2020 Archives - Safe Systems

16 Jun 2022

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

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

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

Planning for Safety, Soundness, and Resiliency

With the rise in cybercrimes and increased regulatory scrutiny, having a board-approved IT Strategic Plan 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.”

08 Apr 2021

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

Banks, Credit Unions, Security Safe Systems 0 comment

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.

11 Feb 2021

Banks, Credit Unions, Security Jordan Hendrix 0 comment

Using Advanced Firewall Features and Other Technologies to Strengthen Network Security

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

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

Antimalware Scanning

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

Dynamic Threat Feeds

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

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

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

TLS/SSL Inspection

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

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

Sandboxing

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

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

31 Dec 2020

Banks, Credit Unions, Security Jamie Davis 0 comment

The Importance of a Layered Approach to Financial Institution Security: Best Practices in Leveraging Firewalls and Encryption

What You Need to Know About Securing Azure AD

Over the last decade, we have seen major advances in the world of online security, mainly with the development of firewalls and encrypted data options.

Safe Systems hosted a live webinar earlier this month discussing how firewalls, encryption and other online security measures work; why a layered security approach is best in all situations; possible threats to each security measure; and what your financial institution can do to keep your information secure and uncompromised. In case you missed it, here are a few key points from the webinar.

What are firewalls and how did we get to where we are today?

Firewalls became a necessity when banks and credit unions started connecting all of their computers to the same network that was then connected to the internet. Firewalls functioned as the first line of defense – but were nowhere near the caliber of defense we have available today.

When attacks started to occur, it put company computers and the data stored on them in a compromised position. A need arose to come up with appliances that were either in line with the firewall or were an additive to the firewall’s system. The new appliances included IDS/IPS systems, AV Gateways and Web filters – all of which added new layers of security to the firewall.

Today, the latest generation of firewalls, known as Next Generation Firewalls, combines earlier firewall models and offers multiple layers of protection as part of the firewall service. However, some of the additional layers may be included by default and some require extra licensing to take advantage of specific features.

What is the layered security approach and how do today’s firewalls implement that strategy?

What we have learned over the last several years is that security solutions may be incredibly strong in some regards but have gaping holes in others. A layered security approach assists in closing those gaps and lessens the potential risks for an online attack.

What is encryption, how does it work and what can we do better?

Encryption is another aspect of the layered security approach. The two encryption types highlighted in the webinar are Secure Socket Layer (SSL) and Transport Layer Security (TLS), and while they use different nomenclature, the two encryption types are essentially the same – TLS is just a slightly new version.

The goals of TLS:

Encrypt Data
Authentication
Data Integrity

In the last 5 years, there has been major growth in website encryption. It has expanded from being used only when a user types in their username and password to include approximately 90% of the most visited websites today encrypting all of their webpages.

Although having encrypted sites gives users a more secure experience, encryption has some unintended consequences. When traffic is encrypted between the website and the desktop browsing the site, the firewall cannot evaluate the traversing traffic. This means, in the past, a firewall could evaluate a large majority of web traffic. Now, the firewall can only evaluate about 10% of web traffic, because the rest is encrypted.

Bad actors have focused on these security holes and have built their malware to navigate encrypted traffic to get through the firewall and to the workstation. To fight this issue, TLS inspection can be implemented on a Next Generation Firewall to inspect the encrypted traffic passing through on a daily basis.

Today, with TLS inspection, firewalls can get back to inspecting a majority of web traffic farther than just 10% that isn’t encrypted today. This closes a major security gap many institutions may not even know they have.

What steps can you take to increase your online security?

Although there are several ways you can increase your level of online security, as of now, there is no software that guarantees you will not be compromised. However, in addition to encryption, you can take several steps to keep your online presence safe and secure.

A few of the steps you can take to fight malware are:

Anti-Malware Scanning – an anti-virus engine that came about in the Universal Threat Management (UTM) devices. Anti-malware is a software program designed to prevent, detect and remove malicious software on IT systems.
Sandbox Analysis Piece – an additive that enables a firewall to analyze a file and determine its risks level. If the file is determined to possibly be malicious, the file can be sent to the sandbox where the file can be detonated. If the file appears malicious after detonation, the file is blocked from being downloaded to the end user. If the sandbox determines the file is likely safe, the file is allowed to pass through the firewall to the end user for us.

To learn more ways to protect your institution, watch our recorded webinar, “Why You Shouldn’t Ignore Encryption.”

23 Dec 2020

Banks, Credit Unions, Technology Eric Delgado 0 comment

What You Need to Know About Securing Exchange Online: Connecting to Exchange Online

What You Need to Know About Securing Azure AD

Technical Level: Beginner/Intermediate

Note: Previously, we discussed PowerShell basics. Later in this series, we’ll discuss security concerns.

TL;DR:

In order to properly secure Exchange Online, you need to know how to traverse and manipulate settings with PowerShell. In this guide we cover the installation of the EXOv2 module, using the module to connect to an Exchange Online instance, and running some basic commands.

Exchange Online Security with PowerShell

In this post we are going to pick up where we left off last time. Now that we have the basics of PowerShell under our belt, we can go ahead and install the newer ExO V2 Module and then use that module to connect to an Exchange Online instance. Finally, we will go over a few simple commands just to verify the connection has been established.

Exchange Online V2 Module Installation

If you follow the link above for the EXOv2 Module you will find the installation instructions point you to the PS Gallery page for the module.

Securing Exchange - Code Example

The PS Gallery has a few ways to install the module.

Securing Exchange - Code Example

If your package manager is already set, you can enter the following statement to begin the installation of the module:


Install-Module -Name ExchangeOnlineManagement -RequiredVersion 2.0.3

Note: In this case, -RequiredVersion is a switch parameter (I just call them switches) to indicate the version you are looking to download. You don’t have to specify the version when you run the command.

If you run the command you should see that PowerShell prompts you to confirm the installation. I would show you that with a screen grab, but I was met with an error:

Securing Exchange - Code Example

I decided to include this error because you will inevitably run into errors when trying to run command logic. Being able to troubleshoot based on the error description is pretty much a necessity with PowerShell and thankfully the error messages are mostly useful. In this case, even though I had uninstalled the Exchange Online V2 Module previously, there are some remnants of the module still in place on my system. PowerShell won’t let me override existing commands with commands from a new module, unless I give explicit permission with a switch. In this case, I ran the following command to get the module installed:


Install-Module -Name ExchangeOnlineManagement -RequiredVersion 2.0.3 -AllowClobber

Securing Exchange - Code Example

This time there was no error and I was just brought to the next line. I am kind of a cautious guy, so this lack of feedback is disconcerting. How can we tell if the module was really installed? A valid question to which there is a valid response: the Get-InstalledModule command. You can use the following command to verify the installation:


Get-InstalledModule ExchangeOnlineManagement

Securing Exchange - Code Example

Tips and Tricks

Once you get into using various modules it can be difficult to keep track of all the different module names. Thankfully, the Get-InstalledModule command is pretty versatile. If you know at least part of the module name you can surround it with wildcards (the * symbol) to have PowerShell find any module that contains the text between the wildcards. For example, running the command below will also show us that the Exchange Online Management module is installed:


Get-InstalledModule *Exchange*

Securing Exchange - Code Example

Exchange Online v2 Module – Connecting to Exchange Online

Now that the module has been installed, we can use it to connect to an Exchange Online instance. There are a few different types of connectivity options depending on the type of workflow you are using to connect to Exchange Online. For these examples, the assumption is that you are an administrator for a single instance of Exchange Online. Without delegated rights or service principals to worry about, connecting is straight forward. Use the following code and an account with enough access to connect to Exchange Online:


Connect-ExchangeOnline

Securing Exchange - Code Example

Since the new ExO V2 module supports modern authentication, if your account has MFA enabled, you will be asked to sign in with modern authentication:

Securing Exchange - Code Example

After you successfully authenticate, you will be brought back to a new line:

Securing Exchange - Code Example

Once again this is one of those things you are just going to have to take on good faith that the authentication was successful. If it wasn’t, you will be prompted with an error.

Get Over Here!

In general, there are three basic command archetypes within Exchange Online: Get, Set, and New. Get commands are basically read operations. They get values/properties and are really pretty harmless to run so this is where we will start.

Note: Set commands are all about modifying existing values/properties and New commands are about creating new values/properties. Both have some inherent risk so we will cover them in a future post.

Let’s use our new connection to grab the mailbox objects for all our users. Use the following code to utilize the new v2 cmdlets to gather all mailboxes:


Get-EXOMailbox

Securing Exchange - Code Example

Side bar: I am really impressed with the new cmdlets! They are just so much faster than the old ones and since there is full backward compatibility you don’t have to take my word for it, you can run the old one and the new and see the time difference yourself!

Ready For A PowerShell Picnic?

My number one recommendation for new NOC analysts and administrators unfamiliar with PowerShell is always to fool around with it and the more you work with it, the less intimidating it will be. With that in mind, it is time to reach back to our previous picnic themed post and pull the concepts from that picnic basket and start eating a PowerShell sandwich made from mailbox statistics.

The command to get mailbox statistics using v2 cmdlets is:


Get-EXOMailboxStatistics

Securing Exchange - Code Example

Yea I kind of set you up for failure on that one but I had a good reason I promise! The command failed but the reason why it failed is important and so is the resolution. Both can be found in the red text of the error but to make it a bit easier to read and understand, I have included the important bits parsed here.

The reason for the failure is “Identity is a mandatory value to provide for running Get-ExoMailboxStatistics.” What this means is we tried to run the command, but it has a mandatory switch that must be provided for the command to run properly.

Note: You can find out which switches are required by looking at the documentation for the command either online — honestly, using your favorite search engine and searching for the command to get to the Microsoft documentation page for the command is your best bet for this option — or straight from within PowerShell with the get-help command.


Get-Help Get-EXOMailboxStatistics -Full

The suggested resolution is:

You can specify identity by using either of the following

Any one of the three available parameters: Identity, ExchangeGuid, UserPrincipalName.
ExchangeGuid and DatabaseGuid.

What this means practically speaking is that the command was not intended to be run to gather statistics for all mailboxes in the organization at once. It requires a specific mailbox and then it will gather the statistics for just that one mailbox. That is the intent of the command but I really would not want to type that command a hundred times just to be able to view the statistics for all my users.

The acceptable identity parameters are Identity, ExternalDirectoryObjectId, or UserPrincipalName. All three are properties that are provided in the default set of properties for a mailbox object. In other words, when we run the command to get mailboxes, the objects that are returned have the information we need to be able to run the mailbox statistics command.
You can see this in action with the following code logic:


Get-EXOMailbox | Get-EXOMailboxStatistics

Securing Exchange - Code Example

Bring Home the Leftovers

Ok, seriously I am kind of running out of picnic metaphors so I may have to switch it up in the next post. Lets wrap up this PowerShell picnic by exporting the data for easier consumption. For me, there are two trains of thought here depending on what I plan to do with the data. If the plan is just to view the data, then pipe the results to an export-csv command and you are set.


Get-EXOMailbox | Get-EXOMailboxStatistics | Export-Csv -NoTypeInformation -Path “c:\temp\EXOMailboxStats.csv”

Securing Exchange - Code Example

If you plan to use that data for more PS commands (in the same session), then store it in an object first and then export the data. This way you won’t have to spend time gathering it again.


$exoMailboxStats = Get-EXOMailbox | Get-EXOMailboxStatistics
$exoMailboxStats | Export-Csv -NoTypeInformation -Path "c:\temp\EXOMailboxStats.csv"

Securing Exchange - Code Example

Conclusion

That about sums it up (pun totally intended). In this post we went over installing the new ExO V2 module, using the module to connect to Exchange Online, and then using our new connection with some small scripting logic to gather mailbox statistics.

Get commands really are important because they are what will show you all your current Exchange Online properties. There are so many properties though, so which ones are important to look at??? Join us next time around as we solidify our grasp of the get commands and start to look at security related properties that could help show you if your users have been compromised!

22 Dec 2020

Banks, Credit Unions, Security Brendan McGowan 0 comment

3 Top Security Threats Financial Institutions Must Defend Against

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

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

#1: Cybersecurity

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

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

#2: Information Security

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

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

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

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

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

#3: Ransomware

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

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

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

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

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

10 Dec 2020

Banks, Credit Unions, Security Christine Ray 0 comment

Bank of Wrightsville Enhances Security a Next-Gen Firewall Solution

A firewall is a key defense measure to combat cyber threats and having the right firewall solution can provide financial institutions with top-rate protection to meet regulatory requirements as well as useful security tools to identify, analyze, and thwart malicious activity. But does your current firewall security meet these expectations and prepare your institution to scale and reach its IT strategic goals?

Challenge

Leesa Anderson, Chief Technology Officer at Bank of Wrightsville, wanted to ensure her institution had the right tools in place to ensure network security, meet compliance requirements, and keep banking operations running smoothly. After an IT audit and third-party vulnerability assessment, it was recommended for the bank to update its firewall to include Secure Sockets Layer (SSL) inspection. However, at the time, this feature was not available on the bank’s current firewall solution. The bank knew it needed to find a new firewall product to improve the bank’s security posture and meet regulatory expectations.

“We needed to have SSL inspection set up on our firewall solution, but our provider at the time wasn’t offering this capability,” said Anderson. “We began looking for a solution that met all of the basic requirements for firewall protection but also included more of the next-gen features that could help us be more proactive and stay ahead of the curve with our perimeter security.”

Solution

After attending Safe Systems’ user conference, Anderson decided to take a closer look at Safe Systems’ Managed Perimeter Defense (MPD) next-gen firewall solution. The solution deploys powerful machine learning algorithms, SSL inspection capabilities, advanced reporting, and alerts to help financial institutions detect and combat malicious activity on the network. After careful consideration, Anderson selected and implemented MPD as the bank was looking to enhance its network security and needed new hardware as well.

Managed Perimeter Defense has provided many benefits to Anderson and her team. Read the full case study to learn how this next-gen firewall solution transformed Bank of Wrightsville’s firewall security and improved its compliance posture.

03 Dec 2020

Banks, Credit Unions, Security Jordan Hendrix 0 comment

How to Improve Network Security With Cyber Threat Intelligence Feeds

While industry-specific threat intelligence feeds keep financial institutions up to date on the latest security threats in the banking industry, the sheer amount of information collected can be challenging for community banks and credit unions to process efficiently. In this blog post, we outline three key information-sharing organizations that community banks and credit unions should consider utilizing and offer a few tips to improve cybersecurity processes as well.

Types of Threat Intelligence Feeds

According to the Federal Financial Institution Examination Council’s (FFIEC) Cybersecurity Assessment Tool (CAT), it is important for financial institutions to have processes in place to effectively discover, analyze, and understand cyber threats. Implementing bank-specific threat intelligence feeds provides financial institutions with industry-specific security information needed to meet this requirement. Here are a few of the top threat intelligence feeds:

1. Geo-IP Threat Feed

IP-based geolocation is a mapping of an IP address to the geographic location of an Internet connected computing device. Financial institutions can use IP geolocation data to monitor threats from high-risk locations and use this data to strengthen their cybersecurity posture.

2. FS-ISAC

FS-ISAC is an information sharing organization designed specifically for financial services organizations and financial institutions. The organization leverages its intelligence platform, resiliency resources, and a trusted peer-to-peer network of experts to anticipate, mitigate and respond to cyberthreats.

3. IBM X-Force

IBM X-Force Exchange is a cloud-based threat intelligence platform that allows organizations to consume, share and act on threat intelligence. With this platform, you can quickly research the latest global security threats, collect actionable intelligence, consult with experts and collaborate with peers.

Strengthening Your Cybersecurity Posture

Regulators expect financial institutions to belong to an information sharing organization or utilize a crowdsourced security feed because they believe that if institutions can share threat information they’re seeing in the industry, then other financial institutions of similar size and complexity will know how to deal with new and emerging security threats. However, there are two key issues with this concept:

Financial institutions are receiving large amounts of information and don’t know what to do with it
Financial institutions are consuming threat information but are not sharing security threats they’ve encountered with their peers

For smaller financial institutions with limited resources, engaging with a knowledgeable third-party provider that has a solid methodology in place to analyze all of the data disseminated from threat intelligence feeds and filter the information to identify key threats can be a great benefit to the institution’s cybersecurity efforts. It is equally important for these institutions to share cybersecurity threats or incidents they’ve encountered with information sharing organizations to ensure other financial institutions are informed, strengthening the banking industry as a whole.

For more information on enhancing your cybersecurity posture, view our cybersecurity resources.

01 Dec 2020

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

Why Documentation is an Essential Priority During the COVID-19 Pandemic

While financial institutions have spent the last nine months focused on pandemic response and ensuring critical services remain available to their customers and members, there are other key areas of consideration to ensure their institutions remain compliant and can thrive in the future, including documentation. Unfortunately, few financial institutions are adequately documenting their efforts and new strategies as they are being implemented. Below are three key reasons why they really should.

1. Regulatory Expectations

Examiners will expect to see how financial institutions have handled the pandemic and that all of the lessons learned are reflected in their business continuity management plans (BCMP).

Some key questions regulators may ask regarding pandemic response include:

What have you learned from this event?
What have you done to enhance your pandemic plan based on those lessons learned?
Prior to this event, had you analyzed your business processes and their interdependencies, and prioritized them by recovery time?
Have you identified employees with job duties capable of being performed remotely? If so, did they have secure, reliable, remote access?
If those job duties are highly specialized, or highly critical, did you have alternate personnel identified and pre-trained to step in when needed?

2. Key Lessons Learned

All banks and credit unions must take a different approach to pandemic planning that fits well with their institution’s unique needs. They need to consider all of the challenges they’ve faced throughout the pandemic and apply key lessons learned to enhance their operations, including the importance of cross-training staff, enhancing security measures, succession planning, or improving technology for an employee to work at home. Until the pandemic passes, financial institutions should continue to reference their business continuity plans and document the entire process to create a blueprint for reference if a similar situation arises again in the future.

3. Strategic Planning

According to the FFIEC, an entity’s strategic planning should be developed to address all foreseeable risks, and these risks should cover the potential impact on personnel, processes, technology, facilities, and data. Throughout the pandemic, financial institutions should track what they are doing, how they are doing it, and whether any new procedure should be included in their existing crisis management or response plan.

The key is for institutions’ steering or strategic planning committee to stop periodically and document—or backfill information after the fact (at least a month or a quarter later.) Failing to document this process will result in institutions returning to business as usual after the crisis subsides and potentially making serious mistakes if a pandemic situation occurs in the future.

To learn more about pandemic response and key priorities for financial institutions, download our latest white paper, “Navigating the Coronavirus pandemic: Best Practices for Pandemic Planning and Key Lessons Learned for Community Banks and Credit Union.”

19 Nov 2020

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

3 Key Concepts to Incorporate into Your Business Continuity Management Plans

The 2019 FFIEC Business Continuity Management Handbook represented a significant change in how bank and credit union examiners will assess your business continuity planning efforts going forward. Here are 3 concepts to make sure you’ve incorporated into your Business Continuity Management Plan (BCMP):

1. Likelihood and Impact

According to the Federal Financial Institution Examination Council’s (FFIEC) Business Continuity Management Handbook, “management should evaluate the likelihood and impact of disruptive events. Risks may range from those with a high likelihood of occurrence and low impact such as brief power interruptions to those with a low probability of occurrence and high impact such as pandemics. The most difficult risks to address are those that may have a high impact on the entity but a low probability of occurrence.”

Performing a risk assessment helps financial institutions identify all potential risks and classify them based on probability and impact. They should also quantify the impacts and define loss criteria as either quantitative (financial) or qualitative (e.g., impact to customers, reputational impact). However, to efficiently assess these risks, banks and credit unions need to be able to visualize them and plan accordingly. One way to do this is to use a four-quadrant matrix to scatter graph and plot the likelihood and impact of every threat.

Likelihood and Impact Graph

There are many other ways to do this, but whichever method you choose, examiners expect financial institutions to be able to document both probability and impact, and not only for the high probability and high impact threats, but also for the low probability high impact threats.

Although the Handbook lists Pandemic as an example of a low probability, high impact event, you may want to adjust the probability (and possibly the impact) rating upward based on the COVID 19 event. At this point, it is a certainty that everyone has been impacted somehow.

2. Resilience

Resilience is the ability to prepare for—and adapt to—changing conditions, and both withstand and recover rapidly from disruptions, whether that includes deliberate attacks, accidents or naturally occurring threats or incidents. The first step to resiliency is to identify your proactive measures for mitigating the risk of a disruptive event such as:

Off-site repository of software (Data vaulting)
Appropriate backups of data

Cloud-based disaster recovery services may be considered as part of resilience programs

Off-site/redundant infrastructure (Hardware, data circuits, etc.)
Third parties (Alternate vendors/suppliers)
Key personnel (Succession planning)
Cybersecurity assessment tool

Annual process of considering changes in inherent risk and how your evolving in maturity

These are things you probably are already doing. If so, you can use your calculations to show that you already have proactive resilience measures in place.

Make sure to incorporate any adjustments made and lessons-learned from the recent Pandemic into your inventory of resilience measure against the next pandemic.

3. Inherent vs. Residual Impact

Although the residual risk rating is often used as the measure of the effectiveness of your risk management program, best practices mandate that management should use inherent risk ratings to guide their recommendations for (and use of) mitigating controls. However, when calculating residual threat impact, you can factor in any existing impact mitigation measures you already have in place. For example, if you use forewarning, duration, and speed of onset to calculate impact, any measures taken to reduce those 3 factors can also reduce your impact rating:

Example 1: Smoke detector & Fire detection equipment decreases the impact of fire by increasing the forewarning factor
Example 2: Auxiliary power decreases the impact power outage by decreasing the duration factor
Example 3: Good project management practices decrease impact of strategic risk by slowing the speed of onset factor

This is how you can take advantage of the existing measures you already have in place to decrease the residual impact of an event. You don’t have to do anything new, just take into account all of things you’ve already done to build resilience into your business continuity plan. Then simply add on where residual risks are still above your risk appetite!

For more information, watch our webinar recording, “The New Business Continuity Guidance Requires a Whole New Approach.”

12 Nov 2020

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

The Importance of Performing a Cybersecurity Gap Analysis for Banks and Credit Unions

In response to the Coronavirus pandemic, many financial institutions have implemented new technologies and made modifications to their IT infrastructure to better serve customers, members, and employees during this time. These changes may have increased the institution’s inherent risk profile, however, making it necessary to review the Federal Financial Institution Examination Council’s (FFIEC) Cybersecurity Assessment Tool (CAT) or National Credit Union Association’s Automated Cybersecurity Examination Tool (ACET). When adjustments are made to the organization, community banks, and credit unions must evaluate their risks and perform a gap analysis to ensure the institution is protected from cyber threats.

What is a Cybersecurity Gap Analysis?

A cybersecurity gap analysis starts evaluating the results of the CAT or ACET, (which is simply a snapshot in time of where you are with your risks (inherent risk profile) and controls (cybersecurity maturity) and then comparing “where your institution is” to “where you need to be.” In almost every case, there is some degree of misalignment between the two. Some common questions financial institutions ask are “Could we be doing more to oversee our cloud providers?” or “Should we be doing more to manage our internal administrators or third parties?” The idea of the gap analysis is to take your risk areas and determine what set of controls are most effective against those specific risk areas.

Completing the Cybersecurity Maturity section, for example, helps financial institutions better identify missing controls and processes. So, in order to increase the level of cybersecurity maturity, institutions should continually implement changes even if their inherent risk profile doesn’t change. Conducting a gap analysis is the first step in this process.

Continuous Improvement

Why should institutions strive to continuously improve their security posture even if their risk profile doesn’t increase? Simply put, because the threat environment is constantly evolving. New threats (and new twists on old threats) require constant vigilance and continuous improvements to existing controls. Standing still means you’re probably falling behind. On the other hand, making steady, incremental progress on your control maturity demonstrates a proactive, forward-thinking approach to cybersecurity.

Key Areas of Focus

First, financial institutions must determine if their controls and risks align – no small task as there are roughly 30 risk elements and nearly 500 control maturity elements in the assessment. Attempting to improve all of these areas in the CAT can be challenging and expensive for any institution, but especially smaller community banks and credit unions. While all control maturity domains are important, if your financial institution has limited resources, there are two key domains that you should focus your attention on when developing the gap analysis.

Domain 4: External Dependency Management

This domain involves establishing and maintaining a comprehensive program to oversee and manage external connections and third-party relationships that provide access to the institution’s technology and information. Most financial institutions have a host of outsourced relationships that they rely on to keep operations running. Evaluating the interdependencies and associated security gaps from third-party vendors should be a key part of your analysis process.

Domain 5: Cyber Incident Management and Resilience

This domain focuses on establishing, identifying, and analyzing cyber events, as well as the ability to prioritize, contain, and mitigate during cyber events. The institution should also have the ability to properly inform the appropriate stakeholders in response to a cyber event. Cyber resilience includes both planning and testing to maintain and recover ongoing operations during — and following — a cyber incident. In the current security environment, it’s not if a cyber event will occur but when. Financial institutions should have an effective cyber incident response plan to control, contain, and recover from a potential cyber incident.

For more information, watch our Banking Bits and Bytes episode, “What is a Cybersecurity Gap Analysis?”

05 Nov 2020

Banks, Credit Unions, Technology Jamie Davis 0 comment

How Banks and Credit Unions Can Maintain Business Continuity to Achieve Effective IT Management

Banks and credit unions of all sizes experience some level of turnover or unexpected absence that can affect internal positions. When the IT administrator role is impacted, it can cause the most disruption, especially for smaller community institutions, as many have limited resources and may rely on only one employee in the role. When an IT administrator leaves, he or she takes with them the institutional knowledge and expertise gained through working with the FI’s unique IT infrastructure and network management processes. To lessen the impact, it’s up to the institution to effectively build continuity into its IT strategy and pay attention to the strategic decisions being made by the IT team.

In a recent Safe Systems webinar, we discussed the importance of continuity in IT and ensuring effective management of the network through transition periods. In this blog post, we highlight three key areas of focus to achieve continuity and keep the institution operating efficiently.

1. Strategic Decisions

We have seen financial institutions fall victim to the “power of one”, where the IT admin has all the knowledge and authority to make IT strategic decisions alone. Then when they leave, the rest of the institution doesn’t have a clear view of what’s been done to the network and how to properly maintain it.

Some IT admins prefer to try new technologies and add more automation to the institution’s processes. While others might stick to their comfort zone and not push for new IT tools. While it’s important to provide an appropriate level of autonomy to the IT admin, it is critical to also have a system of checks and balances in place and to examine the benefits and consequences of these decisions closely to ensure the institution has the right tools to succeed .

2. Strategic Management

For IT personnel to be successful, it is important to outline what your institution wants the IT admin to accomplish and let them know what success will look like when they achieve these goals. Some key questions to consider include: What are the desired outcomes you’re expecting from IT? Is the goal to spend their time and budget on efficiency projects, redundancy projects, or security projects? In other words, what is your tolerance for downtime, security risks, or ineffective and slower processes? How will these goals be measured?

Once these expectations are established, the IT admin should be given the freedom to do what they need to do to achieve the institution’s goals but there should also be a clear chain of command to provide oversight and to evaluate their work.

You do not want to let an employee’s expertise (or lack thereof) impact your technology or for the institution’s security to be affected negatively. Define clear objectives for your IT personnel, whether that’s uptime, recovery time objectives (RTOs), redundancy, budgeting, or specific controls you’d like to have in place to ensure the institution is operating securely.

3. Strategic Plan

Make sure the expectations and objectives you set for IT personnel align with your strategic plan. According to the Federal Financial Institution Examination Council (FFIEC), “strategic IT planning should address long-term goals and the allocation of IT resources to achieve them. Strategic IT planning focuses on a three- to five-year horizon and helps ensure that the institution’s technology plans are consistent and aligned with the institution’s business plan. Effective strategic IT planning can ensure the delivery of IT services that balance cost and efficiency while enabling the business units to meet the competitive demands of the marketplace. The IT strategic plan should address the budget, periodic board reporting, and the status of risk management controls.”

When discussing the strategic plan with management, it’s important to identify the key areas of improvement and provide information on price, level of risk, and what exactly the institution is trying to accomplish. Sometimes having an outside perspective can help push key initiatives along and get them into the budget for the year ahead.

To learn more, download the recording of our webinar, “Understanding The Lifecycle of the IT Administrator: Ensure Effective Management of Your Network.”

02 Nov 2020

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

The Impact of Digital Banking During the Coronavirus Pandemic

The coronavirus (COVID-19) pandemic has drastically reshaped the way banks and credit unions operate today. While financial institutions value face-to-face interactions with their customers and members, social distancing requirements and other safety precautions have caused retail banking to go almost entirely digital. This change impacts not only how financial institutions conduct their business and interact with customers and members, but also how they keep their institutions secure.

In this blog post, we outline 3 key ways the pandemic has impacted the industry and consumers, and how financial institutions are managing these changes in real-time while ensuring they continue to operate effectively for their employees, customers, members, and other stakeholders.

1. Know Your Customer

For banks and credit unions, know-your-customer (or member) procedures are a key function to establish a customer or member’s identity, understand their financial activities, and evaluate the level of risk to the institution. Traditionally, before opening an account, completing a transaction, and/or sharing private information, many financial institutions have relied on at least some face-to-face interactions. For community financial institutions, know-your-customer has gone well beyond best practice to become a competitive advantage. Many (if not most) community institutions pride themselves in knowing their customers by name!

However, due to the COVID-19 pandemic, financial institutions need to find ways to verify their customers’ identities and retain that personal touch using digital channels. Consumers want a frictionless banking experience where they feel trusted and can quickly receive the products and services they need, but they also want to avoid feeling like just another number. Institutions must balance managing remote transactions that could increase their security posture, against technology and policies that positively identify customers without alienating them. As a result, some financial institutions are leaning towards increased security by starting to adopt a “zero-trust” stance where every individual and transaction is considered suspicious unless proven otherwise.

2. Technology Updates

To protect customers and members during the pandemic, banks and credit unions have moved from in-branch, face-to-face interactions to using remote channels such as online, telephone, ATM banking as well as the drive-through to serve their customers. Our experience has been that many institutions that may have technology upgrades on their roadmap two or three years down the road have had to accelerate those projects. Others have added new initiatives to increase their remote capabilities and enhance their electronic services. However, all this likely requires tighter security protocols for customer verification. This can be challenging for smaller financial institutions that rely on more traditional in-branch visits to provide services to their customers or members, particularly if branches are closed or observing limited hours and services. It is up to these institutions to find the right balance of physical and digital solutions to ensure customers and members receive the same level of service they were accustomed to prior to the pandemic.

3. Digital Adoption

The COVID-19 pandemic has driven consumers to rely more heavily on digital channels for their banking needs. This has accelerated digital transformation for financial institutions in the U.S. as their customers demand solutions that allow them to quickly and easily complete transactions remotely. To meet this demand, financial institutions have reevaluated their traditional strategies, implemented and even accelerated digital initiatives, and are more inclined to not just enable but encourage digital capability for their customers. As they encourage consumers to adopt new solutions and remote tools, it will be critical to assess the risk of these solutions and develop controls to keep the network safe and protect sensitive, financial information.

Banks and credit unions must be able to provide the products and services their customers and members need all while keeping information secure, even in the midst of a pandemic. Having a solid plan to guide how you manage operations can make all the difference. One final thought, when the dust settles and things go back to “normal”, the steps you’ve taken to enable digital engagement with employees and customers will be considered resilience measures to mitigate the impact of a future event of this nature. Resilience will be a focus for regulators in future examinations.

To learn more about pandemic planning and best practices, download our latest white paper, “Navigating the Coronavirus Pandemic: Best Practices for Pandemic Planning and Key Lessons Learned.”

22 Oct 2020

Banks, Credit Unions, Technology Jamie Davis 0 comment

Why Safe Systems Made the Switch from Java to Amazon Corretto for Network Management

Java is a programming language and computing platform first released by Sun Microsystems in 1995. On April 16, 2019, Oracle (who owns Java and its development) changed its client-based Java model from free to fee-based. This created a huge issue in the marketplace because so many businesses, consumers, applications used Java and based their code off of Java. So now, to get Oracle’s version of Java requires a fee per device. Many companies are facing an update and licensing management issue as they are forced to track who in their organization has Java; who needs it; and whether there are enough licenses. At this point, they must update only the computers who have purchased licenses.

It seemed like overnight, supporting and updating Java went from “not a big deal” to a headache for a lot of IT people. Luckily several companies saw the issue and began creating their own Java client based on the open source code that was released for Java. Several major players like IBM, Amazon, and even Oracle started creating their own versions of Java. Safe Systems researched which of these versions would be supported by the core providers and software vendors in the financial industry, and Amazon Corretto emerged as a top choice because it is free to use and is backed by a reputable company.

What’s Next?

At the end of December 2020, Safe Systems has decided to no longer support the fee-based version Oracle offers of Java as we now have no way to confirm if a license has been purchased or not. Instead, we have worked with financial institutions and have adopted Amazon Corretto as a supportable alternative to the Oracle fee-based version. Safe Systems will support, update, and report on Amazon Corretto as part of our third-party patching program with NetComply™.

Safe Systems did not make this decision lightly. We worked with multiple institutions using various banking applications to ensure that this could be a widely accepted switch in the industry. We spent hundreds of man hours testing and implementing the appropriate changes to ensure this is a smooth transition. We are happy to say that we can successfully support Amazon Corretto as a key application that in turn supports your critical banking applications.

NetComply is built around monitoring, alerting, automation, and supporting your machines, but it is also about keeping key applications fully patched so that your network is as secure as possible. We encourage each of you to confirm all of your applications work with Amazon Corretto before switching. If they do, there is nothing left to do but sit back and let NetComply take it from there.

15 Oct 2020

Top 4 Security Solutions for a Layered Approach to Cyber Incident Response

Banks, Credit Unions, Security Brendan McGowan 0 comment

1. Network Firewall

We often reach for this tool when a financial institution is working to determine if one of their employees may have received a phishing email or clicked a malicious link. They want to know: who got the email; which user was an entry point for a piece of malware; or when did they connect to it? Relying on the memory of the user often doesn’t provide the detailed information needed to take action and find the true source of the problem. Logs, however, offer deeper insights. If we know the specific workstation or outside IP address, we can then look it up and decipher the entire transaction.

Firewalls, by their nature of design, generate a significant number of logs. The downside is that the sheer volume of logged content is very high and it’s difficult for any human to monitor and manage this amount of data effectively on their own without automated tools. Many community financial institutions are outsourcing firewall management to third-party providers that have created logging infrastructure just for the firewall to store the logs and make the data searchable and readable.

Antimalware - Top 4 Security Solutions for a Layered Approach to Cyber Incident Response

2. Endpoint: Antimalware

Antimalware and antivirus agent tools help financial institutions track down the precise point from which malware and viruses originated. Some of these have better logging capabilities than others, but many of them feature impressive investigative tools. We often reference this tool when a customer says: “I think someone might have opened an attachment they weren’t supposed to,” or “I think we might have some sort of infection that might be spreading, can you check it out for us?” With our antimalware tools, we’re able to track down exactly where it originated; who clicked what; and identify the actual origin point. The tool also enables us to break up the data and show a graphical representation of events.

Server Security Logs - Top 4 Security Solutions for a Layered Approach to Cyber Incident Response

3. Server Security Event Logs

Security event logs record user logins and network access. We reach for these tools when we get questions from customers wanting to know which user logged into a certain application or who may have access to information that they shouldn’t. One of the most important areas to monitor are administrative logging events. If a bad actor gets into your network and gains access to your active directory, they then have the proverbial “keys to the kingdom” with the ability to create accounts, or even worse, admin accounts. However, the one thing they can’t hide is all of the activity they’ve done on the network as long as you’re monitoring these logs.

IT personnel are required to have some mastery of security event logs on the servers and especially on domain controllers to meet examiner expectations, but it requires expertise and research to understand which events are important. For example, with each new version of Windows comes a new set of alerts and often, alerts that were important in a previous version get replaced by something new. This is very challenging to manage along with other important IT activities. Working with a third-party provider can help you stay on top of the latest Windows updates and emerging threats with alerts and reports to proactively monitor the network and effectively thwart attacks.

Cloud - Top 4 Security Solutions for a Layered Approach to Cyber Incident Response

4. Cloud – O365

Most financial institutions use Microsoft O365, but they may not be taking full advantage of all the capabilities it has to offer as there is a host of fantastic logging and audit capabilities that are not turned on by default. So, if you’re an O365 subscriber, you need to review all security settings and make sure you have them turned on.

At Safe Systems, we do this when we onboard customers to our managed O365 offering to protect against e-mail-borne threats. A few key items we make sure our customers are monitoring include:

Email Forwarding – IT admins should make sure that user mailboxes don’t have forwarders set up that point to any other mailbox, especially not an external email address. Without multi-factor authentication turned on, bad actors can access your mailbox; set up forwarding; and monitor correspondence between you and a customer undetected.
Delegated Permissions – IT admins should also check delegated permissions to look for unauthorized access to employee mailboxes. Bad actors often use this tactic to spy on email communications between financial institution staff and customers.

We encourage all financial institutions to implement these four tools for cyber incident response and make sure you understand how to collect important logging information to have conclusive evidence right when you need it.

For more information, watch our recorded webinar, “Not If, But When: Best Practices for Cyber Incident Response.”

08 Oct 2020

Banks, Compliance, Credit Unions Jamie Davis 0 comment

Best Practices for Developing a Compliant Cyber Incident Response Program

If you think a cyber incident won’t impact your financial institution, you are seriously underestimating the lengths cybercriminals will go to steal your customers’ or members’ non-public information. According to a new report from NuData Security, a Mastercard company, financial institutions receive the highest percentage of sophisticated attacks (96%) amongst all industries.

As cybercriminals continue to exploit organizations and increase the quality of their attacks, financial institutions need to have a compliant incident response plan in place to control, contain, and recover from a potential cyber incident quickly and efficiently.

Safe Systems held a webinar discussing what a compliant cyber incident response plan should look like and shared key best practices community banks and credit unions should use to effectively document a cyber incident. In this blog, we’ll cover a few of the key points from the webinar.

Elements of a Compliant Incident Response Program

The requirements for incident response have changed significantly since 2005. The guidance was broad enough to encompass many of the events that are occurring today including cybersecurity and pandemic-related events. According to the Federal Deposit Insurance Corporation (FDIC), there are five key elements of a compliant incident response program:

Assessing the nature and scope of an incident and identifying what customer information systems and types of customer information have been accessed or misused
Notifying its primary federal regulator as soon as possible when the institution becomes aware of an incident involving unauthorized access to or use of sensitive customer information
If required, filling a timely suspicious activity report (SAR), and in situations involving federal criminal violations requiring immediate attention, such as when a reportable violation is ongoing, promptly notifying appropriate law enforcement authorities
Taking appropriate steps to contain and control the incident to prevent further unauthorized access or use of customer information
Notifying customers when warranted in a manner designed to ensure that a customer can reasonably expect to receive it

Although these requirements have essentially stayed the same, there is one key change that has occurred in the FFIEC’s 2019 update to the Business Continuity Handbook. The guidance now requires financial institutions to reference or include the incident response plan (IRP) in the business continuity management plan (BCMP). While still acceptable to have a separate incident response plan, somewhere within your BCMP you must now reference the IRP.

How to Document and Maintain Evidence of an Incident

Documentation is a key component of incident response to provide auditors, examiners, and other stakeholders with key information about the abnormal event or incident. Initial steps include the recording of basic facts about the suspicious event before it becomes an official incident.

Key questions include:

What specific abnormalities were noticed?
Where were they discovered?
When were they discovered?
Who first noticed the abnormality or event and who did they notify/involve?
If the event escalates to an incident, how did it happen, and what were the contributing factors that allowed it to happen?

If the event is categorized as an “incident,” you need to know how to document and maintain the evidence; what decisions were made; and the resulting actions taken. When enacting your containment strategies, part of that should involve collection and preservation of the evidence, including all the key records created by all the various technologies your institution uses. The guidance references that all financial institutions should have some type of logging intelligence. But which logs are most important for incident response?

When creating a logging strategy, there are five key challenges to consider:

Sources – Logs are generated from various sources such as users, databases or file shares, endpoints, networks, applications, and cloud services. With so many logs coming from different sources, it’s important to be aware of all the systems and applications generating logs and know how to access them to monitor efficiently
Log Volume – The volume can be different depending on the source. Some sources are quiet and easier to manage while other sources like network switches and firewalls are a constant torrent of volume and may be difficult to log. It’s important to determine what is realistic for your institution to store and manage
Log Protocols – All of the various sources speak different languages or protocols. Some of them are sending emails using a language called simple mail transfer protocol (SMTP), while other sources like network switches are sending information using a constant stream of Syslog data. It is nearly impossible to create a centralized system that can speak all of these languages perfectly so you must determine how your institution will extract intelligence from the logs
Log destinations – Once you’ve collected information, where are you going to send it? You’ll need to determine storage destinations for the different types of logs
Log interaction – After you’ve built the logging platform, do you want it to be searchable? You’ll need to decide how you want to interact with the data and how long you will keep it. Adding data retention can become significantly more expensive depending on the time frame for storage

Different types of data likely require different lengths of time for retention. Your retention policy should outline the expected retention time frame for each data log. Institutions should carefully consider all these key challenges when building a logging strategy that fits their unique needs.

If you’d like to learn more about cyber incident response, download our recorded webinar, “Not If, But When: Best Practices for Cyber Incident Response.”

01 Oct 2020

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

After a Year Unlike Any Other, What Community Banks and Credit Unions Should Budget for in 2021

In 2020 we’ve learned a lot about ourselves, and whether the general population realizes it or not, they have learned a lot about something often relegated just to banking: Risk Tolerance. And with that in mind, here are seven key items that your institution should consider while budgeting for 2021:

1. Laptops

Supply is down, demand is up, so from a pricing standpoint, you are unlikely to find great deals on laptops, but their portability has been a key component to companies and employees being successful during the pandemic. Remote work is a great option for employees who do not need face-to-face interactions with customers or members, but not every department can work successfully outside of the main office or branch.

When planning for next year, each position in the institution needs to be evaluated, if it hasn’t already, to determine the ability and effectiveness of remote working. When possible, consider having remote employees use a company laptop going forward. In a recent Safe Systems survey of community financial institutions, 1/3 of respondents have already decided that they will be purchasing more laptops this year.

2. Hardware Management Software

How many of the controls you use to secure your institution’s devices require the device to physically be in the office? As the work environment changes and more people make the shift to working from home offices, your current controls need to be evaluated to ensure they work just as effectively outside of the branch. For years, the push for “agentless” controls has been popular, but many of these controls assumed the office was a well-defined building where all devices used the financial institution’s network. As the home office becomes the new standard for many banks and credit unions, the need for agent-based controls is greater than ever. Controls/security measures are no longer effective if they require the device to be on premise.

3. Business Continuity Plan (BCP) Update

Having an updated pandemic plan as part of your BCP is still likely a need for many institutions. Because it has been more than a century since a full-scale pandemic hit the U.S., many of the assumptions and concepts that pandemic plans were based on have proven to be incorrect. For instance, many plans outlined operational changes based on only 50% staff for just a week or two. Much of the concern before 2020 was making sure staff members were properly cross trained in the event key individuals were unavailable for days or perhaps a few weeks. While this is still very important, it represents only a tiny portion of truly being ready for a pandemic.

Pandemic plans often did not address managing operations for a long duration or important measures like social distancing, security measures, consumer access, etc. Financial institutions must take a hard look at key lessons learned so far during the COVID-19 pandemic and update their plans accordingly.

4. Moving to the Cloud

Recognizing that having employees working outside of the office is a real possibility moving forward, investing in new servers and putting them in offices is becoming an antiquated idea. The cloud provides a level of redundancy, scalability, and accessibility that cannot be matched by buying a single server. It also means no one has to be in the office to manage the infrastructure. As servers need to be replaced, banks and credit unions should seriously consider the process of moving to the cloud.

5. Client Experience

One question every institution should be asking itself is: “how can we better enhance the customer experience?” While IT is usually seen as a cost center, the events of the past year may have opened a door for IT to step up and offer solutions that directly affect the customer experience. The pandemic has forced many people, some maybe for the first time, to adopt digital banking solutions. If IT can offer specific tools and/or insight into how to improve the customer experience, this may be the opening that IT has hoped for to secure a “seat at the table” among their institution’s leadership.

6. Cybersecurity

Garmin, the GPS and active wear company, reportedly paid $10 million in 2020 to counter a ransomware attack. Their customers were without the services for over a week while Garmin’s data was held hostage. All of the information about their case is not available yet, but the sad reality is that they likely could have prevented the entire situation with just a few technology solutions and security settings being implemented correctly. The threat to your data is as real today as it ever has been. Be sure to have a conversation with a security company you trust to ensure that even if you are the target of a ransomware attack, it won’t be able to hurt your business long-term. Invest in cybersecurity now, so that your institution won’t end up paying much more later.

Consider this: Cyber-attacks are 300 times more likely to hit financial services firms than other companies, according to a recent Boston Consulting Group report, and cyber-attacks continue to climb each year, with the global cybersecurity market expected to eclipse $300 billion by 2024, according to Global Insights.

Unfortunately spend and layers of protection most likely need to increase annually to address this issue.

Employee training – to ensure adequate and effective
Perimeter protection – to ensure the appropriate layers are enabled and all traffic is being handled correctly including encrypted traffic
Advance 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 can’t wipe out your data

Per Computer Services, Inc (CSI), 59% of financial institutions will increase spending for cybersecurity this year.

7. ISO

With the increase in responsibilities of the Information Security Officer and the focus on separation/segregation of duties, there has been an uptick in the number of institutions looking for virtual ISO (VISO)-type solutions. These solutions can help by taking some level of burden off of internal resources, provide staff with templates or toolsets when needed, and oversight to ensure nothing is falling through the cracks.

For 2021, there are a lot of things to consider. One focus should be to look at the changes your institution had to make because of the pandemic and what changes you should consider making in the future to improve cybersecurity, information security, and as always, your customers’ and members’ experience.

21 Sep 2020

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

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

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

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

1. Incident Response Team Participation

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

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

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

2. Designated Spokesperson and Social Media Monitoring

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

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

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

3. Detailed Incident Documentation and Log Retention

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

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

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

09 Sep 2020

Banks, Credit Unions, Security Keith Haskett 0 comment

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

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

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

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

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

Improperly configured spam filtering/web filtering solutions

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

Lack of multi-factor authentication for ALL accounts

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

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

Lack of security coverage enterprise-wide

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

Accessing external resources (Gmail/Dropbox)

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

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

Utilizing corporate resources remotely

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

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

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

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

03 Sep 2020

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

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

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

The Challenge

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

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

The Solution

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

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

The Results

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

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

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

27 Aug 2020

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

Three Virtual ISO Delivery Models for Community Banks and Credit Unions

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

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

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

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

1. Outsource All Activities

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

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

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

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

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

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

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

3. Hybrid (Toolset + Consultation)

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

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

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

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

13 Aug 2020

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

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

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

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

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

The Challenge

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

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

The Solution

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

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

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

The Results

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

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

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

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

06 Aug 2020

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

Managing Information Security Requirements and Expectations: Accountability vs. Responsibility

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

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

Key Elements

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

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

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

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

Maintaining Compliance

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

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

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

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

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

04 Aug 2020

Banks, Credit Unions, Security Brian Brannon 0 comment

Maintaining Information Security to Combat Cyber Attacks

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

CIA of Information Security

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

Data Breaches

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

Malware

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

Phishing

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

Best Practices for Information Security

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

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

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

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

23 Jul 2020

Banks, Credit Unions, Security Marshall Jones 0 comment

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

Securing Microsoft 365

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

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

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

1. Time

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

2. Bring Your Own Device (BYOD)

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

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

Here are a few options to consider:

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

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

16 Jul 2020

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

The ISO in a Crisis: The Increased Importance of Vendor Management During a Pandemic

In a previous post, we discussed the role of the ISO in a pandemic and how he or she must make sure all routine tasks are still being completed; help the institution adapt to the new circumstances; and continue providing all products and services at an acceptable risk level.

While an institution may be prepared to continue business as usual, its third-party provider partners may not be on the same page. Like the bankers they support, third-party vendors are also experiencing the impact of the pandemic and are dealing with a variety of operational issues as well. Financial institutions must be able to perform effective vendor management during a crisis and develop alternative plans in the event a critical vendor may not be able to perform the services agreed upon.

Here are a few things the ISO must consider to effectively evaluate the institution’s vendors during a crisis like a pandemic:

Identify Vendor Risks

During a pandemic, the ISO must anticipate several different risk scenarios that can adversely impact the institution’s daily operations. With vendors, there are two interrelated key risk factors to consider:

“Supply chain risk” is related to the interconnectivity among the entity and others. In a pandemic, critical vendors may receive an overload of requests for products and services from a variety of industries and may not be able to keep up with demand. For example, many financial institution employees have been working remotely due to Coronavirus and to keep the network secure, financial institutions have provided company laptops to staff. However, if the FI’s laptop provider runs out of inventory, the institution is then put in a difficult situation – if they allow the use of personal devices, they must still make sure all employees can work safely from home and ensure the network remains secure.
“Cascading impact risk” is an incident affecting one entity or third-party service provider that then impacts other service providers, institutions, or sectors. For example, if the vendor that manages the bank’s perimeter security has a large case of absenteeism and an inadequate succession plan, real-time alerting may be negatively impacted, and the institution could be exposed.

Evaluating these risks with third-party vendors in advance will help ensure that they have the proper personnel redundancies in place, so these situations don’t impact the institution.

Managing Third-Party Risks

According to the Federal Financial Institution Examination Council (FFIEC), open communication and coordination with third parties, including critical service providers, is an important aspect of pandemic planning. A current SOC 2 report that covers the “availability” trust criteria is the best way to determine if the vendor has the capability to respond and recover its systems. In the absence of a SOC report, the first thing the ISO should request is a copy of the business continuity plan. Since the SOC report may not cover the service providers’ vendors (also referred to as sub-service providers), the ISO will also want to gain some awareness of the possibility of supply-chain risk. For example, how might a provider failure two to three layers deep affect the institution?

In addition to vendor business continuity plans, the ISO should ask additional questions about how the vendor is managing the pandemic. Here are a few examples:

When was the last time you updated and tested your BCM plan? Have you incorporated the possibility of a failure of a critical sub-service provider?
Is the likelihood and impact of a pandemic evaluated as a part of your risk assessment?
How do you plan to continue providing services in the event of the loss of key employees?
Have you been in communication with your critical third-party providers?
Are you financially prepared to withstand a long-term pandemic event?

Critical third parties are often either overlooked or under-managed during normal circumstances, but because of the current high level of interdependency among financial institutions and their third-parties, operational events such as pandemics call for much closer scrutiny. Depending on responses received, ISOs may choose to accelerate their oversight efforts, revisit their vendor risk assessments, and make adjustments accordingly.

For more information on responding to pandemic events, view our pandemic resources.

14 Jul 2020

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

The ISO in a Crisis: Key Responsibilities of the Information Security Officer During a Pandemic

According to the Federal Financial Institution Examination Council’s (FFIEC) Information Technology Examination Handbook, “ISOs are responsible for responding to security events by coordinating actions to protect the institution and its customers from imminent loss of information, managing the negative effects on the confidentiality, integrity, availability, or value of information, and minimizing the disruption or degradation of critical services.”

When faced with an operational crisis such as the current Covid-19 Pandemic, potential disruption of critical services is the primary concern. Since the information security officer (ISO) acts as the “quarterback” over the many different departments and functions within the institution, they must make sure all routine tasks are still being completed, in addition to ensuring that the institution has adapted to the unique circumstances of the crisis.

The FFIEC Management Handbook lists 8 broad categories of responsibilities for ISO’s. We’ve identified a few of those areas that should be of particular focus during a crisis:

Working With The IT Steering Committee

During any crisis, the ISO must work closely with the IT Steering Committee to ensure that the institution minimizes the risks to the security and confidentiality of non-public information and financial transactions. As difficult as this is during normal operations, it may be even more of a challenge during a crisis. Key considerations include:

The IT Steering Committee should still perform their normal duties and maintain a normal schedule. Phone /video conferences can suffice if in-person meetings are not an option.

Attention to on-going and planned IT project road map/initiatives. Timelines and all supporting activities must still be tracked, project plans updated, and all stakeholders informed.

Review the Remote Access Policy and the Remote User / Acceptable Use Acknowledgement with IT and HR as your current situation may include unique risks that have not been previously addressed. For example, some employees may have to use their personal devices to access the FI’s network to do their job. Take particular note of the Remote Access and Use of Remote Devices sections of the FFIEC Information Security Handbook and any other related best practices and/or guidance initiatives. Trusted third parties can also be an important resource for this effort.

Document all actions taken and lessons learned during the crisis so far. Then, incorporate them into your next round of policy updates.

Continue to report the status of all IT and information security activities to the Board.

Managing Incident Response, BCP/IRP, and Cyber Responsibilities during an Adverse Event

The ISO is typically the Incident Response Team Coordinator and may determine whether or not to activate the formal Incident Response Plan (IRP). The declaration of a pandemic or other adverse operational event does not in itself require the IRP to be invoked, however, any disruption of normal business services may create vulnerabilities that a cyber attacker could take advantage of.

The ISO will also likely be involved with general business continuity planning and recovery efforts. The criteria for activating the Business Continuity Plan will vary by institution, but the ISO is typically one of the few key individuals tasked with evaluating whether the event is likely to negatively impact the institution’s ability to provide business products and services to customers beyond recovery time objectives (RTOs).

In adverse situations, cyber awareness should be heightened. For example:

The institution could have key personnel out, and alternate personnel may not be adequately trained or have the same level of cyber awareness as the primary staff members.

The institution may be implementing workarounds for new software or devices when trying to accommodate customers affected by the event. In the interest of expediency for customers, the institution may take shortcuts that it normally wouldn’t or otherwise fail to follow normal procedures.

The institution could run into issues with the critical vendors that perform or support its perimeter security, compromising real-time alerting for the organization. This is known as “cascading impact”, where a product or service provided by a third-party is degraded, which in turn affects you.

The institution could experience secondary disruptions where hackers may attempt a cyber-attack against perceived weakened defenses.

The ISO must anticipate all of these risks and should communicate with critical third parties to ensure they have a plan in place to keep the NPI and financial transactions secure and provide critical operational services at acceptable levels of risk.

Addressing Auditor and Examiner Expectations

Although a pandemic, as a crisis event, was de-emphasized in the 2019 BCM Handbook, financial institutions should expect regulators to issue additional joint statements in the post-pandemic phase due to the shear impact and duration of this event. ISOs should expect examiners to ask about the specific actions the institution has taken in response to COVID-19, including:

Succession plans – ISOs should be prepared to share the institution’s succession plans, how these plans were implemented during the pandemic, and any key updates to the plan post-pandemic.

Cross-training efforts – the ISO (if also the BCP Coordinator) should explain the institution’s plans for cross-training and how these plans were implemented during the pandemic.

Remote access controls – the ISO should address all of FFIEC requirements for remote access and document any updates or changes that occur.

Third-party/supply chain issues – the ISO should communicate with all critical vendors to ensure there are no interruptions to critical services, and he or she should have contingency plans in place if a third-party provider can no longer provide adequate service.

Information security officers ultimately must be able to show auditors and examiners exactly how the institution withstood the pandemic, maintained compliance, kept all non-public information secure, and kept all stakeholders informed, all of which is no small task during normal operations!

For more information on responding to crisis events, view our pandemic resources.

25 Jun 2020

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

What is My Bank or Credit Union’s Cybersecurity Posture Compared to My Peers?

It is important to understand your institution’s cybersecurity posture to find out where you stand in regard to cyber threats and what you need to do to create a more secure environment. It’s a delicate balance because being behind on your cybersecurity posture means your institution is less secure than it should be but being ahead likely means that you are investing in resources that you may not need. Unfortunately, it’s almost impossible to do a true peer-to-peer comparison because there are just too many variables between even similarly sized financial institutions to obtain a useful analysis. Here’s why:

Every Institution Has a Unique Model

When we implement information security or business continuity programs for banks and credit unions, we start with a process called “Enterprise Modeling” where we identify the departments, the processes, and the functions that make up each individual financial institution. What this process typically reveals is that if you model out two financial institutions that look identical in terms of geographic area, demographic customer or member base, size and complexity, the results will almost always be significantly different since each institution has a unique operating model based on their specific services, organization, processes, and technologies.

Cyber Risk Appetite Is a Key Variable

Cyber risk appetite is another factor that often differentiates your institution from your peers. Safe Systems’ Compliance Guru defines risk appetite as “The amount of risk that an enterprise is willing to pursue and accept in order to achieve the goals and objectives of their strategic plan.” For example, let’s say we have two financial institutions that seem equivalent in outward appearance. Based on their strategic plan, one institution has decided to take a more aggressive cybersecurity posture to electronic banking products and the other has decided to take a more conservative approach. Because the level of risk varies by the approach, you simply cannot accurately compare the two institutions.

The Best Way to Evaluate Cybersecurity Posture

At Safe Systems, we recommend allowing your bank or credit union’s information to stand on its own. To truly improve your cybersecurity posture, you must examine where you are based on where you need to be — not where a peer may be in the process. Carefully evaluate your risks (including areas of elevated risk), and the controls you have in place that offset those risks. Then, examine the best control groups to apply against those areas of elevated risk and develop an action plan to take your institution from where you are now, to where you need to be. Then, when you conduct this process again next year, you can demonstrate steady progress to both examiners and your Board.

Holding Steady May Cause You to Fall Behind

In addition, just because your inherent risk profile isn’t increasing from one assessment to the next, this doesn’t necessarily mean your control maturity levels shouldn’t increase. The risk environment is constantly evolving, so holding steady on your controls may actually mean your cybersecurity resilience is decreasing. Making incremental increases in your control maturity levels will help keep you ahead of the latest threats.

For more information about improving your cybersecurity posture, watch the full “Banking Bits and Bytes Super Duper CEO Series,” below.

18 Jun 2020

Banks, Compliance, Credit Unions Darren Bridges 0 comment

Addressing Banking Security, Technology and Compliance Concerns

To gain new insight into the needs of banks and credit unions today, Safe Systems conducted a sentiment survey and asked community financial institutions directly about their top concerns. Their responses were primarily concentrated in three main areas: security, compliance, and technology, especially regarding exams and audits, cyber threats, and disaster recovery. Since the pandemic events of this year, many of these concerns have only strengthened in importance. In this blog post, we’ll address these challenges and offer some key best practices to solve them.

Top Security Concern: Cybersecurity

Banking security threats are pervasive worldwide, leaving banks and credit unions with good cause for concern. Consider these alarming cybercrime statistics: Cyber-attacks are 300 times more likely to hit financial services firms than other companies, according to a recent Boston Consulting Group report.

A key tool to combat cyber threats is the Cybersecurity Assessment Tool (CAT) from the Federal Financial Institutions Examination Council (FFIEC) and the Automated Cybersecurity Examination Tool (ACET) from the NCUA. Institutions can utilize this voluntary industry-specific cyber assessment tool to identify their risk level and determine the control maturity of their cybersecurity programs.

Top Compliance Concern: Exams and Audits

While examinations and audits are necessary components of compliance, many institutions are intimidated by the process itself, and while exams and audits may overlap in similar areas, they are distinctly different in terms of nature and scope.

The Federal Deposit Insurance Corporation (FDIC) conducts bank examinations to ensure public confidence in the banking system and to protect the Deposit Insurance Fund. Audits, which typically last several months, are designed to ensure institutions are complying with federal laws, jurisdictional regulations, and industry standards. Auditors conduct tests, present their findings, and recommend corrective actions for the bank to undertake.

Banks and credit unions can use several tactics to prepare for, and meet, the requirements and expectations of regulators:

Review all guidance and issues related to their institution and become familiar with any changes that might impact them

Review previous exam reports for comments or matters that require attention and be prepared to report and discuss these findings, along with any previous nonfinding comments

Use a managed services provider in combination with compliance applications to automate the process of documenting, reporting, and preparing for exams.

While following best practices will not guarantee that an institution won’t have examination findings, it can help significantly lower the likelihood and severity of them.

Top Technology Concern: Disaster Recovery

Financial institutions must have provisions for restoring their IT infrastructure, data, and systems after a disaster happens. Considering the recent outbreak of COVID-19, it is also important for community banks and credit unions to consistently review, update, and test their current disaster recovery plans to be able to address any issues that occur during a pandemic event.

With effective planning, banks and credit unions can launch a calculated response to a disaster, pandemic event, or other emergencies to minimize its effect on their information systems and the overall business operations. Some general best practices for disaster recovery include:

Analyzing potential threats

Assessing the technology required

Managing access controls and security

Conducting regular data recovery test

Returning operations to normal with minimal disruption

While the survey respondents shared a number of serious banking security, technology, and compliance concerns, the good news is that they all can be properly addressed with the right processes, strategies, and resources in place. For more information on the top concerns community banks and credit unions are experiencing today, read our latest white paper, “Top 10 Banking Security, Technology, and Compliance Concerns for Community Banks and Credit Unions.”

12 Jun 2020

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

The “Inherited” Risk – Assessing and Reporting on Vendor Risk

Vendors are the largest source of non-preventable risk for a financial institution, so it is critical that banks and credit unions carefully evaluate, monitor, and manage all vendor relationships to remain compliant and reduce risk. Additionally, institutions must be able to accurately assess risk, implement adequate controls, and provide all stakeholders (including regulators, management, and the Board) with appropriate reporting to convey the overall status of the vendor management program at any point in time.

Assessing Vendor Risk

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 in order to achieve a level of residual risk that is within your risk appetite.

Depending on the information you get from the risk assessment, you can clearly map out the level of inherent risk based on the vendor’s access to data and systems and the level of criticality for each vendor. These results will provide the information you need to control the risks, and ultimately report the overall results of your vendor management program to your key stakeholders.

When conducting a risk assessment you want to include all vendors but focus particularly on your critical vendors. A critical vendor is defined as one that either provides a product or service that is a key interdependency of one or more of your products or services, or one that stores, processes, or transmits non-public customer or confidential information.

Once you’ve established the initial or inherent risk level, you can identify one or more controls to off-set the risks. Typically, you want the vendor’s third-party audit report or SOC report; audited financials; insurance binders; a copy of their incident response and disaster recovery plans; and any testing the vendor has done on these plans. If you can’t obtain a SOC report, you’ll need compensating controls to determine their network security. Ask if they have an information security program and if they’ve conducted any vulnerability and penetration testing. You should also request a report of examination (ROE) from your primary federal regulator on your core provider.

Reporting to Stakeholders

When reporting to the various stakeholders within your institution, many of the reports are relatively similar, but the level of detail will be slightly different for each stakeholder group.

Board

The primary stakeholder that financial institutions must report to is the Board. When presenting to the Board, reporting does not generally need to be highly detailed and should provide a brief, high-level summary of the overall program.

Additionally, it is not necessary for the Board to see this report every time they meet. The requirement is to present an annual update, but we recommend reporting more often if the pace of internal change dictates (whether twice a year or quarterly) to show you are adequately managing vendor risk on an on-going basis. Here is an example of what a Board report should look like:

Management

The management committee (i.e. IT Steering) requires a bit more detailed information than the Board does, and unlike Board reporting frequency, IT should report to the management committee every time they meet. If your management committee meets on a monthly basis, you should produce a report each month as well and communicate this information to the committee. Management needs to know what you’re doing; what you’re not doing; what you’re behind on; and have a good understanding of your progress.

Regulators

Regulators typically review the same reports as your board and committee. However, auditors and examiners will tend to take a deeper dive into your vendor management program and want to review everything you have on your critical vendors. They are looking to see if you’ve done a risk assessment and if you have identified the reports from the vendor that will line up with, control, and offset the risks you identified in the risk assessment. The report you present to examiners and auditors may have more of a narrow but deeper focus, taking a more detailed view of your most critical vendors.

04 Jun 2020

Banks, Credit Unions, Technology Allison Stahlman 0 comment

I’m New to Banking Technology – What Do I Need to Know?

The reality for the community banking industry is that often, institutions are limited in staff size, especially in IT. As a result, employees are sometimes placed in an IT role without any prior experience and they are forced to learn the “ins and outs” of information technology quickly to ensure that the institution stays in compliance and the IT environment is secure.

This can be a daunting task for a financial institution employee who’s been placed in an IT role for the first time. From our experience working with more than 600 community financial institutions, there are four key steps that someone who’s new to banking technology needs to know to quickly get up to speed on all things IT:

Step 1: Determine the Financial Institution’s Current State

When stepping into an IT role from another department, the first thing you must do is get a strong understanding of the current state of the institution and how the IT infrastructure is set up. Key questions include:

What does the IT infrastructure look like?

What technology is currently in place?

Is there hardware or software that is reaching end-of-life?

Are network schematics and data flow diagrams up to date and accurate?

Look at all the policies and procedures currently in place and understand what management has approved for the information technology program and how the environment is organized. It’s important to know exactly where the bank is from an IT perspective because without this knowledge you won’t be able to troubleshoot potential issues or plan strategically for where the financial institution needs to be to meet compliance guidelines.

Step 2: Review Vendor Relationships and Responsibilities

It is critical to know exactly who is responsible for each IT activity. Many community banks and credit unions use a variety of vendors, including core providers, cloud providers, managed services providers, and others. It’s important to understand which vendors are involved with all your hardware, software, and IT services and review the service level agreements (SLAs) which are typically found in the contract to be clear on what the vendor should be providing to the institution. This is crucial because if an issue arises you need to know if it is your responsibility to handle it internally or if you should reach out to a vendor for support. Make sure you are clear about what the institution’s vendors are responsible for, when to go to them for help, and which activities are your responsibility under the SLA.

Another key part of this role is vendor management. As a new IT admin, you have a shared responsibility for monitoring and managing the institution’s vendors and weighing the risks each one poses to the institution. To keep the network compliant and secure, you need to thoroughly evaluate potential vendors; identify critical vendors and services; implement an effective risk management process throughout the lifecycle of the vendor relationship, and report appropriately to senior management. Some key best practices include:

Developing plans that outline the institution’s strategy;

Identifying the inherent risks of the specific activity, and the residual, or remaining, risk after the application of controls;

Detailing how the institution selects, assesses, and oversees third-party providers;

Performing proper due diligence on all vendors;

Creating a contingency plan for terminating vendor relationships effectively; and

Producing clear documentation and reporting to meet all regulatory requirements.

Having a proactive plan in place will help you effectively manage vendors and have a clear understanding of the level of criticality and risk for each service provider. Properly vetting and managing vendors will reduce risk for the institution, while also ensuring compliance requirements are met successfully.

Step 3: Understand the Institution’s IT Organizational Structure

How IT roles are structured within a community bank or credit union varies by the institution, but many financial institutions have an IT administrator, information security officer (ISO), chief information officer (CIO), and an IT steering committee to support IT activities. It’s important to learn how the institution is set up and understand what the ISO and CIO are responsible for so you can work together to ensure the institution’s environment is operating securely and efficiently. It’s also important to make sure all ISO duties are separated from other IT roles at the institution to maintain compliance with FFIEC requirements.

At some point, every functional area of a bank or credit union touches IT in one way or another so understanding how every system, application, and functional area within the institution operates and relates back to IT enables you to help the staff by troubleshooting the different issues each department may experience.

Step 4. Review Recent Audits and Exams

Another way to determine the current state of the financial institution is to review all recent IT audits and exams. Determine if there were any findings or recommendations made by a regulatory agency and make sure that this has been addressed and remediated appropriately. With this information, you can tell if there are any current issues or pain points and start to make strategic plans or address specific issues as they arise.

Financial institutions are held accountable for FFIEC compliance and must manage regulatory activities including reporting effectively. New IT personnel should become familiar with FFIEC guidance and understand what is required to meet regulatory expectations and perform well on future audits and exams.

With these steps, new IT admins can gain a deeper understanding of information technology and what their key responsibilities are at the financial institution to ensure the community bank or credit union can successfully meet examiner expectations and keep operations running smoothly.

07 May 2020

Banks, Credit Unions Jamie Davis 0 comment

How the Cloud Revolutionizes Disaster Recovery for Financial Institutions

Disaster recovery is a concern for all financial institutions, regardless of size or location, and is essential to protecting data, infrastructure, and overall business operations. In addition to having a thorough disaster recovery (DR) plan, community banks and credit unions need to have a solid site recovery environment to facilitate a quick return to normal business operations, in the event of a natural disaster or other disruption.

Cloud disaster recovery solutions are growing in popularity among many community banks and credit unions. However, it is important to understand the key differences in site recovery models to determine the best fit for your institution.

In a recent webinar, Brendan McGowan, Chief Technology Officer at Safe Systems, outlined the three most common site recovery models available to community banks and credit unions today and discussed key considerations when implementing each.

In-House Site Recovery

When using an in-house site recovery model, financial institutions commonly have a virtualized server environment. These machines often run in a VMware vSphere environment which sits on top of a storage array. On the DR side, there is essentially a clone of the production environment to receive the replicated data. This works well for many financial institutions, however, there are a few considerations to keep in mind.

With in-house site recovery, you’ll need to:

Have redundant hardware in the DR environment at an additional cost.

Purchase an additional facility like a co-location or branch for DR.

Oversee hardware and software lifecycle management for both production and DR environments.

Set up dedicated connectivity like multi-protocol label switching (MPLS) to point replication to the DR environment.

Conduct regular maintenance to ensure all replications are healthy and perform periodic testing.

Have significant expertise and talent to make sure the system works correctly and consistently.

Cloud Site Recovery

In this model, the production environment remains the same, but the hardware and software used in the DR environment are replaced with a cloud-based solution. With cloud site recovery, financial institutions don’t have to pay for servers and computing time until the day they need to turn on the disaster recovery solution. Until then, the institution will only be billed for the amount of storage it consumes.

When you use a cloud site recovery solution like Microsoft Azure Site Recovery, you create a storage pool to receive replication from a small server on-premise, which is the cloud site recovery replication server. The replication server works by having each of your production servers send its data changes in real-time to the cloud application server. This server is compressing, encrypting, and deduplicating all of the incoming data and continuously shipping it securely to your cloud site recovery storage pool.

With the cloud site recovery model, you no longer have to:

Deal with redundant hardware on the DR side since everything is stored in the cloud.

Manage hardware and lifecycle management on the DR-side.

Pay for separate facilities since the data is in the cloud, and you can store your data anywhere in the world.

Worry about dedicated connectivity because you can send all of the replication over the internet with a simple virtual private network (VPN).

Handle all of the maintenance or have the expertise required to run the system.

Cloud-Native Resilience

In the cloud-native site recovery model, both the production and disaster recovery environments are in the Cloud. To set up the cloud environment, using Microsoft Azure, for example, you can sign up for Azure Virtual Machines, which would correlate to VMware vSphere in your environment. After that, you can set up your production virtual machines.

At this point, you can register for cloud site recovery for your institution’s individual virtual machines. Once you’ve selected your machines for replication, the system automatically moves that data to whichever Azure zone you select so you get to choose some zone disparity.

In the cloud-native resilience model:

There is no Azure site replication server as there was in the cloud site recovery model.

Since both environments are cloud-native, all the data is in the cloud and you need not worry about a replication server. Simply check a box to turn it on.

In addition, file backup is also a simple checkbox for each server, providing you the option to choose the location to store the data.

Migrating to cloud-based services is a great option to reduce maintenance; significantly speed up the disaster recovery process; and improve overall operations for your institution. If you are interested in implementing a cloud-based disaster recovery solution, Safe Systems can help you determine the right environment for your institution.

To learn more about disaster recovery and moving to the Cloud, watch our recorded webinar, “The Cloud: Recovery and Resiliency is Just a Click Away.”

01 May 2020

Banks, Credit Unions, Technology Brendan McGowan 0 comment

Combating Business Email Compromise and Protecting Your Remote Workforce

Over the last two months, there have been more people working remotely than ever before, and with more being done outside the branch, financial institutions cannot rely on their usual firewall and anti-malware solutions to protect their staff. Today, the single most common attack used to target remote users is what is known as “business email compromise” (BEC).

Safe Systems hosted a live webinar earlier this month discussing how BEC works; the main techniques used in these types of attacks; and the cost-effective solutions needed to mitigate them. In case you missed it, here are a few key points from the webinar:

What is business email compromise and how does it work?

Business email compromise is a security exploit where an attacker targets an employee who has access to company funds or other non-public information and convinces the victim to transfer money into a bank account controlled by the attacker.

These attacks have two main categories:

Phishing emails – this is just a spoofed email that seemingly comes from someone you trust within the organization (like the CFO or CEO) instructing an employee to wire money to a specific account.

Account takeover – the attacker procures your real username and password and then logs into your mailbox where they are then able to send and receive emails at will from your actual account.

Using these attack methods, cybercriminals can commit many different types of fraud, including wire fraud, non-public information (NPI) theft, and spreading of malware.

There are also a number of different attack “types” that cybercriminals commonly use to take over accounts:

A single-stage attack is a social engineering email directing a user to complete a certain action. For example, an email may include a link that leads to a rogue website where the attacker is trying to capture login information. This is a fairly simple, one-step attack.

The more sophisticated variation on this type of attack is the multi-stage method. In this attack, we often see that instead of having a link in the email that goes to a suspicious website that could potentially be blocked by other security layers, attackers use a link in the email that goes to a highly trusted place like a Citrix share file or some other trusted site. If the user clicks the link, they’ve now stepped outside of any email security layers the institution might have in place. Most often these sites are SSL encrypted so this underscores the importance of having SSL inspection performed on your traffic to ensure links in emails do lead to legitimate, secure websites. The problem with this, however, is that it can be an increasingly difficult job for some financial institutions to implement and manage.

How Can Financial Institutions Defend Against These Threats?

Prevent

The first line of defense against business email compromise is to stop the user from being exposed in the first place, and the single most effective measure financial institutions can implement is user training. It’s important for financial institutions to regularly conduct penetration testing and use security awareness training to educate their employees. Over the years, we’ve seen a distinct correlation between the frequency of user security awareness training and the success rate of phishing attacks. Some institutions leverage self-testing tools such as KnowBe4, but there are many other services that financial institutions can use to test their employees.

Mitigate

The second line of defense is to stop the user from causing damage. To mitigate the threat, financial institutions can use a variety of effective tools, including:

Email Filtering – a tool that filters out suspicious emails to ensure no spam, malicious content, or sensitive data makes it out of the institution unauthorized.

DNS Filtering – is the process of using the Domain Name System lookup to find the IP address of a website to block malicious websites and filter out harmful or inappropriate content.

URL Rewrite – if an email has a link, the system rewrites the destination of the link to go to a security company first before the real session is connected.

Multifactor Authentication – this tool requires more than one method of authentication to verify a user’s identity for a login or other transaction. The methods include something you know (pin); something you have (phone) and/or something you are (biometrics).

These are just a few of the tools that can help strengthen your institution’s security posture and ensure users do not fall victim to malicious attacks. However, if they do, it is critical to have a plan to respond.

Respond

The last line of defense is to stop the expansion of damages if a threat has occurred. In this case, financial institutions must conduct an investigation into the cyberattack and have thorough logs of their mail system to understand exactly what occurred; how far it has spread; and determine the next steps. Community banks and credit unions should have an incident response plan in place and perform regular tabletop testing to confirm the plan works and will be useful when a real attack occurs.

To learn more ways to protect your institution from business email compromise, watch our recorded webinar, “Business Email Compromise – Preventing the Biggest Risk from Remote Users.”

23 Apr 2020

Banks, Credit Unions, Technology Jamie Davis 0 comment

Managing Banking IT Operations During a Pandemic: Your Top Questions Answered

For many financial institutions, it has been a challenge to keep IT operations moving efficiently during this pandemic. Since community banks and credit unions are considered an essential business, they are required to continue to serve customers and members. This can be difficult when employees are unavailable or are forced to work remotely from their homes for the first time. Many financial institutions have questions about how to efficiently manage their remote workforce, while keeping the institution secure and employees, customers, and members safe.

To address these questions, Safe Systems’ Information Security Officer, Chuck Copland, VP of Compliance Services, Tom Hinkel, and Chief Technology Officer, Brendan McGowan held a live panel discussion last week covering ways financial institutions can manage banking IT operations during a pandemic. In this blog, we’ll cover a few of the top questions from the panel:

1. How would you suggest making sure that remote access vendors are vetted quickly but thoroughly?

For many financial institutions, remote access was limited before the pandemic because this technology either didn’t support critical functions or wasn’t a priority at the time. Now, remote access is very important to continue business operations efficiently, and many community banks and credit unions are evaluating options for larger scale use. To do this effectively, you first need to consider all of the risks associated with remote access and the potential impact on your organization. This helps you get a quick baseline of the controls you’re going to require, which will then inform your vendor review.

While some institutions may be in a rush to get remote access tools up and running, it is important to stick to your normal vendor review process and take the time to thoroughly evaluate third-party risk. If you do have to sacrifice the integrity of your normal due diligence process and cut some corners to choose a vendor quickly, understand that there will be a resulting change in your institution’s risk appetite, or your acceptable risk. Make sure this is updated and that the executive management team including the Board sign off on the your new risk appetite.

2. What are some lessons learned about remote access for financial institutions during this pandemic?

It can be difficult to determine which remote access tool fits best with your institution’s unique security and regulatory needs. First, you should identify the best way for your staff to access the network whether it’s through a virtual private network (VPN) or an application for remote access, like a telecommute remote control tool. A VPN is a piece of software that lives on a computer that your user has at home — preferably a bank or a credit union asset and not their personal home PC.

When a user connects through a VPN tunnel, typically the computer gives access to the local network at the institution. With telecommute remote control tools, like LogMeIn and Splashtop, the user is working from a local computer at the office. These tools limit the abilities of the computer from interacting with the institution’s local network, often, making it a secure option for organizations that don’t want employees to have direct access to the network. Because each tool achieves a different goal, you will want to determine exactly what your team needs to conduct remote work efficiently, effectively, and securely.

There are also several collaboration tools and meeting tools to consider which can help different teams within your institution communicate and collaborate on projects internally and meet with each other or speak with external users outside of your organization.

What are you hearing from examiners? How are exams continuing during the pandemic?

We’re seeing that all examinations have either been pushed back to a later date or changed to a remote visit. In the climate that we are in, examiners are expecting institutions to make accommodations to customers that may be negatively affected by this pandemic and ensure they have access to other critical products and services.

But what happens when the dust settles, and we go back to a more normal set of circumstances? What will examiners expect then?

Most likely, we expect them to be looking for a mature “lessons learned” document that financial institutions create to show what they have learned over the course of this particular pandemic event. We can certainly see guidance changes coming out of this, with regulators having a new set of expectations for financial institutions going forward. Right now, we are all concerned with just getting through this challenging time but all financial institutions need to document what they are doing and the lessons they have learned along the way. They also need to create a report for the Board and the executive management team recommending any necessary changes to mitigate the impact of a pandemic, should one happen again in the future.

If you’d like to find out what other questions were answered during the live panel, watch our recorded webinar, “Ask Our Experts: Managing Banking IT Operations During a Pandemic.”

16 Apr 2020

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

Building a Pandemic Response Plan: What Are the Requirements for Community Banks and Credit Unions?

As COVID-19 continues to spread around the world, financial institutions have been forced to respond to this pandemic in new and innovative ways to stop the spread of the virus; protect their employees and the public; and keep their doors open and operations running smoothly to serve their customers and members. Community banks and credit unions are referencing the Pandemic sections of their business continuity management plans to determine the best way forward for their institutions during this challenging time. With the Federal Financial Institution Examination Council’s (FFIEC) recent business continuity management (BCM) guidance, many financial institutions are first of all wondering what has changed in the guidance, and second what specific additional changes this particular event might require.

Pandemic Planning

Since 2007, financial institutions were required to have a separate pandemic plan, and regulators only looked for documentation that institutions were testing their plans periodically. Unfortunately, the pandemic section of the business continuity plan (BCP) has tended to be treated as more of an afterthought since these situations have historically occurred much less often than natural disasters or other business interruptions. If they were assessed at all, they fell into the category of a high impact, low probability event.

Notwithstanding COVID-19, pandemics are still low probability events, but the impact of these events may be far more significant than past risk assessments have indicated. In what may now be perceived as an untimely move, the FFIEC made the decision in the 2019 BCM update to deemphasize Pandemic by categorizing it the same as any other disruptive event. The FFIEC no longer requires financial institutions to have a separate pandemic plan, but instead expects community banks and credit unions to assess and manage pandemic risk alongside all other possible disasters.

In other words, your BCM plan is your pandemic plan, and you must analyze the impact a pandemic can have on your organization; determine recovery time objectives (RTOs); and build out a recovery plan. You must also include a methodology to determine the key triggers your organization will use to activate your recovery plan when faced with a pandemic. But when should you activate your recovery plan and who is in charge of this process?

Pandemic Response

Before a recovery plan is activated, it is important to have an initial response team (typically comprised of C-Level executives) evaluate the situation and assess the potential impact of the current event on the institution. The team must determine if the situation is likely to negatively impact the institution’s ability to provide products and services to their customers or members beyond the established recovery time objectives outlined in the BCM plan.

The same rules apply in a pandemic. Community financial institutions should use the six pandemic phases outlined by the World Health Organization (WHO) or the Center for Disease Control (CDC) to evaluate the severity of the situation.

In most cases, the pandemic portion of the plan is not triggered for activation until phases 4-5 (or if between 20-40% of your workforce is not available to work).

What Regulators Expect

During a pandemic, regulators expect financial institutions to continue offering products and services to customers/members and conduct operations as normally as possible. This underscores the importance of including succession planning and cross training in the BCM plan. In the past, assumptions used to simulate a pandemic were that phases 4-5 wouldn’t last more than a week or two, so most financial institutions may only have planned for one person to be identified and pre-trained to step into a critical role until the event was over. However, the COVID-19 pandemic is a global crisis currently impacting at least 183 countries and territories and is predicted to impact many more people, and take much more time to contain.

To ensure critical functions continue, financial institutions should have at least two or three alternate staff members trained for every primary resource within the institution and assess whether some roles can be performed remotely. This can be difficult for smaller institutions with limited staff and resources. For specialized functions dominated by key personnel, such as funds management, wire services, human resources, etc., these institutions may not have multiple alternatives to step in if key employees are unavailable. In these circumstances, you may need to have other cross-trained staff members identified who can step into these roles quickly.

Next Steps: Lessons Learned

There will be many more lessons learned after the COVID-19 pandemic has passed, and regulators will expect those lessons to be reflected in your plan. When all is said and done, regulators are likely to ask “what have you learned from this event, and what have you done to enhance your pandemic plan based on those lessons learned?” Prior to this event, had you analyzed your business processes and their interdependencies, and prioritized them by recovery time? Since interdependencies include employees, and pandemic events almost exclusively impact personnel, have you identified employees with job duties capable of being performed remotely? If so, did they have secure, reliable, remote access? If those job duties are highly specialized, or highly critical, did you have alternate personnel identified and pre-trained to step in when needed?

The answers to these questions, and many more, will be used to enhance the pandemic section of your BCM plans, but until we reach that post-event, lessons-learned point, it’s important for financial institutions to continue to reference their business continuity plans; document the entire process; keep stakeholders informed; and put measures in place to continue serving their customers and members and protecting their employees and the public.

For more information on pandemic response, view our pandemic resource center. Or, if you would like to make sure your BCM is up to date, please request a complimentary plan review to ensure that your business continuity management plan is keeping up with changing regulations.

View Our Pandemic Resources

09 Apr 2020

Banks, Compliance, Credit Unions Christine Ray 0 comment

American Pride Bank Tackles Information Security Responsibilities with Safe Systems’ ISOversight Virtual ISO Solution

With ongoing cybersecurity threats; increased use of third-party providers; and constantly evolving regulatory and reporting requirements, the role of the information security officer (ISO) is even more important in today’s complex banking environment than ever before. However, community bank and credit union ISOs often struggle to keep up with the growing number of responsibilities this role requires – often forced to manage critical tasks with limited resources and a lack of segregation of duties.

The Challenge

Nicole Rinehart, Chief Operations Officer at American Pride Bank, ran into this very issue as the sole IT admin at American Pride Bank. Managing all of the ISO responsibilities, including critical activities such as Board reporting and the production of comprehensive reports for examiners, was difficult to manage due to the many manual processes required.

During a regulatory examination, an examiner recommended the bank focus on having more independence within its ISO duties. The Federal Financial Institution Examination Council (FFIEC) states that all financial institutions must have separation of duties for the ISO role. To accomplish this, the bank began evaluating solutions to help streamline processes and ensure complete oversight of all information security activities.

The Solution

After consideration, American Pride Bank decided to partner with Safe Systems and implement its ISOversight virtual ISO solution. The service includes a suite of applications and programs to help institutions streamline management of key compliance duties including the CAT, BCP, Vendor Management and Information Security.

In this case, the bank was already leveraging individual components of ISOversight. By converting to the virtual ISO service, they gained additional tools, reports, and expert compliance support. An important part of the solution includes monthly meetings with the Safe Systems compliance team to assess the bank’s information security activities and provide guidance.

The Results

With ISOversight, American Pride Bank has improved its overall preparation and communication of the information security program. All key stakeholders in the bank have access to ISO-related items in real-time, and the information security program is more organized and streamlined, enabling the bank to save time on monitoring and reporting.

“The ISOversight solution has been a game-changer for our bank because now we have a robust process in place working with Safe Systems and a full committee of our team members to ensure all tasks are completed accurately and nothing slips through the cracks,” said Rinehart. “It’s so important to have a process like this, especially when you have limited resources. Safe Systems has truly become an extension of our internal team, helping us to stay on track with ISO responsibilities and ensuring we comply with all regulatory requirements.”

To learn more, read the full case study, “American Pride Bank Streamlines Processes and Improves Compliance Reporting with Safe Systems’ ISOversight Virtual ISO Solution.”