimeter as the moat.) No one outside the network is able to access data on the inside, but everyone inside the network can. However, security gaps may still exist in this model and others. The best approach to compensate for gaps is to surround the network with layers of security.

The basic “table stakes” for a layered security approach include a perimeter firewall with content filtering, email threat filters, an endpoint malware solution, and a robust patch management process. Banks and credit unions could also invest in additional and more sophisticated layers but each one will have associated acquisition and management costs, along with ongoing maintenance. So, it’s prudent for institutions to invest only in the number of layers/solutions they can competently manage.

Key Concerns

Today the top IT security concern for many organizations is ransomware. Due to the proactive measures many financial institutions have taken, the banking industry has fewer security breaches than health care and some other industries thus far. However, when a breach does happen to a financial institution, the impact is more costly than breaches occurring in other industries.

Four-Layer Security Formula

With these concerns in mind, here’s a four-layer “recipe” organizations can employ to improve their security posture:

  • Training and Testing: Using email phishing tests can serve as a good foundation for minimizing BEC and other social engineering threats.
  • Network Design: Institutions should refresh older networks to segment their components into different zones. It’s no longer sufficient to have servers, workstations, and printers sitting in one IP space together.
  • Domain Name System (DNS) filtering: DNS filtering prevents potentially damaging traffic from ever reaching the network. Because it proactively blocks threats, this makes it one of the most effective and affordable security layers institutions can apply.
  • Endpoint Protection: Institutions should have this type of protection on each of their endpoints, and the best endpoint protection tools have built-in ransomware solutions.

Other Important Considerations

It’s important to back up data regularly and ensure that those backups are well beyond the reach of ransomware and other threats. (Backups done to a local server that’s on-site and are still on the network may be susceptible to ransomware.) One way to address this issue is to have immutable backups, which are backup files that can’t be altered in any way and can deploy to production servers immediately in case of ransomware attacks or other data loss. Another option is to send backups to a cloud solution like Microsoft Azure Storage, which is affordable and easy to integrate because there are no servers to manage.

Another crucial element in security is Transport Layer Security/Secure Sockets Layer (TLS/SSL) encryption protocol, which can be somewhat of a double-edged sword. About 80 percent of website traffic is encrypted to protect it from unauthorized users during transmission. Traditional firewalls don’t have the ability to scrutinize traffic against a content filtering engine, which means savvy hackers can hide ransomware and other dangerous content inside. But firewalls with advanced features are capable of TLS/SSL inspection; they can decrypt content, analyze it for threats, and then re-encrypt the traffic before entering or leaving the network.

There’s an array of security solutions that institutions can implement to establish layered protection against cyber threats. For more insights about this topic, listen to our webinar on “Cyber Threats, Why You Need a Layered Approach.”

23 Nov 2021
Importance of Security Layers

Importance of Security Layers

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.

16 Nov 2021
Using the Free Features of Microsoft Azure AD and O365/M365 to Enhance Cloud Security

Using the Free Features of Microsoft Azure AD and O365/M365 to Enhance Cloud Security

Using the Free Features of Microsoft Azure AD and O365/M365 to Enhance Cloud Security

Microsoft Azure Active Directory (Azure AD) and Office 365/M365 have a variety of free security settings that financial institutions can customize to their needs. These settings are important because they can enhance an institution’s cloud environment and operational security—and they’re available to everyone with Azure AD or O365/M365. Remember, even if the license was acquired through a third party, your institution is still responsible for managing all the security features of these cloud-based solutions.

Be aware that while adjustments made to the defaults can strengthen your cloud security, they will also impact the way people use the products. For instance, multifactor authentication (MFA) is a great first step at improving the security of your cloud environment but does impact how your users will log in.

Here are some other important free security settings you can optimize in Azure AD and/or O365/M365 to enhance security:

  • Global Auditing — The global auditing feature logs events that happen across Azure AD and O365/M365. It is advisable to enable Global Auditing. The information gained with this feature can help troubleshoot problems and investigate issues. Once Global Auditing has been enabled, it can take about 24 hours for the new setting to take effect.
  • Alert policies — Alert policies are designed to help you monitor threats against your existing resources. There are default built-in policies, and you can also create additional custom policies for free on your own. Keep in mind, you need to set the target recipient(s) for these policies.
  • Sharing in Microsoft OneDrive and SharePoint — Since these products were created to foster collaboration, their default setting is normally set to enable external data sharing. This allows users to create anonymous access links that make it possible for anyone in any organization with OneDrive and SharePoint to sign in and view their information. It is recommended that you review the level of sharing to control the flow of data based on what is appropriate for your organization.
  • External access in Microsoft Teams — Teams is set up by default to make it easy for individuals to connect with users located anywhere in the world, even in other organizations. You should review the platform’s security and compliance settings to ensure it fits your organization’s standards. You can block all external domains to restrict users’ ability to communicate externally.
  • Enterprise applications — Enterprise apps can represent a huge risk if users have the freedom to add them on their own. You can change the security setting to prevent anyone from randomly adding apps without the administrator’s approval. When this feature is activated, Microsoft will block users’ attempts to add apps and notify the administrator, who can approve or deny their requests.
  • Application registrations — Similarly, institutions can alter their security features to block users from registering any applications. There’s rarely a reason to allow users without administrative rights to create app registrations, so reviewing and/or adjusting this setting is essential.

Making these adjustments will help you to maintain control over users’ activities and tighten security. To learn more about M365 security topics, listen to our recent webinar, Ask the Experts: O-M365 Security Basics for IT Administrators.

Safe Systems’ M365 Security Basics solution provides visibility into these and other security settings and allows banks and credit unions to regularly monitor and review their configurations making it easier for them to manage their Azure AD and O365/M365 accounts.

05 Nov 2021
Minimize Examiner Scrutiny by Automating Compliance Processes

Minimize Examiner Scrutiny by Automating Compliance Processes

Minimize Examiner Scrutiny by Automating Compliance Processes

Financial institutions can expect to receive increased auditor and examiner scrutiny over their governance and oversight practices, and inconsistencies between procedures and practices will often result in findings. However, these challenges can be minimized or even eliminated by using automation to manage compliance processes.

Incorrect or Outdated References

One of the most widespread exam issues institutions encounter is due to policy inconsistencies, where incorrect or outdated references are used. Mentioning outdated guidance in policies is one of the most common offenses that institutions commit. For instance, referring to an older term like SAS 70 (Statement on Auditing Standards No. 70) or SSAE 16 (Statement on Standards for Attestation Engagements No. 16) instead of the newer SSAE 18 (Statement on Standards for Attestation Engagements No. 18) could be dismissed as a minor oversight, but it could also be considered a “red flag” causing examiners to question whether the institution has properly updated its policies, resulting in further scrutiny. A weakness in one area strongly suggests that there may be other weaknesses.

Another example of this type of issue is referencing “business continuity planning” (or BCP) versus “business continuity management planning” (or BCMP). Again, this would be a minor mistake because the term business continuity planning is not necessarily obsolete; still, it’s not consistent with the most recent guidance, and could lead to deeper dives in other areas. (In 2019, the Federal Financial Institutions Examination Council (FFIEC) issued the Business Continuity Management booklet. This guidance, part of the FFIEC Information Technology Examination Handbook, replaces the Business Continuity Planning booklet issued in February 2015.)

The problem with employing slightly outdated terminology also applies to phrases like “maximum allowable downtime” (MAD) and “maximum tolerable downtime,” (MTD) which is the newer reference. Examiners and auditors will accept either phrase so this is not a critical issue, but the use of dated terms can instill doubt in examiners and make them inclined to dig deeper into the institution’s policies.

Procedure and Practice Inconsistencies

Disconnects between policies and practices are another frequent exam challenge for institutions. Ideally written procedures should not contain statements that contradict the institution’s actual practices. In other words, your actual practices should as closely as possible reflect what you say you’ll do in your written procedures. For instance, there would be a procedure/practice inconsistency if the password policy of the information security program required eight characters, and the acceptable use policy (AUP) that employees signed allowed passwords of a different length. This type of inconsistency will almost certainly lead to further issues with examiners and auditors.

Another key area of focus for examiners and auditors is board reporting. Disconnects can occur if the information presented to the Board is not properly documented in Board minutes. This challenge is compounded by the sheer volume of information modern Boards are required to digest. The only way to make sure board minutes contain all pertinent details is to periodically review them. This will help ensure that the content of board meetings is consistent with both examiner expectations, and your written procedures.

Integrating Automation

In addition to changes in guidance terminology or updates to guidance policies, an institution’s procedures can and do change periodically as well. So contradictory statements resulting from policy updates are inevitable. Still, financial institutions must be aware of guidance changes and must also ensure their current procedures align with their practices and are consistent across all documents to make sure they comply with industry guidance and regulations. While this is easier said than done, technology can make it easier for institutions by providing regular updates to accommodate changing regulations and trends as well as make it more feasible for them to identify inconsistencies between their policies and procedures.

For example, a simple way to assess your potential exposure to procedural disconnects is to search through the documents in your institution’s information security program, for statements that include the words “will,” “must” or “shall.” Each of these statements contains an obligation of some sort; something you’ve committed to doing. For each occurrence, determine if A) it’s being completed exactly as indicated, B) by the group or individual assigned responsibility, and C) it’s being performed at the designated frequency or interval. Automation can help track these tasks and provide the necessary proof in the form of documentation. Additionally, most policies will make multiple references to the same task; business continuity may be referenced in information security, incident response in business continuity, vendor management in both information security and business continuity, etc. A change to a procedure or practice in one document should automatically trigger the associated changes elsewhere.

Integrating automation into the equation can help institutions streamline their methods for managing a variety of compliance changes and issues and greatly reduce the most common causes of findings due to disconnects and inconsistencies. Automation can make it easier to maintain more consistent and complete integration in areas throughout the organization, including information security, risk management, network management, vendor management, and business continuity management. Ultimately, automated updating, tracking, reporting, and other tasks can facilitate better preparation for exams and audits, and greatly reduce stress levels!

To learn more about how automating routine procedures can help financial institutions avert auditor and examiner criticism, listen to our webinar on “Managing Your Compliance Processes in 2021: Is There a Better Way?”

If you’re not certain where to begin when it comes to automating your compliance processes, check out our new service, COMPaaS™ (Compliance as a Service). This set of connected applications and powerful monitoring and reporting tools can be customized to target and eliminate your institution’s specific compliance pain points. One of our experts will help you create a solution that is unique to your institution, so you only pay for the services you need. And you can feel confident in choosing from products and services that are backed by nearly 30 years of experience in the banking industry.

26 Oct 2021
Glennville Bank Strengthens Security Posture with CloudInsight™ M365 Security Basics

Glennville Bank Strengthens Security Posture with CloudInsight™ M365 Security Basics

Glennville Bank Strengthens Security Posture with CloudInsight™ M365 Security Basics

Our CloudInsight™ M365 Security Basics solution is helping community financial institutions increase their security posture. Take Glennville Bank, for example. The Georgia community bank, which has $312 million in assets, seven locations, and 66 employees, jumped at the chance to capitalize on the service to identify and secure threats to its Microsoft 365 settings. M365 Security Basics provided the bank with greater visibility into cloud security settings for Azure Active Directory (Azure AD) and M365 tenants through reports and alerts.

Like most financial institutions, Glennville Bank leverages technology to better serve its customers and maintain its operations. Also, like other institutions, the bank has a variety of Microsoft licenses, and managing the security settings for these products became difficult and time-consuming, particularly for Glennville Bank’s network administrator, Zach Horn, who describes his proficiency with Microsoft as “fairly limited.”

“Given the complexity of our cloud tenant settings, I’m not comfortable enough with Microsoft or their updates to manage every setting correctly,” Horn explained. “With all the potential security risks out there, I knew I needed reports that could help me identify risky security settings, monitor identity controls, and ensure our configuration matches our information security policy.”

With M365 Security Basics, Glennville Bank was able to set data trends and identify several settings that needed addressing, such as creating a baseline for failed logins. The bank also discovered that its user access details were often inconsistent, and through the M365 Security Basics service they received easy-to-follow instructions for correcting the problem. “Safe Systems did a great job fine-tuning the product to the demographic we needed,” Horn said. “Their knowledge has been helpful in pointing me in the right direction in knowing which Microsoft licenses I need to go to in the future.”

Product Highlights

M365 Security Basics is the first offering in Safe Systems’ CloudInsight™ family of products. It’s specifically designed for community banks and credit unions that have Microsoft 365 products (Exchange Online, SharePoint, or OneDrive), use Azure AD, and store non-public information in the cloud. M365 Security Basics’ reporting, alerts, and quarterly reviews are customized to help financial institutions improve their cloud security awareness by identifying potential risks and common signs of compromise. The product is developed by engineers who hold dozens of certifications, including the Microsoft 365 Certified: Security Administrator Associate certification. M365 Security Basics makes it easier for institutions to monitor their configurations for current and new features that are automatically enabled by major cloud providers like Microsoft Azure.

The powerful reporting from M365 Security Basics enables financial institutions to review vital Microsoft cloud tenant settings. This allows them to recognize unsafe security settings, examine identity controls, make sure their configuration is consistent with their information security policy, and demonstrate this to examiners and stakeholders. Reports are available as “Summary” versions (with brief information, such as the Tenant Summary and User Summary) and “Details” versions with more in-depth data. (Glennville Bank uses the Tenant Summary to highlight important issues during IT steering committee meetings.)

M365 Security Basics also offers alerts and quarterly reviews as add-on services. Alerts provide notifications about the most common indicators of compromise (like unauthorized access) and are grouped under Azure AD Roles, Azure AD Sign Ins, OneDrive, SharePoint, and Exchange Online. The quarterly reviews give institutions a periodic, objective analysis of their recent M365 Security Basics reporting, so they can gain a better understanding of their Microsoft 365 tenant security.

CloudInsight™ M365 Security Basics not only helps financial institutions like Glennville Bank secure their information but also makes it easier to compile data required for examiners. Read the complete Glennville case study to see how your organization can benefit from M365 Security Basics.

21 Oct 2021
The Importance of Cybersecurity, not Just in October—but All Year Long

The Importance of Cybersecurity, not Just in October—but All Year Long

The Importance of Cybersecurity, not Just in October—but All Year Long

Do Your Part. #BeCyberSmart.

With October being Cybersecurity Awareness Month, it’s the opportune time for everyone to focus on online safety and to become more cyber savvy. This month, the Cybersecurity & Infrastructure Security Agency (CISA) and National Cyber Security Alliance (NCSA) are encouraging all Americans to do their part and be cyber smart. This means organizations and individuals need to own their role in protecting cyberspace, which requires taking personal accountability and proactive steps to enhance cybersecurity.

The first step to increasing cybersecurity is to understand its importance. Cybersecurity, according to the CISA, is the art of protecting networks, devices, and data from unauthorized access or criminal use and the practice of ensuring the confidentiality, integrity, and availability of information. And the importance of applying effective strategies to keep computer systems and electronic data secure is growing as cybercrime rises. But the key to enhancing cybersecurity is to recognize the hazards that can threaten online safety: malware erasing an entire computer system; a hacker breaking into a system and altering files; someone using another person’s computer to attack others; or an intruder stealing credit card information and making unauthorized purchases.

To minimize the risk of cyberattacks, organizations should consider implementing these best practices from the CISA:

  • Keep software up to date by installing software patches to prevent hackers from taking advantage of known problems or vulnerabilities.
  • Run up-to-date antivirus software to automatically detect, quarantine, and remove various types of malware.
  • Install a firewall to prevent cyberattacks by blocking malicious traffic before it can enter a computer system.
  • Employ multi-factor authentication (MFA) to validate users’ identity.
  • Change default usernames and passwords, which are readily available and can be used by malicious actors.
  • Select strong passwords that will be difficult for attackers to guess and use different passwords for different programs and devices.
  • Beware of suspicious emails that may be engineered to steal information and money or install malware on devices. 

While taking precautions cannot guarantee complete protection against hackers, improving cybersecurity practices can certainly help. It’s also important to become more knowledgeable about effective strategies for reducing cybersecurity risks, which is a major goal of Cybersecurity Awareness Month. In addition, Cybersecurity Awareness Month, formerly called National Cybersecurity Awareness Month, strives to ensure that individuals and organizations have the resources they need to be safer online. People can take advantage of the CISA’s cybersecurity tips, cyber essentials, and other information to become more cyber smart—not just this month, but throughout the year.

Safe Systems also offers a wide range of resources to help financial institutions enhance their cybersecurity and protect the confidentiality, integrity and availability of their information. Our multi-layered security suite, which is designed to protect vulnerability points inside and outside the network, includes DNS filtering, endpoint protection, next-generation firewall, security event log monitoring, and vulnerability monitoring. Community banks and credit unions can implement these security services to improve their cybersecurity posture, prevent cyberattacks and keep their operations running smoothly.

19 Oct 2021
What Makes a Successful Business Continuity Management Plan (BCMP)?

What Makes a Successful Business Continuity Management Plan (BCMP)?

What Makes a Successful Business Continuity Management Plan (BCMP)?

Minimizing the impact of disruptions of any kind, natural or man-made, or cyber should be a priority when it comes to the overall security of your institution. But how do you know if you’ve checked off all the important boxes?

A compliant and successful business continuity plan has the following components: Risk management (Business Impact Analysis, Risk/Threat Assessment); continuity strategies (Interdependency Resilience, Continuity, and Recovery); training and testing (aka Exercises); maintenance and improvement; and board reporting. In addition, the expanded FFIEC BCM IT Examination Handbook calls for all “entities” to rethink their approach to business continuity and be prepared to make appropriate plan revisions to meet these expectations.

To comply with regulatory requirements, it is important for institutions to not only understand the BCM process but also focus on an enterprise-wide, process-oriented approach that considers technology, business operations, testing, and communication strategies that are critical to business continuity management for the entire organization, not just the information technology department. It seems like a lot, but the risks an institution could face by not having a compliant and effective plan in place can be even more costly.

Don’t know where to start? We’ve developed a blog that walks you through the key requirements of BCMP, provides insight into the new guidance and the specific changes you may need to make to meet these expectations, and helps you ultimately determine what to include in the plan. View the original blog post here.

13 Oct 2021
Stories from the Front Lines

Stories from the Front Lines: How Real Financial Institutions Handled an O365/M365 Cloud Security Compromise

Stories from the Front Lines

Microsoft 365 (formerly Office 365) comes with an array of settings that customers can modify to enhance their security controls. When these settings are not effectively adjusted though, serious cloud security compromises can ensue. Our M365 Security Basics solution helps financial institutions detect and respond to potential problems. From our recent webinar, here are real-life stories about financial institutions (whose names have been changed) that had their cloud security compromised. See how they handled each situation, so you can learn what to do and not do to secure your O365/M365 account.

Loan Officer – Email Forwarding

Luke, a loan officer, is constantly emailing people inside and outside his organization. He often sends sensitive information but uses encryption to protect his outbound emails and multi-factor authentication (MFA) to protect his identity. Somehow his email account was compromised—for eight whole months—before the problem was discovered. Our M365 Security Basics reporting indicated there was an issue with his email being forwarded to an external domain. We worked with the IT administration team to confirm that a suspicious Yahoo address was not an authorized send-to address for the emails Luke had been receiving. The intruders’ cunning scheme involved a modified mailbox setting that predated Luke’s MFA setup and the other precautions Luke had implemented. We were able to resolve the compromise by removing the forwarding property. Moving forward, Luke’s IT team needs to keep a close watch to ensure the organization’s email accounts are protected.

IT Administrator – Global Auditing

Han works at a smaller organization and wears multiple hats as an IT, compliance, and security administrator. While he’s not well versed in cloud security, Han thinks the cloud is the best option for his organization. He selects various Microsoft cloud resources and works with a vendor to establish a tenant in Azure Active Directory (Azure AD), which is a requirement for O365/M365. Han provisions his account administrative rights in Azure, synchronizes users and passwords, and gets help training end-users on Microsoft 365 services like OneDrive, SharePoint, and Teams. Then he notices an Azure AD account that he and his team have never seen—and the name of the account is strangely almost identical to an existing end-user. Han called our support staff for assistance and learned that his global administrator account had been compromised. To make matters worse, Han had left his security settings at defaults and had not enabled global auditing, which meant there was no way to determine what the attacker had changed in the system. The best solution was to move the organization’s data, email, and identities to a brand new Microsoft tenant. This extensive migration project could have likely been avoided if Han had enabled MFA and the proper audit settings.

HR – External Document Sharing

Human resources vice president Leah employs a variety of technologies to facilitate working from home and the office. Leah relies on the Cloud, and desktop and mobile apps to access documents on all her devices and enjoys using Teams to share files with others in her organization. Using these technology services has caused her to inadvertently place the company at risk of exposure and identity compromise because her IT administration team had not implemented the appropriate security controls for all their organization’s licensed technology services, creating a security gap. Luckily, the IT team received an M365 Security Basics alert for a file being shared externally in OneDrive, which is a common alert that we see. There was also enough data in the alert to indicate the multiple bad security, identity, and compliance practices that Leah has. The IT team resolved these issues by reducing the default sharing levels of SharePoint Online and OneDrive and retraining Leah on good and bad practices for security, identity, and compliance.

CEO – Multifactor Authentication

As the CEO of his organization, Chewy’s contact information is very public; his email address is prominently displayed on the company’s website, LinkedIn, and other social media platforms. Chewy uses multiple devices to get work done in the office and at home. He often signs into whatever computer is handy, whether it’s his or his wife’s laptop. Chewy’s account is under attack in Azure AD from a Russian IP. M365 Security Basics Alerting was able to notify his IT team of this by way of the Large Number of Failed Sign Ins for a Single User alert. Unfortunately, the IT department did not require MFA registration for most of the organization’s users, including Chewy, even after being alerted to the attack. The Russian attackers eventually compromised Chewy’s account. Once they did, our alerting engine promptly notified the IT team of a successful sign-in from outside of the USA, which they promptly responded to, limiting the amount of time the account was compromised.

Listen to the full stories or watch the complete webinar.

11 Oct 2021
What Financial Institutions Should Budget for in 2022

What Financial Institutions Should Budget for in 2022

What Financial Institutions Should Budget for in 2022

Many of us thought 2021 was going to be the downhill side of the pandemic. I recall working on a webinar presentation that we hosted last summer and including the words, “Now that the pandemic is behind us…” Obviously, I was overly optimistic. As we look ahead to 2022, we must acknowledge that the COVID-19 pandemic will continue to affect us to one degree or another. With that said, these budgeting ideas for 2022 may look somewhat similar to those for 2021, but there are slight variations based on current banking technology, compliance, and security issues.

1. Multifactor Authentication

Implement multifactor authentication (MFA) on all your email accounts wherever it is possible and appropriate. MFA can reduce the risk of having account credentials compromised by as much as 99.9%, making it one of the most effective measures you can use to protect your institution. There is typically a small cost for licensing and implementing MFA software. So, you can add MFA to your email accounts for a nominal cost and with minimal effort in most cases. If you are using Microsoft’s cloud email solution, for instance, implementing MFA can be as easy as changing a few minor settings. Another area to consider for MFA is logging into the domain account. There can be a cost associated with this as you will probably want to use a tool to help you manage the process. You can apply MFA only on accounts with administrator rights or on all users. But since many cybersecurity insurance companies are requiring MFA for accounts with administrator rights, using this stronger type of authentication might be your only option.

2. Laptops

With different variants of COVID-19 or other viruses popping up, remote work may still be an option for certain employees. Remote capabilities may even be necessary to keep the institution operating smoothly at times. Be sure you have the infrastructure in place for a partial remote workforce because the need could develop at any point. For this reason, you should consider providing laptops for all employees who could conceivably work from home. Start with those who need new devices. Then prioritize based on those doing the highest-level work necessary to keep the institution running. Laptops and encryption software, required for mobile devices, may cost slightly more but should not cause a huge increase in expenditures. In some cases, you may be able to reuse a desktop computer to replace an older workstation for an employee whose duties cannot be performed remotely.

And don’t forget… There is a chip shortage and high demand for laptops, which means it can take months to secure computers and other hardware. So, order any equipment you need well in advance to ensure you have the appropriate infrastructure in place to support staff that may need to work from home.

3. Moving to the Cloud

Having infrastructure in the cloud can be extremely beneficial, so slowly start moving your infrastructure to the cloud. Cloud infrastructure decreases the need for an employee to be onsite with the hardware, and cloud computing increases uptime. In addition, disaster recovery becomes easier and faster with cloud infrastructure. More than 90% of Fortune 500 companies are running at least some infrastructure in the cloud, primarily through Microsoft’s cloud computing platform: Azure. The cloud is the future of IT and infrastructure, and it makes sense for institutions that need reliable and resilient infrastructures. So, if you need to purchase a server next year, consider getting a quote for moving the server to the cloud instead.

4. Cloud Security

While the cloud offers plenty of advantages, it comes with settings, management tools, and security options that must be effectively configured and managed to ensure the highest level of security in the cloud. Cloud security is a concern for not only institutions with infrastructure in the cloud, but also for M365 Windows/Office licensees with OneDrive enabled, email in the cloud, or using Microsoft as an authentication mechanism with a third-party application. Earlier this year, the FDIC released a letter outlining the need to secure cloud configurations. Their cloud-security concerns are warranted. Safe Systems has worked with several institutions ranging from a hundred million in assets up to multibillion dollars in assets and found that almost every institution had gaps in their cloud security. Some institutions had indications of their email or user accounts being compromised; others had settings that could open the door to future compromises. Safe Systems worked closely with these institutions to develop an innovative M365 Security solution to address these issues with reports, alerts, and reviews. This unique product is specifically designed to help financial institutions manage their cloud setup now and in the future. In addition, it is a reasonably priced option for the substantial amount of value that it delivers. Institutions should reach out for a quote to determine if M365 Security could fit into their budget next year.

5. Virtual ISO

Another item to consider for your budget is virtual Information Security Officer or VISO services, which we also mentioned last year. These services have become increasingly popular as the landscape of information security has grown more extensive and complex. In many cases, institutions are finding it harder to keep up with the latest information security expectations, regulations, and trends. Safe Systems’ ISOversight service addresses this problem by combining applications for self-management with assistance from compliance experts to offer a VISO service at a competitive price. This type of service can be beneficial in many ways as it can provide structure, automation, accountability, assistance, and consistency throughout your information security program. It can also enable your institution to stay engaged, which is critical when an exam or audit occurs. VISO services, which vary in price depending on the work being performed by the third-party provider, are ideal for any institution with limited access to security expertise in-house.

6. Cybersecurity

You cannot have a conversation about budgets for next year without addressing the issue of cybersecurity. Consider this: Cyber-attacks are 300 times more likely to hit financial services firms than other companies, a recent Boston Consulting Group report indicates. Cyber-attacks continue to climb each year, with the global cybersecurity market expected to eclipse $300 billion by 2024, according to Global Insights. And cybersecurity has become even more precarious during the COVID-19 pandemic. The pandemic has created new opportunities for security breaches as the increase in remote work makes information security more challenging to manage. Unfortunately, institutions will need to increase their security layers and annual spending to address this issue. According to Computer Services Inc. (CSI), 59% of financial institutions will increase spending for cybersecurity this year.

In Conclusion

The threat to your institution’s data is as real today as it ever has been. Therefore, make sure you are applying these measures to strengthen your security:

  • Employee training to ensure adequate, effective, and safe practices
  • Perimeter protection to ensure the appropriate layers are enabled and all traffic is being handled correctly, including encrypted traffic
  • Advanced threat protection and logging to be able to identify how, if at all, malware or an intrusion created an incident
  • Backup and data redundancy to ensure ransomware cannot wipe out your data

Have a conversation with a security company you trust to ensure that, if you are the target of a ransomware attack, your business won’t sustain long-term damage. In other words, invest in cybersecurity now, so your institution won’t end up paying more later.

As you contemplate your budget for 2022, don’t just think about the items that others have put on your plate. Be sure to consider the changes that may have occurred at your institution—and the ones that may be coming—and have a plan to address these. All these changes can be exciting and make a major difference for your institution. But they can often be hard to get implemented if they are not budgeted for ahead of time.

29 Sep 2021
Understanding Microsoft O365/M365 Settings to Ensure Your Security Controls Are Effective

Understanding Microsoft O365/M365 Settings to Ensure Your Security Controls Are Effective

Understanding Microsoft O365/M365 Settings to Ensure Your Security Controls Are Effective

It’s important for financial institutions to understand Microsoft Office 365 (O365) and M365 settings, so they can optimize the security controls and quickly detect potential areas of compromise. The educational journey begins with acknowledging the role of Azure Active Directory (Azure AD), Microsoft’s cloud-based user authentication platform.

When your institution purchased O365 (recently rebranded as M365), it established a Microsoft tenant with Azure AD. Since that tenant belongs to you and your institution—not the licensing reseller—it is your responsibility to understand Azure AD and its controls. This is where you can customize the settings to create more sophisticated and appropriate security policies for your institution.



Monitoring for Exceptions to Security Controls

Once your institution has good policies in place, it’s essential to monitor for exceptions. There are so many security controls to check; it can be difficult to know if there is a policy exception or even an active compromise. As an added challenge, some controls can have a major impact on the user experience, and these controls cannot be created arbitrarily by a third party simply based on what is presumed to be best practice.

Therefore, you must build policies around what users are allowed to do, what your institution’s risk assessment defines, and what users will tolerate. Making appropriate policy-related adjustments to O365/M365 requires knowing how to connect with and analyze specific Microsoft data to modify the related security controls. Microsoft has created a plethora of controls, which can be difficult for many customers to navigate. That’s where it can be beneficial to partner with a value-added reseller like Safe Systems.

M365 Security Basics

Safe Systems consults with clients to help them best use O365/M365 controls and uncover their cloud security “blind spots.” M365 Security Basics is the first CloudInsight™ offering that provides visibility into security settings for Azure Active Directory and O365/M365 tenants.

M365 Security Basics consists of three main parts—reporting, alerting, and quarterly reviews— that your institution can choose from based on its needs. The reporting feature pulls Microsoft data that may not be easily accessible and compiles it into a user-friendly format. The reports show the fundamental settings at a glance, so institutions can track configuration changes over time. There are summary reports that IT administrators can use to quickly identify anomalies in their organization as well as detailed reports that include the specifics of a given anomaly.



While reporting generates important ongoing details, it can produce a substantial amount of information for you to review. Alerts can notify you as soon as possible about the most common setting changes or activity that can represent an indicator of compromise, so you can investigate and respond.

With the quarterly review component, Safe Systems will help you walk through the content of all your reports and discuss your overall strategy for adjusting the configurations. Having all this data at your fingertips makes it easier to make assessments to determine which settings are right for your organization. Two key settings to enable are multi-factor authentication—which should be universal for every user because it adds a critical layer of protection to the user sign-in process—and auditing which is crucial for investigating changes.



Educate. Expose. Empower.

The goal of M365 Security Basics is to educate financial institutions about the unfamiliar concepts related to O365/M365, expose the reality of what they are already living today, and empower them to take action where changes are needed.

For more information about how to understand O365/M365 settings to ensure your security controls are effective, listen to our webinar on “Cloud O365-M365 Security – Do You Know if You Are Currently Compromised?”

21 Sep 2021
Multi-Factor Authentication Offers Secure, Reliable Access Control

Multi-Factor Authentication Offers Secure, Reliable Access Control

Multi-Factor Authentication Offers Secure, Reliable Access Control

In our increasingly digital world, financial institutions must go beyond requiring only usernames and passwords for the sign-in process. They need to employ a combination of factors to validate the individuals using their resources, whether they’re customers accessing electronic products and services or employees accessing systems, applications, and data. Institutions can choose various levels of authentication to verify people’s identity before giving them access to sensitive information, accounts, and other assets. However, multi-factor authentication (MFA) offers a secure and reliable approach for reducing the potential for unauthorized access.

One of the key values of MFA lies in its use of multiple factors for the validation process. MFA adds a layer of protection by requiring users to present a variety of elements to prove who they are. With this method, users must supply valid identification data such as a username followed by at least two types of credentials, such as:

  • Something the person knows: This represents “secret” information that is known or shared by both the user and the authenticating entity. Passwords and personal identification numbers (PINs) are the most commonly used shared secrets, but newer methods of identification are gaining popularity. Users may be required to answer questions that only they should know, like the amount of their monthly mortgage payment. Another example is they might have to identify their pre-selected image (chosen when they opened their account) from a group of pictures.
  • Something the person has: This is often a security token or a physical device, such as an I.D. card or smartphone, that people must have in their possession. Password-generating tokens can significantly enhance security because they display a random, one-time password or passcode that the recipient must promptly provide to complete the authentication process. Having unpredictable, one-time passwords makes it more challenging for hackers to use keyboard logging to steal credentials.
  • Something the person is: This more complex approach to authentication uses a physical characteristic (biometrics) such as face, fingerprint, or voice recognition to verify people’s identity.

Since MFA incorporates factors based on knowledge, possession, and/or biometrics, it makes it more difficult for cybercriminals to compromise people’s identity. Thus, MFA is an ideal verification method to use when more sensitive or critical assets are at stake. MFA is so reliable that the Federal Financial Institution Examination Council (FFIEC) recommends applying it in more high-risk situations. “Management should use multi-factor authentication over encrypted network connections for administrators accessing and managing network devices,” states the FFIEC IT Handbook’s Architecture, Infrastructure, and Operations booklet.

MFA gives financial institutions a valuable security control for their internal and cloud resources. Take our quiz to see how much you know about multi-factor authentication.

14 Sep 2021
How Financial Institutions Can Better Manage Their Azure Active Directory Responsibilities

How Financial Institutions Can Better Manage Their Azure Active Directory Responsibilities

How Financial Institutions Can Better Manage Their Azure Active Directory Responsibilities

If your institution is using Microsoft 365 (formerly Office 365), you also have—and are responsible for—Azure Active Directory (Azure AD), Microsoft’s cloud-based identity and access management service. Microsoft Online business services like M365/O365, require Azure AD for sign-in and to help with identity protection. If you subscribe to Microsoft Online business services, you automatically get Azure AD with access to all the free features.

With an Azure AD tenant, you’re responsible for overseeing Azure AD’s security features, which can be customized to your business requirements. For instance, you can use Azure AD to require multi-factor authentication for users who are accessing important organizational resources. You can also employ Azure AD utilities to automate user provisioning between your existing Windows Server AD and cloud apps, including M365.

The Good News: You’ve Already Vetted Azure AD

If you’re daunted by the idea of overseeing Azure AD, don’t be. You’ve likely already vetted Azure AD for compliance because you’re using M365/O365. So, if you properly completed the vendor management process, Azure is already covered. In addition, Microsoft has taken steps to secure the environment that houses data in the Azure AD platform.

However, customers have the ability to choose settings that can make Azure AD more secure. Since M365/O365 is designed to be a collaborative environment, their out-of-the-box security settings are calibrated for sharing, requiring some modifications to enhance the security features. For example, you can use the Azure AD management interface to adjust the sharing dial to keep users from disclosing non-public or sensitive information.

Oversight Responsibilities

If you obtain an Azure AD license through a third party, you’re still responsible for managing, controlling, and monitoring access within your organization. This includes access to resources in Azure AD and other Microsoft Online services like Microsoft 365/Office 365. More importantly, your institution (not your vendor) is responsible for managing all the security features of Azure AD.

With an Azure AD tenant, you should:

  • Manage your cloud and on-premises apps
  • Manage your guest users and external partners, while maintaining control over your own corporate data
  • Customize and control how users sign up, sign in, and manage their profiles when using your apps
  • Manage how your cloud or on-premises devices access your corporate data
  • Manage your organization’s identity through employee, business partner, vendor, service, and app access controls
  • Detect potential vulnerabilities affecting your organization’s identities, configure policies to respond to suspicious actions, and then take appropriate action to resolve them
  • Gain insights into the security and usage patterns in your environment through reports and monitoring

Safe Systems can help financial institutions optimize key features in Azure AD and M365/O365 to meet or exceed their security objectives. Our M365 Security Basics solution can provide expertise and visibility into security settings through reporting, alerting, and quarterly reviews.

08 Sep 2021
Key Terms FIs Need to Know for Microsoft 365 (Office 365) and Azure Active Directory

Key Terms FIs Need to Know for Microsoft 365 (Office 365) and Azure Active Directory

Key Terms FIs Need to Know for Microsoft 365 (Office 365) and Azure Active Directory

Many financial institutions rely on Microsoft 365 (formerly Office 365) and Azure Active Directory (Azure AD) to access resources that can enhance their employee productivity and business operations. Here are some basic, but important, terms to keep in mind for these products:

  • Microsoft 365 (M365) versus Microsoft Office (O365)

Microsoft announced early last year that it was rebranding most of its O365 products to M365.

“We are changing the names of our Office 365 SMB SKUs on April 21, 2020. Yes, that’s right, the Office 365 name is hanging up its jersey and making way for Microsoft 365.”

Because Office 365 was so widely used, it has taken a while for this name change to catch on. Adding to the confusion, Microsoft already had M365 products prior to the name change. In most cases today, M365 and O365 are terms that are used interchangeably.

  • Azure AD

Microsoft Azure AD is a cloud-based identity and access management service that enables users to sign in and access various resources. You may be familiar with Active Directory as your on-premises identity management platform. What you may not realize is this: When you purchased M365, you received Azure AD along with it. Azure AD allows your employees to sign into resources like M365, the Azure portal, and other SaaS applications. They can also use Azure AD to sign into some of your institution’s other resources, such as apps on the corporate network and intranet.

  • Azure AD Sign in

Since all O365/M365 services are funneled through Azure AD, whenever employees try to access these resources, they must first sign in to Azure AD. Essentially, Azure AD facilitates sign-in attempts by authenticating users’ identities. Because Azure AD works behind the scenes, employees may not realize they’re not directly signing into O365/M365.

  • Basic versus Modern Authentication

Customers of O365/M365 and Azure AD can choose basic or modern authentication to access their services. Basic authentication requires simple credentials like a username and password while modern authentication goes a step further with multi-factor authentication. This advanced login protocol requires a username, password, and another identity verification such as scanning a fingerprint, entering a code received by phone, or using the Microsoft Authenticator app. This adds another layer of protection to the sign-in process before users can access their O365/M365 and Azure AD accounts.

Safe Systems can make it easier for financial institutions to strengthen their security posture when using cloud-based solutions like M365 and Azure AD. M365 Security Basics provides visibility into security settings for these products through in-depth reporting, alerting, and quarterly reviews.

01 Sep 2021
FIs Must Plan Ahead for IT Projects to Get Hardware in Time

FIs Must Plan Ahead for IT Projects to Get Hardware in Time

FIs Must Plan Ahead for IT Projects to Get Hardware in Time

The coronavirus pandemic has fueled ongoing inventory and material shortages in a number of industries and IT is no exception. Many components, such as servers, routers, firewalls, network switches, phones, keyboards, microphones, webcams, and more are still in relatively short supply. We’re seeing lead times for hardware delivery lasting four to six months—and the situation could get worse with the Delta variant. So, it’s crucial for financial institutions to plan ahead when ordering IT equipment.

There’s a combination of factors driving these hardware shortages and delivery delays. With more people working from home, there’s an increased need for hardware, and the rise in demand for electronic devices has placed an extra load on the semiconductor industry. Semiconductors, commonly referred to as computer chips or chips, are a core element in almost everything electronic. The semiconductor market is also consolidated with only three manufactures who can produce the most advanced chips. These factors account for some of the reasons why chips are becoming scarce during a time of heightened demand. Currently, semiconductor lead times are stretching to more than 20 weeks—almost three times the pre-pandemic norm, according to Bloomberg.

Another key factor in hardware shortages is the just-in-time production (JIT) model that many companies, including those that manufacture chips, use to turn out small batches of products instead of creating huge inventories. While this lowers their production costs, it can cause supply chain problems when there’s a rapid surge in demand. Employee shortages worsened by the pandemic have only helped to strain hardware supply chain output even further.

If you’re planning to make upgrades or replace any end-of-life (EOL) equipment, you should order it now to help ensure your institution gets what it needs in time. Another issue is not about ordering the hardware; it’s about having time to properly execute the implementation. For instance, if you need new servers, routers, or phone systems, you need ample lead time to design the project, sufficient time for deployment, and additional time to ensure everything works properly post-implementation. Thinking ahead will make the hardware acquisition and implementation much easier to manage in the long run.

Potential Impact of Not Planning Ahead

Lack of effective planning for hardware purchases could result in serious complications. For instance, if you need a new phone system, you might not be able to secure phones, switches, and routers in time for your scheduled implementation. The delivery delay could be several months which not only impacts deployment but also results in a disruption to your current business functions.

In addition, a delay in installing new equipment could lead to security problems. Often, the new version of software will not install on old hardware, which could leave your institution using obsolete software that doesn’t get the appropriate patches and updates. So, actively researching any EOL issues that could lead to this problem is critical, (Incidentally, Microsoft Server 2012 is coming up on its EOL.)

Keeping hardware and software properly updated is also a matter of regulatory compliance for financial institutions. Management should implement policies, standards, and procedures to identify assets and their EOL time frames to track assets’ EOLs and to replace, or upgrade, the asset, according to the FFIEC Examination Handbook’s Architecture, Infrastructure, and Operations booklet. The guidance states, “Failure to maintain effective identification, tracking, and replacement processes could have operational or security implications (e.g., unavailable or unapplied security updates [patches] that make technology vulnerable to disruption).”

The bottom line is: If you need any IT equipment, it could be months before it’s available. So, plan your project accordingly and order the hardware as soon as possible to ensure the success of your implementation timeline. If you need assistance with researching lead times on hardware such as servers, routers, firewalls, network switches, and more or would like support with EOL products and planning for what is ahead, Safe Systems has experts on hand to help.

18 Aug 2021
How Banks and Credit Unions Are Responding to Emerging Cybersecurity Threats

How Banks and Credit Unions Are Responding to Emerging Cybersecurity Threats

How Banks and Credit Unions Are Responding to Emerging Cybersecurity Threats

Cybercriminals are always looking for new ways to bypass defense measures and exploit emerging weaknesses. Today, financial institutions are fending off security threats that are more ubiquitous, complex, and costly.

As more employees than ever before engage in remote work and online collaboration, this presents a host of potential security gaps. Unsecured home Wi-Fi networks, remote servers, mobile devices, a lack of encryption, and inadequate intrusion detection software are just a few of the factors that contribute to a spike in cyber attacks.

From an internal operations standpoint, it’s equally as important for financial institutions to secure data from basic human error, as 85 percent of data breaches involve a human element, according to the Verizon 2021 Data Breach Investigations Report. Employee awareness training can be the first (and best) defense against emerging cybersecurity threats like business email compromise which is designed to trick people into processing a payment or sharing valuable information.

Leveraging the Latest Technology

Next-generation firewalls (NGFWs) and cloud platforms can also support organizations’ efforts to combat cybersecurity threats. NGFWs offer advanced features that make risk easier to detect, manage and eliminate. SSL/TLS inspection can ensure that encrypted traffic is safe to transmit over the firewall. In addition, threat feeds can help firewalls effectively analyze traffic and route potentially dangerous traffic to a virtual “sandbox,” where it can be processed securely. Automated log analysis is then used to enhance the difficult job of managing voluminous logs and resolving security issues. To learn more about how these advanced features work, listen to our recorded webinar, “Firewall Chat: A Panel Discussion on the Technical Advances in Firewalls”.

Cloud computing is also providing benefits to financial institutions to enhance their security resources. While cloud technology is nothing new, innovations from major platforms like Microsoft, Amazon and Google offer enticing advantages to moving data and business processes into the cloud. But it’s important to keep in mind that employing cloud services requires institutions to use different security practices in order to minimize data breaches and other cyber threats.

Growing Need for Insurance and Expertise

As another developing trend, more companies are adding cyber insurance to their security toolbox. A cyber insurance policy can be an effective way to mitigate risk related to financial losses from cyber attacks. But with more cybercrime happening, organizations can expect to see higher premiums, decreased limits, and changes in exclusions for certain losses.

As cybersecurity threats become more frequent, sophisticated and expensive, financial institutions need to apply more vigilance and expertise to keep hackers at bay. Safe Systems can help ensure that community banks and credit unions have the technical resources they need to effectively address the latest security issues. Managed Perimeter Defense (MPD) offers a combination of professional IT solutions, including device monitoring and management, sandbox analysis, dynamic threat feed analysis, and SSL/TLS inspection.

09 Aug 2021
Third-Party Solution Makes It Easy for Community Bank to Enhance InfoSec Program

Third-Party Solution Makes It Easy for Community Bank to Enhance InfoSec Program

Third-Party Solution Makes It Easy for Community Bank to Enhance InfoSec Program

Implementing a technology-enhanced information security program doesn’t have to be a daunting task. Working with a third-party expert can make the process easier and smoother than managing all the requirements completely in house.

Effective information security (InfoSec) allows organizations to safeguard key IT assets, business processes and data from potential threats. It involves the broad measures that ensure the confidentiality, integrity and availability of the information being processed and stored by computer systems. Most financial institutions, especially those with limited IT resources, can benefit from having an outside vendor provide additional technical expertise and solutions to enhance their existing InfoSec program.

First State Bank Improves InfoSec with Safe Systems

First State Bank of Blakely, Ga. is a prime example of how a financial institution was able to tap external resources to expand its InfoSec program. The bank, which has about 100 employees and 10 branches, was handling most of its InfoSec requirements in house. But when First State Bank’s InfoSec consultant retired, the bank opted to expand its vendor management relationship with Safe Systems to include information security.

Safe Systems made the implementation quick and easy, recommending strategic tweaks that significantly streamlined the process. Consequently, First State Bank was able to avoid “reinventing the wheel” by importing some of its existing information. And since the program elements are web-based and accessible through any internet browser, it will be easy for the bank to make future edits.

First State Bank’s IT Manager, William Barnes, specifically references Safe Systems’ expertise, saying: “The knowledge and experience of the experts I worked with during implementation were very helpful. It is good to know they are there to consult with. I think overall, we are in a good place with the new information security program.”

In addition, the program provides an easy-to-follow guide for securing the First State Bank’s operations and processes. The program is reviewed at least annually, which serves as a reminder of important security requirements. “It helps us stay on top of the risks within the bank and has all the available forms that we need for most policies and procedures,” Barnes says.

Benefits of Technology-Enabled InfoSec

Having a technology-enabled InfoSec program offers a host of benefits for institutions like First State Bank. In general, an automated security program can help banks better support the hardware, software, policies, procedures, and information assets needed to accomplish their business objectives. More specifically, incorporating technology can simplify an InfoSec program; it can streamline the process of identifying and classifying the vast number of assets institutions often have scattered across multiple branches and geographic locations. And a built-in risk assessment tool can provide pre-determined default risks for different assets based on commonly known threats and vulnerabilities.

All of this can reduce the need to create huge spreadsheets to maintain the amount of data typically required for an InfoSec program. As a result, financial institutions can have more accurate security-related information, enhanced board reporting, and better decision making and governance.

Consulting with a trusted vendor like Safe Systems allows institutions to immediately expand their information security expertise and resources. Safe Systems includes three applications in their service including Risk Assessment, Policy Manager, and Enterprise Modeling, to help banks and credit unions centralize and automate their InfoSec program. These powerful applications can make it easier for institutions to enhance their processes for assessments, notifications, reporting, policy/procedure updates and regulatory compliance so they can optimize their security posture.

04 Aug 2021
Technical Advances in Firewalls and How FIs Can Make The Most of Them

Technical Advances in Firewalls and How FIs Can Make The Most of Them

Technical Advances in Firewalls and How FIs Can Make The Most of Them

Firewalls have been a critical first line of defense in network security for decades. Over the years, they have evolved beyond simply filtering traffic between internal and external networks to offering more advanced features. Today banks and credit unions can capitalize on the technical innovations of next-generation firewalls (NGFW) to significantly enhance their network security.

NGFW Features

NGFWs offer a combination of advanced elements that can help financial institutions better manage incoming and outgoing traffic. Encryption is one example and is a key defensive weapon—but it can be a two-edged sword. While encryption is designed to ensure that only the intended audience can see the data being sent, a network’s security system may not be able to properly view, examine, and identify the encrypted traffic.

When a firewall receives encrypted traffic, it has to unscramble it into readable, usable, plain text. Secure Sockets Layer (SSL) and its successor Transport Layer Security (TLS) inspection are required to allow this unscrambling. Without these next-gen inspection features, it is estimated that more than 80% of internet traffic will traverse the firewall uninspected. This means encrypted web traffic can deliver malware to the client without the firewall ever knowing it. Additionally, many advanced firewalls employ “sandboxing,” which ensures suspicious traffic is processed in a secure alternative environment without posing risks to the production network.

Many NGFWs also use what are known as “dynamic” and “static” threat feeds. These lists of potential and current threats enable the firewall to determine whether certain traffic will be passed through or denied. Suspicious traffic gets flagged and remains in the database to support future evaluations.

With threat feeds, a static list is generally used for a small number of IP addresses – in part because it requires more manual labor for maintenance and updating. A dynamic list is typically automated from the cloud, which makes it less user-intensive, easier to keep updated, and more effective than a static list. Geo IP filtering, for example, is just one type of dynamic feed that institutions can use to block certain countries from accessing their outbound or inbound traffic.

Website whitelisting and cross-site hosting are additional tactics for managing and troubleshooting firewalls. Whitelisting allows access to websites that have been blocked by the firewall, and cross-site hosting comes into play when a different but related site is requested.

When it comes to advanced firewall devices, logs and log analysis are especially critical. Logs provide records of every action and event that happens on a network and provide valuable insight into identifying issues that impact performance, compliance, and security. As data logs can surpass millions of lines from just a single 24-hour period, manually analyzing this data is an overwhelming undertaking. With NGFW features such as automated log collection and analysis, institutions can improve data gathering and log management to detect and address potential security problems more effectively.

So which NGFW features are the most important? All of them are important. They’re intended to complement each other and work together toward a common goal: enhancing network security.

There are a few additional, important aspects to consider when implementing a firewall, such as ingress vs. egress rules, cloud services, or content delivery networks, protecting a remote workforce, and ongoing employee training. To learn more about these and all the advanced firewall features, listen to our webinar, “Firewall Chat: A Panel Discussion on the Technical Advances in Firewalls.”

29 Jul 2021
2021 Hot Topics in Compliance

2021 Hot Topics in Compliance: Mid-Year Update

2021 Hot Topics in Compliance

While the COVID-19 pandemic certainly isn’t over, financial institutions have learned valuable lessons so far. In retrospect, the pandemic’s impact on community banks and credit unions hasn’t been as catastrophic as examiners had initially feared—at least not financially. Key impacts have been mostly operational, involving risk related to temporary measures taken to weather the crisis. For instance, examiners will want to know what modifications institutions have made to their operational processes to accommodate an increasingly mobile customer and member base and remote employees, and whether they accounted for additional fraud, cyber threats, or other risks as a consequence. If institutions implemented new products or services, they would need to also account for the operational risk associated with these changes—especially if additional third-party providers were involved. That said, throughout the pandemic, the overall industry demonstrated a very high level of resilience.

In addition to the post-Pandemic lessons, there are other important compliance trends and new regulatory guidance that institutions should anticipate as we approach the rest of the year:

Emphasis on Ransomware Cybersecurity

Recently, 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 ramp up going forward. This will be reflected, in part, by the number of (and types of) assessments that they may expect financial institutions to perform on an annual basis, including the familiar Cybersecurity Assessment Tool (CAT) and newer, non-compulsory Ransomware Self-Assessment Tool (R-SAT) developed partly by the State regulatory bodies.

In addition, at the federal level, the Cybersecurity and Infrastructure Security Agency (CISA) has recently developed its Cyber Security Evaluation Tool. This tool is not specific to the financial industry but rather designed to apply to multiple industries. And the National Credit Union Association (NCUA) decided earlier this year to move away from using its version of the CAT, known as the Automated Cybersecurity Evaluation Toolbox (ACET). It’s now prioritizing a modified InTREx for Credit Unions (InTREx-CU), which is designed to enable credit unions to identify and remediate potential high-risk areas, including within the cybersecurity controls domain.

Changes with Cyber Insurance

Major shifts are also happening with cyber insurance. Because of excessive losses by the insurance industry, there will very likely be increased deductibles, increased exclusions, and decreased limits for covering cyber losses. Cyber insurance coverage—which is not an absolute requirement by regulatory agencies—is going to be more difficult and expensive to obtain. So, the lesson is: As insurance policies come due, don’t automatically renew before you assess what has changed in terms of the coverages, exclusions, and limitations, and make sure you’ve documented your cost-benefit decision.

New Guidance on Architecture, Infrastructure, and Operations

In June, the FFIEC released a new Architecture, Infrastructure, and Operations booklet in its Information Technology Examination Handbook series. The updated guidance, which replaces the “Operations” booklet issued in July 2004, acknowledges the inextricable link between an institution’s operations, architecture, and infrastructure. Or as a recent FFIEC press release states:

“The booklet discusses the interconnectedness among an entity’s assets, processes, and third-party service providers, along with the principles, processes, potential threats, and examination procedures to help examiners assess whether a financial entity’s management adequately addresses risks and complies with applicable laws and regulations.”

The booklet provides a fresh take on several concepts: It recognizes different treatments for smaller or less complex institutions and adopts a different approach to data classification by factoring in value with criticality and sensitivity. All entities—not just credit unions and banks but also non-financial, third-party service providers—are expected to adhere to the guidance.

In addition, there are also pending new rules for incident notifications for banks, service providers, and core providers, which isn’t surprising with all the recent cybersecurity attacks. Finally, examiners are also expecting more detailed board reporting, such as showing how an institution’s business continuity management plan, business strategy, and risk appetite are all aligned.

For more information about the latest expectations, compliance trends, and regulatory guidance, listen to our “2021 Hot Topics in Compliance: Mid-Year Update” webinar.

22 Jul 2021
How Financial Institutions Can Enhance Board Reporting and Governance with Technology

How Financial Institutions Can Enhance Board Reporting and Governance with Technology

How Financial Institutions Can Enhance Board Reporting and Governance with Technology

As financial institutions face greater expectations for corporate accountability from regulators, effective board reporting and governance are becoming even more essential in the banking sector. While board members aren’t generally involved in the day-to-day operations, they are ultimately responsible for the success of their institution. Proper reporting can enable the board to make decisions without having to be involved in routine activities, and technology can help institutions enhance their board reporting and, in the process, help directors exercise the care, skill, and diligence required for good governance.

Five Essential Elements of Reporting

Board members need access to a range of financial and non-financial information relating to their organization’s products and services. In order to function effectively as a feedback tool for the board and senior management, the FFIEC Management Handbook states that information systems reporting should meet five essential elements:

  • Timeliness: To facilitate prompt decision-making, an institution’s information systems should be capable of providing and distributing current information to appropriate management or staff
  • Accuracy: A sound system of automated and manual internal controls should exist to ensure the validity of the information and should include appropriate editing, balancing, and internal control checks
  • Consistency: To be reliable, data should be processed and compiled uniformly. Variations in data collection and reporting methods can distort information and trend analysis
  • Completeness: Reports should contain the necessary information to inform decision-makers without voluminous detail
  • Relevance: Information systems should provide current, applicable, and actionable information

Reporting that contains the essential elements above can provide decision-makers with facts that support and enhance the overall decision-making process and can also “…improve job performance throughout an institution.” At the board and senior management level, information systems reporting provides the data and information to help the board and management make strategic decisions. At other levels, information systems reporting allows management to monitor the institution’s activities and distribute information to staff, customers, and members of management.

Applying Technology

Advances in technology have increased the volume of data and information available to management and directors for planning and decision-making. Converting that data into actionable knowledge is essential for the board to provide a “credible challenge” to management, which involves being actively engaged, asking thoughtful questions, and exercising independent judgment. Integrating technology into their InfoSec efforts, institutions can create a comprehensive system to generate, collect, and analyze data to support a more effective process for board reporting and a more knowledgeable board.

Heather Helms, CFO and Information Security Officer of Mount Vernon Bank, knows firsthand the importance of having an application that supports board reporting. “Before we started our partnership with Safe Systems, we were not up to par with the industry standards of reporting. Since redoing our Information Security Program and moving away from a paper-based model to automated applications, we’ve seen noticeably better results in our board reporting and regulatory updates,” said Helms. “When trying to wear numerous hats within a small community bank and stay on top of a topic so huge in a regulatory world, solutions like Safe Systems’ Information Security Program makes all of the difference.”

There are several advantages to financial institutions using technology solutions to automate and optimize board reporting and governance. The primary advantage is the ability to generate on-demand reporting on all aspects of information security management; from managing projects, to risk assessments (including risk appetite), to managing critical vendors, to mitigating operational risk through business continuity planning. Reporting should allow just enough detail to enable the board to fulfill their responsibilities, but not be so detailed that they struggle to comprehend. Ideally, technology should support high-level reporting, with the ability to “drill down” as necessary. The emphasis should be on quality, not quantity.

Another potential advantage of technology in reporting is the ability to aggregate business intelligence from multiple sources enterprise-wide. This not only gives the board a more complete picture of risk but can also stimulate internal collaboration and deeper insights, giving directors more meaningful information for analysis. The importance of timely, accurate, relevant, complete, and consistent information cannot be overstated, as the success or failure of management is often defined by the decisions they make. As the FDIC states, “The extreme importance of a bank director’s position is clearly emphasized by the fact that bank directors can, in certain instances, be held personally liable.” By having a comprehensive system in place for optimal decision-making, institutions can improve the quality of the information flowing from management to the board, and then from the board to other internal and external stakeholders—helping directors not only improve governance, but also enhance regulatory compliance and possibly even reduce lawsuits, monetary fines, and other negative consequences from inadequate board reporting.

Technology not only optimizes board reporting and decision-making but also makes it easier for directors to access the information they need to perform their due diligence and oversight obligations. It all boils down to implementing technology to exercise better accountability—ensuring sound policies are in place to promote strategic objectives and regulatory compliance.

Safe Systems offers a wide range of compliance-centric, innovative solutions that can help financial institutions take advantage of technology to improve their board reporting and governance.

15 Jul 2021
Cybersecurity Shouldn’t Be Keeping You Up at Night

Cybersecurity Shouldn’t Be Keeping You Up at Night

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.

01 Jul 2021
Benefits of Integrating Technology into Your InfoSec Program

Benefits of Integrating Technology into Your InfoSec Program

Benefits of Integrating Technology into Your InfoSec Program

Information security (InfoSec) is a critical aspect of keeping an organization’s computers, networks, sensitive information, and users safe from potential threats. Integrating technology into a financial institution’s InfoSec program can make it easier to manage risk and protect their information and infrastructure assets. Institutions can utilize automation to capitalize on a variety of other benefits, including:

Simplicity

Banking is a complex business. Banks and credit unions maintain a wide assortment of information technology devices, systems, and applications to support their operations. They also have multiple personnel, partners, and third-party providers spread across different geographic areas. The interconnectivity of their operations can make it even harder for institutions to protect the hundreds (and in some cases, thousands) of assets they must maintain. An automated system can make it easier for institutions to inventory and classify their assets—without having to create enormous, time-consuming spreadsheets. It provides a centralized solution for tracking the criticality, location, and risk exposure level of each asset. Identifying the source of risk is the essential first step to effective risk management. Technology and various Software as a Service (SaaS) applications can greatly simplify the process of inventorying assets, assessing the risk, and selecting controls. Technology can also create automatic updates to ensure that all policies and procedures are current and based on industry standards and regulatory requirements. Additionally, on-demand stakeholder reporting can be generated to provide the requisite documentation to management committees, board of directors, and regulatory authorities, respectively.

Completeness and Transparency

Integrating technology can help financial institutions get a clearer sense of their security posture, so they can develop a more complete InfoSec program. Automation makes it easier to identify and categorize each asset, along with its related risks, threats, and controls. This can enable institutions to make a more accurate assessment of where their security risks actually lie. With enhanced transparency, institutions can determine the most appropriate level of protection for each of their assets. As a result, they can more effectively use, manage, and secure these assets. Proactively identifying risks, threats and controls can also better position them to minimize the impact of security incidents in the future.

Better Intelligence and Insights

Some financial institutions rely on manual spreadsheets to manage the vast amount of information and other assets in their InfoSec program. But manual spreadsheets are not always the most effective tracking and reporting mechanism. People can inadvertently feed the wrong data into spreadsheets and produce unreliable results (“garbage in, garbage out”). Plus, since creating spreadsheets is such a repetitive and time-consuming process, information may be infrequently updated—which can make it less timely and thus less useful. However, integrating technology can help institutions enhance the accuracy of the intelligence that supports their InfoSec program. In turn, their board and management can have better insights into the important issues that impact the information security of their organization, which in turn empowers them to make better decisions.

Enhanced Reporting

To make the best decisions for their institution and perform their fiduciary oversight duties, boards and management committees need accurate, relevant, and timely information. By incorporating technology in their InfoSec program, institutions can put an efficient process in place to generate, collect, and analyze data to support board and committee reporting. This can enhance the overall quality of the information being reported to the board, shareholders, and auditors, and regulators. Optimized, on-demand reporting can improve governance, foster compliance, and potentially reduce negative consequences from inadequate board reporting.

Resource Collaboration and Augmentation

InfoSec resources are limited at many financial institutions, and most community banks and credit unions do not have a dedicated InfoSec specialist in-house. Additionally, information security officers (ISOs) tend to wear multiple hats and are often stretched thin by their broad range of responsibilities. An automated application can create a centralized solution that creates a multi-user approach to allow the ISO to leverage internal resources wherever and whenever possible. For example, a department head or process owner can be a valuable internal resource for assessing vendors impacting the department’s functionality. Similarly, the process owner (and not necessarily the ISO) would be the most logical choice to perform the process Business Impact Analysis. In this way, InfoSec becomes an “all hands on deck” operation, with all personnel sharing ownership of the process. Outsourcing additional aspects of InfoSec via a virtual ISO solution can provide an institution with additional subject matter expertise and solutions to further support their designated ISO and the overall security of their systems and information.

Read more about the benefits of integrating technology into your information security. Download our white paper on “How Financial Institutions Can Use Technology to Build an Automated, FFIEC-compliant Information Security Program.”

24 Jun 2021
Automating Your Information Security Program - How Technology Can Get Policies Off the Shelf

Automating Your Information Security Program: How Technology Can Get Policies Off the Shelf

Automating Your Information Security Program - How Technology Can Get Policies Off the Shelf

Working with paper-based information security policies can be limiting for financial institutions. Automation allows banks and credit unions to take their policies off the shelf and move them online to reap multiple benefits.

There are 2 major challenges to having a static, paper-based information security program; the first is making sure policies accurately reflect the financial industry’s current guidance and best practices, and the second is making sure they accurately reflect your institution’s specific practices. Often new paragraphs and sections get added to cover additional policies while almost nothing gets expunged. Or a revision in one section of the program might not be properly updated in all other related areas.

These twin challenges are the primary cause of disconnects between policies, procedures, and practices —and compliance-related findings from IT auditors and examiners. Today examination auditors are scrutinizing documents far more closely, and they expect to see documentation that proves institutions are doing what their policies say they are. And unfortunately, policy disconnects and lack of adequate documentation in IT often reflect poorly on management. It is not unusual for us to see weaknesses in the IT area pull down the CAMELS management component in other areas. In a study conducted by the OCC earlier this year, researchers found that:

“… both the CAMELS composite and Management component ratings have significant predictive power for features of the distribution of banks’ return on assets (ROA), non-performing loans (NPL), stock returns, stock return volatilities, and market-to-book ratios.”

Advantages of Automation

Leveraging technology for an information security (InfoSec) program offers significant benefits by addressing both challenges. A key advantage is that it places all InfoSec related documents in one place where personnel can easily access them. Having a digitally enhanced program makes it easier to minimize exam findings related to inconsistencies between policies (what you say you’re going to do) and procedures (how you say you’re going to do them). Automation streamlines the process of updating policies and documenting the corresponding procedures that are in place to support them.

As another advantage, automation promotes personnel collaboration and engagement in the information security process. Having a web portal where staff can access the policies and procedures related to their area of focus enables collaboration, encourages engagement, and generally helps generate buy-in. As a result, personnel becomes better informed and more engaged in the information security program.

Automation also supports change management by facilitating periodic, detailed reporting to update various stakeholders about the status of the information security program. Reports can focus on a specific area or be customized for different stakeholders who may need more specialized reporting. They may be high-level summaries, or highly detailed. Most importantly, as regulatory guidance and best practice evolve, automation can allow policy updates to happen with the click of a button.

Our Unique Approach

At Safe Systems, we took a unique and comprehensive approach when creating our new Information Security Program solution. The program includes a comprehensive set of policies and a process-based risk assessment. It’s also structured around the Information Security and Management handbooks by Federal Financial Institution Examination Council (FFIEC). And it features a detailed, easy-to-navigate table of contents that will look familiar to auditors and examiners. The idea is to make it as easy as possible for IT auditors and examiners to find what they’re looking for, so they can move on to other areas!

Another way our approach is unique is that our methodology starts with enterprise modeling: We find out everything about the institution’s departments, processes, functions, and required interdependencies. That data then flows directly into the risk assessment and links to other areas that may be added later, such as business continuity management or vendor management. All of these areas will “talk” to the model to support automatic updating whenever global changes are made.

Positive Feedback

Our Information Security Program—which has been years in the making and incorporates everything we’ve learned about what does and doesn’t work—is effectively simplifying an inherently complex process for institutions of all types and sizes. So far, we’ve heard great feedback from auditors, examiners, and customers. (In fact, the risk assessment was developed in close collaboration with IT auditors.) Customers are finding our information security program much easier to manage than having multiple disjointed policies in Word documents and PDFs strewn across disparate folders. They can access policies without worrying if they have the most current version. And our broad and deep understanding of financial institution risk management allows us to start with a pre-filled set of policies, which are then customized to each institution. This greatly accelerates the onboarding process. Customers also like being able to work one-on-one with our team to build a process-based risk assessment model, being able to customize policy language as needed, and not worrying about what changes to make, or where to make them.

For more details, listen to our webinar on “Automating Your Information Security Program: How Technology Can Get Policies Off The Shelf.”

18 Jun 2021
5 Areas to Outsource so Your IT Administrator Can Go on Vacation

5 Areas to Outsource So Your IT Administrator Can Go on Vacation

5 Areas to Outsource so Your IT Administrator Can Go on Vacation

It’s summertime. And COVID restrictions are finally being lifted. Maybe now your IT administrator can go on vacation—if there’s someone available to fill in.

Third-party IT and security service providers can make it easier for smaller banks and credit unions to manage when staff takes time off. Here are five areas where financial institutions can outsource to maintain adequate IT resources—and peace of mind—while the IT administrator is out of the office enjoying some downtime:

1. Network monitoring for diagnostic or security issues — Monitoring is critical for detecting, diagnosing, and resolving network performance issues. A network monitoring solution can gather real-time information to ensure the system is being effectively managed, controlled, and secured. With proactive monitoring, IT staff can find and fix network issues more quickly and easily. This can help them keep the network operating smoothly, stay ahead of outages, and avoid expensive downtime. It can also help the IT department maintain critical business services and reduce potential security risks for the institution. Outsourcing network monitoring can lighten the workload for time-strapped staff who are probably juggling more tasks while the IT administrator is away.

2. Managed replication and real-time backup to the cloud — Replication tools can automate the process of copying data across multiple sources, relieving the IT department from the burden of monitoring backups on a daily basis. The data gets stored in multiple locations, increasing its redundancy and resiliency. Using cloud-based managed data replication and backup solutions can make it easier for institutions to have the data they need to maintain normal business functions. It also provides another major benefit: No matter where the network admin is, it will be easy to restore data if a hardware failure, power outage, cyberattack, or some other disaster impacts the system.

View the PDF5 Things to Outsource So Your IT Administrator Can Go on Vacation Get a Copy

3. Regulatory and IT reporting — The need for data to confirm controls are in place does not go away when someone leaves or goes on vacation. It is important for management to have access to timely reporting about IT issues to enhance security and meet regulatory compliance. Having a system in place that generates reports in a single location, rather than manually created reports or reports pulled from disparate systems helps ensure data on security controls can be reviewed by anyone anytime. Partnering with a third-party provider that can aggregate reporting and control data can make it easier for institutions to meet these requirements.

4. IT support experts — Financial institutions must have the appropriate IT expertise to stay on top of complex security issues. Outside vendors can provide access to IT specialists who can augment the efforts of their IT team. The added support not only can be a godsend while the system administrator is on vacation, but it can also meet an ongoing need. An institution can use outside experts to provide technical knowledge and resources that may be lacking in the IT department.

5. Cloud-based infrastructure — Virtual servers, storage, software, and other cloud-based solutions offer access to resources on demand. And since cloud infrastructure is flexible and scalable, it is the ideal way to modernize a computer system and build redundancy. Using cloud-based infrastructure allows financial institutions to have duplicate copies of their data and core systems available whenever they’re needed. So, if an IT issue comes up, a third-party service provider can troubleshoot the problem remotely while the IT administrator is on leave.

Safe Systems offers a range of IT and security solutions to help institutions keep their operation and network running efficiently. Learn more about how our compliant solutions can provide professional support whenever your IT administrator takes a much-needed break.

10 Jun 2021
Resource Center

Technology, Compliance, and Security Best Practices – All in One Place

Resource Center

A few years have passed since we launched the Safe Systems online Resource Center, which provides community banks and credit unions access to a centralized knowledge base of materials that help you learn more about technology, compliance, and security best practices.

With a wide variety of content, ranging from videos to white papers to case studies, the Resource Center allows you to stay current with the latest trends and insights in the industry. For example, visit the Resource Center to view our latest webinar, infographic, or a short and timely blog. Come back often, as we add new content every week!

Just in case you missed our Resource Center reveal, or you would like a few more details on what it has to offer, please view the original blog post here.

03 Jun 2021
What CEOs Should Know about Disaster Recovery

What CEOs Should Know about Disaster Recovery

What CEOs Should Know about Disaster Recovery

Disaster recovery—the process of restoring IT infrastructure, data and systems in the aftermath of a major negative event—is a specialized area of technology that’s not always top of mind for executives. CEOs must ensure their organization is equipped to quickly resume mission-critical functions following a calamity.

Here are some key considerations that bank CEOs should keep in mind to make sure their financial institution has a feasible approach to disaster recovery.

Expect the Unexpected

A disaster can happen anytime—and in any form. While people typically think of disasters as being natural occurrences, manmade catastrophes such as power outages, equipment failures, cyber attacks, and network downtime due to human error are equally common causes of disruption. Regardless of the source, the need for DR is truly a matter of when—not if. So, CEOs should get comfortable with the uncomfortable idea that some type of disaster will eventually impact their institution.

Be Proactive

DR planning is the key to both preventing disasters, and when they do eventually occur, successfully recovering from a natural or manmade calamity. Not having a sufficient plan in place can hit an institution where it hurts most: a loss of data, business functions, clients and reputation—not to mention time and money. Therefore, bank CEOs must ensure their management team is taking proactive steps to adopt effective DR strategies. This includes implementing—and testing—a plan for getting operations back to normal with minimum interruption.

Besides the practical need for DR planning, the Federal Financial Institutions Examination Council (FFIEC) advocates taking a preemptive approach to this often overlooked area of technology. The FFIEC IT Handbook’s Business Continuity Management booklet advises: “Management should identify key business processes and activities to be maintained while IT systems and applications are unavailable and prioritize the order in which these systems are restored, which should be reflected in the BIA. In addition, management should develop a coordinated strategy for the recovery of data centers, networks, servers, storage, service monitoring, user support, and related software.”

The business impact analysis (BIA) is one tool that bank management can use to ensure their financial institution is adequately preparing for DR. This important mechanism predetermines and prioritizes the potential impact disruptive events will have on business functions. Essentially, the BIA can show gaps in critical processes that would impede disaster recovery and, in turn, the institution’s business continuity.

Consider Outsourcing DR

The intricacies of disaster recovery planning can be daunting, which is why many organizations fail to create a viable DR plan. More than one-third of small and medium-sized businesses do not have a plan in place for responding to data breaches and cyber attacks, according to the Ponemon Institute’s 2019 Global State of Cybersecurity in Small and Medium-Sized Businesses report. However, bank management can leverage external resources to expand their institution’s disaster recovery capabilities. Outside vendors can provide new technologies that reduce risk and enhance data backup, storage and recovery. They offer a variety of cloud-based solutions that can make the DR process more streamlined, efficient and cost-effective. Outsourcing DR can be especially advantageous to smaller banks that may lack this type of specialized knowledge in house. It can also benefit larger institutions that want the comfort of having third-party services available to support their resident DR specialists.

CEOs have a lot on their plates but paying attention to these important DR issues can help ensure both operational resilience during a disaster as well as regulatory compliance. To learn more about how Safe Systems helps financial institutions and their CEOs develop well designed, compliant DR plans, explore our Managed Site Recovery solution.

27 May 2021
Kids on Banking – 3 Years Later…

Kids on Banking – 3 Years Later…

 

Kids on Banking – 3 Years Later…

It’s been almost 3 years since our 25th anniversary, and thus, the introduction of our Kids on Banking project. Designed to give us a refreshing perspective on banking from the minds of children, Kids on Banking offers a little comedic relief in stressful times. Who knew banking concepts could be so fun?!

While we are so grateful to have spent the last 28 years serving more than 600 financial institutions and managing more than 20,000 network devices, we are even more excited to see what the next 28+ have in store.

In case you missed our original Kids on Banking reveal, view the blog (and adorable video!) here.

13 May 2021
Is Your Financial Institution BCM Compliant?

Is Your Financial Institution BCM Compliant?

Is Your Financial Institution BCM Compliant?

It’s been a few years since the FFIEC updated its BCM IT Examination Handbook and expanded its focus from “business continuity planning (BCP)” to “business continuity management (BCM).” While most financial institutions should already be aware of the updates to the handbook, it’s always beneficial for banks and credit unions to refresh their plan to remain up to date and compliant when it relates to business continuity.

In a recent post, Safe System’s compliance expert, Tom Hinkel, discusses five key points to keep in mind when evaluating your Business Continuity Management plan:

  • Resilience
  • Entities vs. Institutions
  • MAD vs. MTD
  • Exercises and Tests
  • Guidance vs. Requirements

In case you missed the full blog, view it here

06 May 2021
After the Disaster: Real Community Banking Recovery Stories

After the Disaster: Real Community Banking Recovery Stories

After the Disaster: Real Community Banking Recovery Stories

Even the best-laid plans can go awry—especially after a disaster. Our real-life stories from actual community financial institutions underscore the importance of having an effective disaster recovery (DR) process in place.

It’s obvious that a disaster can strike anywhere and anytime. What’s less obvious is that a natural disaster doesn’t have to happen for a financial institution to implement its DR plan. For instance, a server room and all the equipment inside could become damaged by a fire or flood. A power outage or loss of a communications line could take out an institution’s phones, email, and internet. This could be devastating because communication is such an integral function of a financial institution.

Not knowing how long a power outage will last can further complicate the issue. If the outage stretches over a few hours or days, the institution should be thinking about implementing its DR process. But making that call can be difficult. That’s where having an outside team of DR experts available can be helpful. For example, we can help institutions quickly leverage Microsoft Azure for cloud site recovery. We can also assist with ongoing monitoring, maintenance, and testing to ensure the viability of their DR plan.

Real DR Stories from Community Banks

For example, a tornado struck one of our community bank clients and severely damaged its main office. The branch was rendered completely inoperable, unable to serve customers or employees. Fortunately, the critical servers that were housed in the building were not destroyed, and we were able to relocate them to a different branch location. The bank operated the servers from that site for a year while the main office was being rebuilt. Ultimately, we returned the servers to their original location and made the necessary reconfigurations to get everything functioning again. Moving the severs to a different place allowed the bank to avoid failback, which can be the most complicated aspect of the disaster recovery process.

Another DR scenario involves a financial institution on the South Carolina coast, where hurricanes frequently make landfall. In this case, a hurricane demolished the main office and completely flooded the location. As a result, the institution lost its servers, internet connection, and ability to communicate. The bank’s DR strategy relied on using 4G to restore internet connectivity, but the cell towers were down. Thankfully, the network had an old telecommunication circuit that we were able to get turned on and operational. So, after we dealt with the communication curveball, we were able to get the network—and bank—up and running again.

Community Bank in Alaska Shares Insights

It’s often the physical environment that determines the disasters that an institution may encounter. Potential hazards for Fairbanks, Alaska-based Denali State Bank include flooding from nearby rivers, jolting earthquakes, and volcanic eruptions on the Aleutian Chain. Therefore, Denali State Bank—which has $380 million in assets and 150 endpoints across five branches—focuses on ensuring that it has critical IT staff and services available during a disaster.

As part of its DR solution, the bank maintains a designated alternate site—one of its branches—that sits on a separate portion of the power grid. Denali also uses cloud-based Microsoft Azure, which makes it easy to run and test critical functions. During testing, the bank can shut down all connections to its main office (including large SQL servers), quickly spin up everything virtually through Azure, and establish connectivity through a Safe Systems co-location facility. This helps to ensure that vital functions will work properly to support the institution after a disaster.

Get more community banking DR insights. Listen to our webinar on “After a Disaster: Real Community Banking Recovery Stories” to make sure your institution is better prepared for an unexpected negative event.

29 Apr 2021
The 4 “Rs” of Disaster Recovery

The 4 “Rs” of Disaster Recovery

The 4 “Rs” of Disaster Recovery

Organizations can be impacted by a natural or manmade disaster at any time. Having an effective approach to disaster recovery (DR) can help banks and credit unions meet their regulatory obligations, better protect themselves from the impact of a significant negative event and enhance their ability to bounce back and continue operating in the aftermath of a disaster.

There are four “R’s” when it comes to disaster recovery that every financial institution should focus on: Recovery Time Objective (RTO); Recovery Point Objective (RPO); Replication; and Recurring Testing. Here’s why each of them is integral to DR:

RTO

RTO, the longest acceptable length of time that a computer, system, network, or application can be down after a disaster happens, is a crucial facet of DR. Established RTOs essentially represent trade-offs, with shorter RTOs requiring more resources and ongoing expenses. When setting RTOs, prioritizations must be made based on the significance of the business function and budgetary constraints. Ideally, financial institutions will have RTOs predetermined before a disaster strikes, and the RTOs will be included in the institution’s Business Impact Analysis (BIA) as part of the business continuity planning process. Following a disaster, the recovery process will depend on the type of institution, technology solutions, and business functions as well as the amount of data involved. Institutions with an outside vendor guiding their disaster relief efforts typically have a more streamlined and less stressful recovery process.

RPO

The RPO represents the amount of time between a disaster occurring and a financial institution’s most recent backup. If too long, and too much data is allowed to be lost, it could result in substantial damage. Essentially, the RPO will be determined by the institution’s technology solution and risk tolerance. The Information Security Officer (ISO) and management must define exactly how long they are willing to go without having a copy of their data available. As banks and credit unions become more dependent on technology, however, their tolerance for not having critical functions available shrinks. Increasingly, financial institutions are turning to outside vendors to bolster their recovery solutions, but they must ensure that those third-party providers are adequately equipped to satisfy their RPO requirements.

Replication

Effective DR replication is essential because it allows an exact copy of an institution’s data to be available and remotely accessible when an adverse event happens. DR requires the duplication of data and computer processing to take place in a location not impacted by the disaster. The best practice is to have one backup onsite and another offsite in a different geographic region—somewhere that is not likely to be affected by the same disaster. Options for recovery can take various forms: fully redundant systems at alternate sites; cloud-based recovery solutions (either internally developed or outsourced); another data center; or a third-party service provider; according to the Federal Financial Institution Examination Council (FFIEC).

Recurring Testing

Recurring testing allows banks and credit unions to pinpoint key aspects of their DR strategy and adjust as needed to accomplish their objectives. Thorough testing of a financial institution’s core applications should be done annually — while they are functioning normally — to generate the most meaningful feedback. The institution should employ a variety of tests and exercises to verify its ability to quickly resume vital business operations in a disaster situation. Regular testing can reveal possible problems in the institution’s DR plan so that it can immediately address these issues. The aim is not necessarily to pass each test or exercise, but rather to find and fix flaws before a disaster occurs.

Read more about how your bank or credit union can be better positioned to recover from a disaster. Download our “4 Rs of Disaster Recovery” white paper.

22 Apr 2021
Why a Comprehensive Disaster Recovery Service is Critical to Any Financial Institution’s BCM

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

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.

15 Apr 2021
Latest Microsoft Updates Show Importance of Patch Testing

Latest Microsoft Updates Show Importance of Patch Testing

Latest Microsoft Updates Show Importance of Patch Testing

In early March 2021, Microsoft published some cumulative updates for different versions of Windows 10, including KB5000802. Unfortunately, the new updates and patches caused a variety of problems, including workstation crashes when printing, problems opening emails in Outlook, and some vendor products, such as Fiserv’s Navigator, not displaying correctly.

As a result, many people could not use printers from several popular brands such as Kyocera and Ricoh, and the new patches caused some users to experience the dreaded “Blue Screen of Death” (BSoD) when they clicked on the “print” option in some apps. Ultimately, Microsoft addressed the issue and rolled out a fix for the printer problems.

Importance of Patch Testing

The problems associated with Windows 10 KB5000802 serve as effective real-world reminders of the importance of patch testing as these issues could have been avoided by implementing proper testing procedures. Vendors are constantly releasing patches to correct software problems, improve performance and enhance security. But as the recent Microsoft incident clearly shows, patches can sometimes trigger new problems while trying to address existing ones.

All of this demonstrates why it is so important for banks and credit unions to test patches before installing them. Ideally, financial institutions should create a test group of the different kinds of machines and applications used in their environment and then apply any newly released patches to the elements in the group. Besides being a pragmatic approach, utilizing a test group also adheres to guidelines of the Federal Financial Institutions Examination Council (FFIEC), and it helps effectively protect institutions from downtime, security breaches, and IT issues.

Value of a Third-Party with Financial Industry Expertise Managing Patches

The problems surrounding the latest Microsoft patch also illustrate the value that a qualified third-party IT expert like Safe Systems can bring to community banks and credit unions. Through our meticulous testing process, which includes more than 2,000 machines running a wide variety of banking and lending applications, Safe Systems was able to identify both general PC issues and banking application issues related to the patch. This regimented testing process, which follows FFIEC guidance, enabled Safe Systems to minimize the impact on more than 25,000 financial institution devices. As a result, clients were able to avoid major hassles and headaches with a vast majority of their devices.

Safe Systems issued an official notification about the situation, spelling out the specific problem, impact, resolution, and action required for customers and eliminated the patch from the environments of clients that were having trouble. Customers using NetComply One to manage patches didn’t need to take any additional action—unless they still had problems after the patch was removed. For clients with lingering complications, Safe Systems’ fully staffed Network Operation Center (NOC) was available to resolve their issues quickly.

Safe Systems’ proactive actions to neutralize possible issues relating to the patch is a prime example of the benefit of our NetComply One solution. Part “product” and part “service,” NetComply One is a comprehensive patch management solution that offers quarterly advisement from Safe Systems experts. It provides valuable reporting and insight into potential issues to help community banks and credit unions pass audits and exams. To learn more about how NetComply One can help your financial institution, click here.

08 Apr 2021
Why Security Solutions Fail and What Your Financial Institution Can Do to Stay Safe Featured Blog Image_Header Image

Proven Security Solutions to Keep Your Financial Institution Safe from Cybersecurity Threats

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

Like many other professional industries, the financial sector of business was forced to work from home due to the COVID-19 pandemic. With an unprecedented number of employees still working remotely, now more than ever financial institutions are susceptible to a cyberattack. The increased threat of a security compromise has prompted financial institutions and other organizations across the country to increase their cybersecurity posture to help prevent a future attack.

In a recent post, Safe System’s guest blogger, Keith Haskett, president and CEO of Rebyc Security, discusses 5 reasons security solutions fail, such as lack of multi-factor authentication or improperly configured spam filtering and what you can do to keep your institution safe. In case you missed the full blog, view it here.

02 Apr 2021
Is Cybersecurity Your Weakest Link

Is Cybersecurity Your Weakest Link?

Is Cybersecurity Your Weakest Link

Is Cybersecurity Your Weakest Link?

The financial landscape has changed drastically in the last 20 years, one of the most notable changes being the variety of financial services now being offered online. Although the wide-spread use of internet has made it possible to receive financial guidance from anywhere in the world, it has also created an environment where sensitive information and data could potentially be compromised by cybercriminals.

Today, professional hackers are spending more time and money than ever before to gain access to personal information for both monetary gain and “professional” recognition. The sensitive information that the financial services industry has access to continues to make them a prime target for hackers and other cybercriminals. Attacks can range from malware threats, DDOS attacks, phishing attempts and data breaches – all of which bad actors can use to commit fraud themselves or sell to a third-party.

Importance of Being Secure

 

Cybercrime continues to be a growing problem for banks and credit unions across the country. The impact of a cybercrime can be very costly for a financial institution, both financially and from a reputational standpoint. The main risks include theft or unauthorized access to sensitive customer information along with the disruption of normal business operations.

In addition, as the number of security threats continues to increase in the financial services industry, regulators are taking a closer look at financial institutions’ policies and procedures to ensure that they can effectively safeguard confidential and non-public information. As an example, the Federal Financial Institutions Examination Council’s (FFIEC) Cybersecurity Assessment Tool (CAT) is designed to ensure financial institutions are prepared in the event of a cybersecurity attack. The FFIEC CAT is now the guide regulators are using to examine institutions and determine their level of cybersecurity preparedness.

Some of the most common security threats financial institutions face today include:

Malware and Ransomware

 

Ransomware has established itself as one of the leading cyber threats for many organizations, but especially financial institutions. Using ransomware technologies, hackers can gain complete access and control over legitimate websites, often by encrypting data or programs, and extort ransom payments from victims in exchange for restoring access to the individual or business. Malicious software, or “malware”, is no longer characterized by simple aggravating popups and sluggish computer performance, but rather the encryption of all data on a machine, rendering it unusable.

Internet of Things (IoT) Attacks

 

Unsecured Internet of Things (IoT) devices such as DVRs, home routers, printers and IP cameras are vulnerable to attack since they are not required to have the same level of security as computers. To breach a financial institution, attackers will target insecure devices to create a pathway to other systems. Unsecure IoT devices are also used to launch distributed denial-of-service attacks (DDoS) against institutions. These DDoS attacks prevent legitimate users from accessing computer systems, devices or other online resources. The perpetrator floods the victim’s machine or network with false requests from various sources to overload the system and prevent legitimate access. A well-executed attack can interrupt a host of banking services including website access, ATM networks, and online banking platforms, in addition to internal systems and functions.

Phishing Scams

 

Phishing scams that specifically target financial institutions’ employees, attempting to obtain sensitive information such as usernames and passwords, have become increasingly common within the last few years. The goal of phishing is to direct employees to a fraudulent website where they are asked to share login credentials and other personal information. The information that employees are tricked into providing then allow for cybercriminals to read a bank or credit union’s critical information, hack into the employee’s bank and social media accounts, send emails on an employees’ behalf, and gain access to internal documents and customer financial information.

Lack of Third-Party Vendor Security

 

While a financial institution might have the right security systems and policies in place to protect itself and its customers from a cyber-attack, its third-party providers may not have the same level of security and diligence. This creates a major vulnerability for the financial institution. Without a proactive approach to vendor management, financial institutions are opening themselves up to increased levels of risk that can have a negative impact on the institution’s financial standing, compliance posture and overall ability to serve its customers. Federal regulators have issued guidelines to help institutions better understand and manage the risks associated with outsourcing a bank activity to a service provider. The FFIEC IT Examination Handbook was revised to help guide banks to properly establish and maintain effective vendor and third-party management programs.

Insider Threats

 

Often, all it takes is a disgruntled employee or ex-employee to release valuable security information and compromise system and data security. Additionally, cybercriminals are increasingly realizing success through bribery as a means to entice bank employees to give up their login credentials or other security information, allowing direct access to internal systems.

Lack of Employee Training and Security Expertise

 

The COVID-19 pandemic has certainly brought its share of challenges to the financial sector of business, including increased network vulnerability and internal threats as employees transitioned to a remote work environment. These changes required cybersecurity personnel to change their online security baseline and continuously adapt to the changing IT security landscape. With the increased popularity of remote work, company IT staff are encouraging employees to take charge of their own online security through testing and training. The training includes topics like the importance of password security and multi-factor authentication and helps employees understand their roles and responsibilities in protecting against security threats. Until this learning gap is resolved, financial institutions will continue to struggle to efficiently manage cybersecurity threats.

Combating Security Threats and Ensuring Institution Security

 

While cybersecurity has become a major point of discussion among professionals within the financial industry, the truth is that many financial institutions are too complacent when it comes to protecting themselves. With hackers using advanced technology, the “bare minimum protection” is no longer enough to keep sensitive information safe. To adequately protect against security threats, financial institutions must ensure that every device on the network has up-to-date antivirus software, adequate firewall protections and that all patches are up-to-date as a minimum requirement. In addition, financial institutions should also employ a layered security strategy, from the end-user to the internet to establish a secure IT environment. Adding preventive, detective and responsive layers to IT security strategy will help strengthen an institution’s approach and build an effective security foundation.

A uniquely tailored layered security approach enables financial institutions to:

  • Monitor antivirus for servers, workstations, and off-site laptops
  • Use services that evaluate site lookups to avoid exposure to compromised websites
  • Scan the network for vulnerabilities and detect unusual activity against hackers and rogue employees
  • Block access to all external ports while also monitoring the access of various machines
  • Meet government regulations and requirements
  • Counter extortion threats by preventing a hacker from holding your customer’s personal data for ransom with special customized software for stopping ransomware
  • Patch machines, encrypt laptops, and install alerts on new devices plugged into the network

The security landscape is constantly evolving, and it is imperative to have a solid security plan in place that accounts for this evolution. It should be a fluid document that is frequently reviewed, updated and that specifically outlines administrative, technical, and physical controls that mitigate evolving risks. It is also important to test the full plan on a regular basis to ensure all procedures can be executed successfully and verify that all regulatory requirements are met.

Managing Security Needs

 

Many community banks and credit unions find that managing the security needs of their organization can be a time-consuming and challenging task. To help augment the security responsibilities, these institutions are turning to financial industry-specific IT and security service providers to act as an extension of their organization, provide timely support, and help the financial institution successfully design and execute a comprehensive security strategy. The right solution provider couples security measures with an understanding of and support for the unique security and compliance demands of the financial industry.

At Safe Systems, we believe that proactively protecting customer data will always be more cost effective than falling victim to malicious activity. To that end, we have the unique expertise to ensure that financial institutions employ the right combination of both broad and specific security products to create an ecosystem of protection. Safe Systems helps secure an organization’s endpoints, devices, and users by assessing vulnerabilities, detecting unwanted network activity, safeguarding against data loss, and preventing known threats while staying ahead of developing ones.