13 May 2021

Banks, Compliance, Credit Unions Safe Systems 0 comment

Is Your Financial Institution BCM Compliant?

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

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

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

In case you missed the full blog, view it here

06 May 2021

Banks, Credit Unions, Technology Marshall Jones 0 comment

After the Disaster: Real Community Banking Recovery Stories

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

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

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

Real DR Stories from Community Banks

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

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

Community Bank in Alaska Shares Insights

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

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

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

29 Apr 2021

Banks, Credit Unions, Technology Marshall Jones 0 comment

The 4 “Rs” of Disaster Recovery

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

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

RTO

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

RPO

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

Replication

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

Recurring Testing

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

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

22 Apr 2021

Banks, Compliance, Credit Unions Marshall Jones 0 comment

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

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

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

The Need for a Comprehensive DR Solution

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

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

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

Essential Aspects of a DR Service

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

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

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

15 Apr 2021

Banks, Credit Unions, Technology Jamie Davis 0 comment

Latest Microsoft Updates Show Importance of Patch Testing

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

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

Importance of Patch Testing

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

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

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

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

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

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

08 Apr 2021

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

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.

02 Apr 2021

Banks, Credit Unions, Security Brian Brannon 0 comment

Is Cybersecurity Your Weakest Link?

SKIP AHEAD:

Importance of Being Secure
Malware and Ransomware
Internet of Things (IoT) Attacks
Phishing Scams
Lack of Third-Party Vendor Security
Insider Threats
Lack of Employee Training and Security Expertise
Combating Security Threats and Ensuring Institution Security
Managing Security Needs

Is Cybersecurity Your Weakest Link?

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

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

Importance of Being Secure

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

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

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

Malware and Ransomware

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

Internet of Things (IoT) Attacks

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

Phishing Scams

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

Lack of Third-Party Vendor Security

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

Insider Threats

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

Lack of Employee Training and Security Expertise

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

Combating Security Threats and Ensuring Institution Security

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

A uniquely tailored layered security approach enables financial institutions to:

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

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

Managing Security Needs

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

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

01 Apr 2021

The Security Evolution Featured Blog Image

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

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

The Security Evolution Featured Blog Image

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

Importance of Resilience

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

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

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

Compliance and IT Security Integration

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

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

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

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

Third-party Management

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

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

25 Mar 2021

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

The ISO in 2021: New Challenges and Expectations Require a New Approach

The ISO in 2021 Featured Image

One of the key lessons financial institutions learned from the COVID-19 pandemic is that regardless of new challenges and seemingly constant change, they were expected to ensure their customers and members continued to receive products and services uninterrupted. The past 13 months (and counting) have been a live exercise in operational resilience.

The current crisis—perhaps more than any even prior—has underscored the true scope of the Information Security Officer’s job. Technically, there are only eight broad areas of responsibility for ISOs outlined in the Federal Financial Institution Examination Council (FFIEC) IT Handbook’s Management booklet. But the actual scope of ISO accountability spans at least 36 elements. One of the key challenges and responsibilities of the ISO is stakeholder reporting, which is intricately linked to accountability. The relationship between responsibility and accountability is that while the ISO is responsible for making sure critical InfoSec tasks are completed, they are also accountable to the various stakeholder groups, which requires providing documentation that a task is being completed a certain way, with a certain group, or with a certain frequency.

To meet their accountability obligations, because information security is pervasive, ISOs must be engaged at all levels across the enterprise and in all lines of business. This requires understanding every place that data is stored, processed, or transmitted—whether it involves a customer or member, employee, or vendor. The ISO also needs to be aware of the latest emerging risks and be able to implement an effective mitigation strategy. Ultimately, ISOs need to be effective at translating information to the board, management committee, and IT auditors and examiners, in a manner in which these various stakeholders are best able to consume and comprehend it.

The expectations for ISOs also extend beyond the traditional area of ensuring the confidentiality, integrity, and availability of data. ISOs are also responsible for minimizing the disruption or degradation of critical services—which has emerged as the more urgent necessity during recent pandemic and cyber events.

Some of the early challenges ISOs faced during the pandemic ranged from the technical, such as securing virtual private network access, to the administrative, such as ensuring that employees have signed acceptable-use policies and remote-access agreements. Fortunately, we’ve found that most institutions adjusted well to the initial hiccups, resulting in minimal degradation in their services. However, cybersecurity promises to keep that pressure on for the foreseeable future, even post-pandemic.

Predictably, financial institutions are now seeing more exam scrutiny in three areas.

Business Continuity Management (BCM)

When the FFIEC implemented a BCM update in 2019, it created new terminology and new expectations that are finally beginning to emerge in exam findings.

Strategic Planning

The expectation for additional strategic planning is calling for more formal project management procedures. On the IT examination side, FIs are receiving requests for “pre-initiative” risk assessments, meaning that ISOs are expected to assess the risks of a project or initiative before they even agree to move forward and select a vendor. The FFIEC’s Development and Acquisition Handbook states that “Poor planning often contributes to projects failing to meet expectations.” This early stage is referred to as the “initiation” or “feasibility” phase of the project. Once the project clears this phase and moves forward, a vendor or vendors are selected, and vendor due diligence and on-going management can proceed. As the project proceeds to completion, management should be kept informed.

Board and Committee Reporting

Which is now focusing on not just what gets reported, but the frequency of the reporting as well. Suffice to say that the traditional annual updates won’t get it done going forward.

A New Approach to Virtual ISO Services

With ISOs being forced to wear multiple hats, some institutions are choosing to leverage a virtual ISO solution. Whether outsourced, insourced, or a hybrid virtual ISO model, each offers varying levels of service, flexibility, and support. Further still, several FIs are leveraging technology in tandem with security expertise to support their ISOs.

Safe Systems’ ISOversight is a proven risk management solution that provides complete and comprehensive accountability for the responsibilities of the ISO position. This third-party solution assigns a dedicated ISO oversight lead who understands the details of the institution’s environment and provides institutions with expert guidance and access to additional resources. ISOversight is an ideal asset for new (or frankly, overwhelmed) ISOs that may be struggling to keep up with the complex responsibilities of their position. And now with federal and state examiners tightening their level of scrutiny, ISOversight is proving even more crucial for institutions that need to enhance their information security expertise.

To learn more about how Safe Systems is supporting ISOs in the industry, listen to our webinar on “The ISO in 2021: A New Approach to New Challenges and Expectations.”

18 Mar 2021

Banks, Credit Unions, Security Jamie Davis 0 comment

Top Phishing Scams and Emerging Trends Your Bank or Credit Union Staff Should Be Aware of

Phishing—the practice of using fake emails and other schemes to obtain sensitive information or data, such as usernames, passwords, or credit card details—continues to be one of the most prevalent security threats today. This blog covers some of the top phishing scams, as well as some new trends, that banks and credit unions should know about, so they can better protect themselves.

Top Scams

One of the most widespread and potentially devastating types of phishing scams is “impersonation phishing,” according to the Q1 2021 Financial Crime Report by Feedzai, a data science company that prevents, detects, and remediates fraud risk for financial institutions. With this tactic, cybercriminals target people by a phone, text, or email claiming to be from a financial institution or government agency. The objective: Convince the potential victim to make some kind of payment, which will enable the culprit to access the person’s credit card or financial account. Or the impersonator might send a “Suspicious Account Activity”’ email from a financial institution, asking the targeted individual to log into their online account and verify a transaction. Then when the person logs in using the button or link provided in the email, the attack ensues.

Spear phishing is another common con that financial institutions should have on their radar. Almost two-thirds of all known groups carrying out targeted cyber attacks use spear-phishing emails, according to Symantec’s 2019 Internet Security Threat Report. Many of these attacks originate from hijacked business email accounts, and as a result, can be quite effective. The perpetrator normally already knows some information about the recipient, so the fake emails appear to be legitimate.

Clone phishing, a variation of spear phishing, involves the attacker recreating or cloning a legitimate and previously opened email with a new attachment or link included. The duplicated email is then sent with an infected attachment that can be used to control or steal information once clicked or downloaded.

Top Emerging Trends

A new approach that banks and credit unions should know about is “vishing” (or voice phishing). Cybercriminals are now using Voice over Internet Protocol (VoIP) platforms to launch vishing attacks against employees worldwide, the FBI warns. In these cases, vishers try to get users of VoIP platforms to pick up the phone and authenticate themselves on a phishing website designed to steal their credentials. Vishing scams have now evolved to the point where perpetrators are successfully faking caller IDs and pretending to be someone else.

We are also seeing phishing scammers modifying their basic tactics. Many are now sending emails that simply ask for “urgent attention” rather than payment transfers, which suggests they are altering their approach to bypass standard fraud-prevention methods. They’re also using strategies like the “Zombie Phish” which involves taking over an email account and responding to an old email conversation with a new phishing link. Additionally, phishers have started using shortened URLs, which have an easier time getting past filters and vigilant employees.

As an evasive strategy, attackers link potential victims to the websites of trusted cloud filesharing services like SharePoint and OneDrive. Consider this: More than 5,200 SharePoint phishing emails were reported in a 12-month period, along with almost 2,000 attacks involving OneDrive, according to Cofense Intelligence’s Q3 2020 Phishing Review. More advanced phishing campaigns are also employing unusual attachment types to elude the controls imposed by secure email gateways. For example, .iso files are being renamed to .img files to sneak malware through a gateway.

Ultimately, the best defense against phishing is human intelligence, so training employees to detect this type of fraud is essential. Financial institutions can also take advantage of third-party information security services to strengthen their security posture against phishing attacks. Safe Systems, a national provider of fully compliant IT and security services, is enabling institutions to win the cyber battle against phishing through a full spectrum of solutions specifically designed to help community banks and credit unions enhance their security posture.

11 Mar 2021

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

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

It’s essential that banks and credit unions maintain segregation of duties between their information security officer (ISO) and network administrator to ensure network security, regulatory compliance, and the overall health of their operations.

From a regulatory standpoint, the separation (or segregation) of the ISO’s duties is the corrective action to a concentration of duties finding. Management should designate at least one information security officer responsible and accountable for implementing and monitoring the information security program, according to the Federal Financial Institutions Examination Council (FFIEC) IT Handbook’s Information Security booklet. The booklet states: “ISOs should report directly to the board or senior management and have sufficient authority, stature within the organization, knowledge, background, training, and independence to perform their assigned tasks. To ensure appropriate segregation of duties, the information security officers should be independent of the IT operations staff and should not report to IT operations management.”

The FFIEC also provides guidance on this matter in the IT Handbook’s Management booklet. “The institution should separate information security program management and monitoring from the daily security duties of IT operations. The IT department should have personnel with daily responsibility for implementing the institution’s security policy,” the booklet explains. “Responsibility for making changes and granting exceptions to policy should be segregated from the enforcement of the controls.”

Oversight Is the Key Issue

The importance of isolating the ISO’s duties comes down to oversight as separating the functions of the ISO and network administrator helps to create a clear audit trail and ensures that risk is being accurately assessed and reported to senior management. Without proper oversight reporting, financial institutions and their Boards lack a clear picture of their information security posture and can face other negative repercussions, such as downgrades in their Management IT component.

If, for instance, the ISO shares administrative duties and an administrator account, oversight dynamics can be undermined. As an example, the admin may have day-to-day responsibility for patch deployment, but the ISO is ideally suited to monitor and validate the overall patch management program—not the network administrator. The ISO has a higher-level, enterprise perspective of the impact of day-to-day activities; whereas the admin is at the ground level and may not always be capable of accurately assessing the full impact of performing, or not performing, a particular task. In addition, the definition of “oversight” is basically having another set of eyes validate the actions of someone else.

Understanding the Role and Duties of the ISO

The ISO’s oversight role primarily serves to ensure the integrity of a financial institution’s information security program. In essence, by segregating the admin/ISO duties, ISOs are the “other set of eyes” that help to maintain a level of accountability to management, the board, and other stakeholders.

The responsibilities of the ISO are clearly outlined in the FFIEC’s Information Security and IT Management booklets. Some of the ISO’s key duties include responding to security events by ordering emergency 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.

However, in fulfilling these obligations, ISOs are expected to continually meet a high standard of information privacy and security. It’s imperative for institutions to not only assign the proper responsibilities to the ISO but to also select the right individual to assume the role.

Banks and credit unions often have difficulty designating an ISO with the appropriate technical and regulatory compliance expertise. Institutions in rural or small communities—where the talent pool is meager—might even have their chief financial officer or chief operations officer wear the hat for this “part-time” job. Regardless of these challenges, community institutions are expected to maintain the same level of segregation of duties as larger institutions. Size and complexity considerations may allow for some leeway in the timing of the separation, but not the ultimate outcome.

Leveraging a Virtual ISO

For every responsibility, there is an associated piece or set of documentation that must be provided to demonstrate adherence to and alignment with your formal written procedures. Not having an ISO with the requisite knowledge and/or time to effectively manage the assigned responsibilities of the position can result in control failures—and possibly policy or procedure non-compliance. In some cases, financial institutions may have a separation of duties “on paper”, but not so in practice. Again, the absence or presence of oversight is the key.

In fact, feedback from examiners indicates that because of the lack of oversight, there is a certain level of concentration of duties that cannot be adequately addressed internally. But institutions can remedy this problem by engaging a third-party, virtual ISO to add assurance that all responsibilities are being successfully addressed. A virtual ISO can provide another set of eyes and an independent layer of oversight on top of what the institution already has in place internally.

Virtual ISO services from Safe Systems, a national provider of fully compliant IT and security services, can be the ideal solution for community banks and credit unions. Safe Systems has proven experience in providing institutions with dependable technical expertise to ensure there is adequate separation of ISO-related duties within their organization—enhancing network security and significantly increasing regulatory compliance.

04 Mar 2021

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

5 ISO Duties that Can Be Automated for FIs

Information security officers (ISOs) at financial institutions typically have myriad responsibilities on their plates, and each of those responsibilities comes with one or more forms of documentation to verify the actions taken. While these duties relate to the main categories of network security and regulatory compliance, there are a host of functions that fall under the ISO’s oversight role.

Fortunately, many ISO responsibilities can be automated in some areas to facilitate the management of the institution’s information security program. Here are five of them:

1. Business Continuity Management (BCM)

ISOs are responsible for overseeing and coordinating BCM, providing detailed guidance on how to recover from a business interruption, and ensuring that the appropriate people, processes, and technology components that make up the network of interdependencies are also restored. Automation can make it easier for the ISO to identify the interdependencies, complete the annual updates, and conduct the training exercises and testing required. Automation can also enable alerts for tasks due by process owners, and generate reminders for annual plan board approval, and report the test results to the board. While the tests for BCP cannot be automated, the documentation and reporting of the tests can—something that can significantly streamline the ISO’s oversight responsibilities and make it much easier to locate these documents at audit and examination time.

2. Updates to the Information Security Program and Information Security Risk Assessment

Automation can provide alerts to help ISOs keep abreast of updates from regulators. Then the ISO can easily pull reports on the revised areas to present them for board approval. Essentially, it’s plan maintenance that can be automated—although some interpretation is needed to support the process. Automation can prevent an institution’s information security program from becoming out-of-date (which can happen easily when an ISO is relying on manual processes for management) as failing to make an important update can have significant, negative consequences. For instance, if management misses a major BCP update, or an annual test, or board reporting, auditors may construe this as a general weakness in management, and scrutinize other areas more closely, such as lending practices or financial reporting. Automation can help institutions avoid inadvertent missteps and resulting hassles within their information security program.

In addition, many recent examination findings relate to inconsistencies between the institution’s policies (what they say they do) and their procedures (how they say they will do them). Automation, when combined with integration between applications, can greatly reduce this probability by easily propagating policy and procedural changes throughout all elements of your information security program. For example, sometimes financial institutions will update their BCM plan but might be lax with other policies—something that can result in a disconnect between different policies. In this case, one policy may refer to a process that is no longer being used; or a policy may contain conflicting references for a process that has been updated. These and other kinds of inconsistencies are virtually impossible to catch without automation and integration.

3. Tracking Audit Exam Findings

Unresolved, or “repeat” findings are usually treated very harshly by regulators. Making sure that all audit and exam issues are resolved in a timely manner is crucial. Automation can rate the severity, assign them to a responsible party, assign a due date for resolution, and sending “ticklers” and reminders as the dates come due. At the end of the process, the ISO can quickly generate reports to provide to the institution’s board, examiners, and other stakeholders. Alerts and on-demand reporting can enhance accountability for addressing each of the findings to improve internal controls and other areas.

4. Managing Third-party Relationships

Financial institutions are required to manage the risks of their third-party vendors and the responsibility to assure this is done falls squarely on the shoulders of the ISO. Institutions can use automation in every aspect of their vendor relationship management, including alerting and tracking of periodic updates to the risk assessments, annual updates to the control reviews, contracts, and contract renewals. With automation, the ISO can instantly identify required tasks and produce the necessary documentation related to its vendor management activities.

5. Cybersecurity

Cybersecurity is an important sub-component of information security, and automation can significantly enhance the ISO’s multiple oversight efforts in this area. An automated system can remind ISOs to verify that crucial assessments are completed, including the annual Cybersecurity Assessment Tool (CAT) and the Ransomware Self-Assessment Tool (R-SAT). Alerts can be scheduled to prompt ISOs to conduct annual incident response tests, a gap analysis, and cybersecurity training for employees and the board. And on-demand reporting can keep all stakeholders informed on the progress of your cybersecurity efforts.

One final thought about automation; when the application is combined with a provider familiar with, and dedicated to, the regulatory environment of the financial institution, you do not have to worry about a non-compliant policy or procedure. All necessary regulatory and best practice updates are built-in to the automation.

As a national provider of fully compliant IT and security services, Safe Systems offers a variety of innovative solutions that can help financial institutions automate some of the important responsibilities of their ISO.

25 Feb 2021

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

Five Key Areas of Focus for Your Regulatory IT Exam

Key Areas of Focus for Your Regulatory IT Exam

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

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

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

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

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

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

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

Ransomware on The Rise

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

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

Resiliency

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

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

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

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

23 Feb 2021

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

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

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

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

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

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

The Pre-examination Questionnaire

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

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

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

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

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

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

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

18 Feb 2021

Is Your FI Ready to Move to the Cloud? | Webinar Recap

Banks, Credit Unions, Technology Marshall Jones 0 comment

Webinar Recap: Is Your FI Ready to Move to the Cloud?

Is Your FI Ready to Move to the Cloud? | Webinar Recap

With organizations in virtually every industry employing cloud computing to enhance their infrastructure, cloud adoption is becoming mainstream. But is your bank or credit union ready to make the move to the Cloud?

Before you attempt to answer this question, start with why you should be considering the Cloud. There are significant benefits to using cloud-based solutions: guaranteed uptime; rapid scalability for expanding or reducing resources; flexibility for reprovisioning; and improved redundancy. Another important—but often undervalued—reason for moving to the Cloud is ease of use. The Cloud simply makes it easier for IT administrators to do their jobs and easier for financial institutions to manage infrastructure costs. Instead of buying, owning, and maintaining physical data centers and servers, institutions can procure IT resources over the Internet on an “as-needed” basis with true “pay-as-you-go” pricing. This kind of arrangement can be especially appealing to a de novo, a growing bank, or any institution wanting a more efficient, cost-effective way to manage IT-related expenses.

In addition, cloud systems offer the key advantage that they’re built from the ground up to cater to remote users. Bank and credit union employees can access the same tools, applications, and resources using the Internet whether they’re working on-site, from home, or in another location, making the Cloud the ideal tool for both remote work and collaboration.

Determining When to Make the Move

So how do you know if your financial institution is ready to move to the Cloud? The main indicator is whether management is supportive of the idea or feels implementation would be too burdensome. If your institution can’t manage the research, preparation, and challenges involved with cloud migration, it may not be the best time to make the transition.

One obvious sign that you are ready for the Cloud is if your organization is steadily growing and needing to augment resources. Perhaps you’re looking at expanding to new servers or rethinking your current architecture. Maybe it’s a situation where you’re tired of being stuck in a cycle of dealing with replacement projects for new servers. If you’re looking at replacing multiple servers that are running out of warranty, it could be the opportune time to move some of that workload up to the Cloud.

Transitioning Slowly

Moving to the Cloud can be a complex undertaking, but the good news is that your institution doesn’t have to make the leap all at once. In general, it’s best to be slow and methodical. This strategy can involve transferring one aspect at a time over several years. We are seeing a number of institutions start with moving their disaster recovery solution to the Cloud or using a “brick-by-brick” approach by migrating one or two servers at a time.

Don’t forget, the Cloud isn’t just a new tool, it’s a whole new world. Once your institution makes the jump to the Cloud, you need to monitor and manage the systems in the Cloud going forward. As with everything in IT, some adjustments may be needed over time. If you engage with a trusted partner for cloud services, they may be able to assist with your ongoing monitoring and management of your resources in the Cloud.

For more insights about cloud migration, watch our webinar on “Are You Ready to Move to the Cloud.”

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.

04 Feb 2021

Banks, Credit Unions, Security Greg Batore 0 comment

Does Your Financial Institution Have the Right Security Layers in Place to Combat Today’s Threats?

In 2020, 80 percent of firms experienced an increase in cyberattacks, and the pandemic was at the root of a 238-percent spike in attacks on banks, according to Fintech News. In a world of ever-increasing cyberattacks, does your bank or credit union have the appropriate security layers in place to effectively thwart these threats?

There are some proven, preemptive measures that financial institutions should take, including:

Effective Log Analysis

Logs record every activity and event that occurs on a network, providing valuable clues about potential performance, compliance, and security issues. But it can be challenging for an institution to analyze, manage, and tailor all the log data that it receives—which can exceed millions of lines in just a 24-hour period. Without sufficient data analysis tools, information technology (IT) professionals are severely limited. They have to depend on their own processing capabilities to manually analyze data, which can be a labor-intensive, mistake-prone task.

Effectively managing log analysis has become more problematic with shifts in the security landscape: the expansion of security features, increase in firewall complexity, rapid emergence of new security threats, and constant growth in endpoints. This creates a situation that no security team can effectively manage on its own without some level of automated log collection and analysis.

With this technology, firewall logs are sent to a device that deftly collects and interprets the data. Information is then displayed in a format that is more readable, searchable, and useful for security engineers. While this process can go a long way toward improving the gathering of raw data, institutions can do even more to enhance their log management by building in additional security layers through the automated threat identification.

Log analysis automation equips security professionals to more effectively receive alerts about current and possible threats. Many banks and credit unions have limited personnel and expertise available to analyze their vast amount of traffic logs manually. But automated log analysis allows institutions to maximize their resources by leveraging more advanced technologies, like artificial intelligence (AI), cloud-based computing, and big data to collect alerts more efficiently.

Improved Education and Continuous Improvement

Staff training and education are also an important aspect of solidifying an institution’s security posture, and institutions can employ a variety of tactics to ensure their employees are better able to interpret and respond to alerts. Bank tellers, loan officers, and administrative staff all benefit from informative seminars, brochures, and other learning opportunities. Information security operations personnel can improve simply by calling on experienced colleagues to share their expertise in a more informal exchange of information. These combined efforts can help institutions minimize the number of threats and manage their operations more efficiently on a daily basis.

Financial institutions must also commit to continuous improvement in regard to their firewall security. While enhancing log analysis is not an exact science, there is value in institutions asking targeted questions to help determine the need for specific enhancements to help ensure that the most actionable and best information is being presented to the individuals who need to review it.

Integrating Advanced Technologies

Additionally, banks and credit unions should leverage next-generation firewall (NGFW) features and other advanced technologies – like dynamic threat feeds – to optimize their security initiatives, helping ensure they allow “good” traffic in and keep “bad” traffic out while maintaining critical processes.

NGFWs also enable financial institutions to perform functions beyond that of a traditional firewall, including deeper inspections of transport layer security (TLS) and secure socket layer (SSL) encrypted traffic. The practice of “sandboxing” to physically or virtually segment a system, network, or entire environment creates a secure location to test and neutralize potential threats.

Learn more about how your institution can incorporate the right security layers to combat today’s threats by downloading our “Improving Security Posture Through Next-Generation Firewall Features” white paper.

28 Jan 2021

Banks, Technology Mike Bell 0 comment

Why De Novo Banks Should Choose the Cloud

De novo banks have enough to be concerned about as they struggle to get established: raising capital, selecting a core system and products, getting enough personnel in place—and keeping everything afloat until they begin to thrive. Opting for the Cloud is one of the most prudent decisions a de novo bank can make.

Ease and Speed

A key benefit of employing the Cloud is the ease and speed of implementation, which is especially advantageous for a de novo with a tight timeline to get up and running. The Cloud also affords a de novo the ability to choose technology solutions based on its unique specifications. Rather than trying to estimate and make provisions for future growth, the bank can select cloud services according to its current requirements and as the de novo grows or reduces its operation over years, it can make the necessary adjustments to fit. In a real-world scenario, if a bank needs the capacity to process more loans, a cloud provider can instantly ramp up to meet that demand.

Cloud services also provide de novos with the cost-saving flexibility to forgo extensive infrastructure investments upfront and help avoid the expense of maintaining and replacing outdated hardware over time. Working with a major cloud provider means de novos will always be using the latest and best technology. This supports more predictable technology costs, especially when working in tandem with a managed cloud provider that can minimize the need for retaining a larger IT staff.

Disaster Recovery

Financial institutions—no matter how new they are—must have a strategy in place for restoring their IT infrastructure, data, and systems following adverse events, such as natural disasters, infrastructure failures, technology failures, the unavailability of staff, or cyber attacks, according to the Federal Financial Institutions Examination Council (FFIEC) IT Handbook’s Business Continuity Management booklet.

When a de novo chooses the Cloud to support its banking system, it simplifies many of the typical aspects of disaster recovery (DR). Cloud-based DR allows institutions to replicate the data in their main offices and transmit it to a safe location that staff can access during a catastrophic event. Having continuous replication means there’s minimal lag time when switching from live to DR mode. Plus, the Cloud makes it easier for IT staff to go live, run tests, and complete tests more thoroughly. Ultimately, cloud services can help de novos go beyond merely addressing disaster recovery, to instituting steps for disaster avoidance.

Here are some other compelling reasons for de novos to embrace the Cloud:

Security: A de novo bank has access to more security resources with the Cloud, making it easier to incorporate the best practices that regulators expect. Major cloud providers like Microsoft, Google, and Amazon maintain an army of security experts; they simply can offer more robust security than small de novos can build on their own.
Compliance: Leading cloud vendors are well versed in regulatory compliance issues, and de novos that use managed cloud providers receive a comprehensive solution that can further enhance compliance and vendor management.
Flexibility: With cloud services, de novos not only gain the advantage of being able to manage their IT infrastructure from anywhere, but they also gain the capability to easily turn on/off cloud services allowing them to quickly explore new ideas or diagnose problems within their environment.

The simple truth is that a de novo bank could never build an IT infrastructure on par with what it can accomplish through the Cloud. And working with a managed cloud service provider like Safe Systems can make using the Cloud even easier, leaving bankers free to focus on banking.

14 Jan 2021

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

Looking Ahead to 2021: A Regulatory Compliance Update

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

Focus on Ransomware

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

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

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

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

What to Expect in 2021

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

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

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

08 Jan 2021

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

2020 in the Rearview: A Regulatory Compliance Update

The COVID-19 pandemic dominated the regulatory landscape early in 2020, with cybersecurity dominating the last couple of months. Here is a look back at important regulatory changes and trends in 2020 and a look ahead at what to anticipate for 2021.

Characterizing Causes of Weakness

When it became obvious that the pandemic would have a pervasive and wide-ranging effect, the Federal Financial Institution Examination Council’s (FFIEC) issued several statements to address the situation. The FFIEC outlined some of the adjustments and accommodations that regulators expect bankers to make concerning lending, operational risks, and other areas. For instance, if an exam results in downgrading component or composite ratings for an institution, a distinction will be made between any weakness caused by the pandemic vs. management and governance issues.

Essentially, examiners will differentiate between a weakness resulting from an external event versus an internal systemic issue—even if the event is beyond management’s control.

The statement issued in June 2020, states, “Examiners will consider whether institution management has managed risk appropriately, including taking appropriate actions in response to financial and operational stresses caused by COVID-19 impacts.”

It is uncertain exactly how this issue will be interpreted in a post-pandemic world. After all, pandemic should be a part of all financial institutions’ business continuity planning, and as such, not completely outside the realm of a reasonably anticipated threat. So ideally management should have anticipated such an event, and have been prepared to respond. The only unanticipated aspect of the current Covid 19 event is the extreme extended duration compared to a standard Pandemic. It will be interesting to see how the agencies square the concepts of a “reasonably anticipated threat” vs. “external factors beyond management’s control”. Aren’t most threats both reasonably anticipated, and also beyond management’s control? We’ll let you know if and when we get any clarification on that.

Regardless of the scenario, documentation is crucial and often overlooked. Most folks are laser-focused on just getting past this and back to “normal” business, but memories fade over time, and documenting what adjustments you’ve made (or plan to make) during the pandemic will make the post-pandemic adjustments easier to explain to management and justify to examiners. Documentation can also help establish your increased ability to anticipate and respond to the next threat, also referred to as “resilience”. Institutions should make every attempt to document all management decisions, such as the minutes from management meetings, communications with third-parties, and any strategic or procedural changes you may have made or need to make. For example, if you’ve implemented technology to enable an increased mobile workforce (a strategic change), have you updated the remote access procedures and best practices in your employee Acceptable Use Policy accordingly (a procedural change)? Have all remote employees signed the updated AUP?

In our next blog post, we will dive into the focus on ransomware mitigation, how best to address cybersecurity, and what to expect heading into 2021.

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.

02 Jul 2020

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

Keys to Develop a Compliant Business Continuity Management Program

Financial institutions (and examiners) are still adjusting to the Federal Financial Institution Examination Council’s (FFIEC) 2019 update to its BCP IT Examination Handbook. The handbook, now renamed Business Continuity Management (BCM), included several updates to the previous 2015 guidance. According to the FFIEC, BCM is the process for management to oversee and implement resilience, continuity, and response capabilities to safeguard employees, customers, and products and services.

To ensure financial institutions do this effectively, the FFIEC expanded the original BCM process.

The previous handbook encouraged institutions to adopt a four-step approach:

Business Impact Analysis

Risk Assessment

Risk Management (essentially, recovery procedures), and

Risk Monitoring and Testing

The new guidance recommends a slightly different approach:

Risk Management (Business Impact Analysis, Risk/Threat Assessment)

Continuity Strategies (Interdependency Resilience, Continuity and Recovery)

Training & Testing (aka Exercises)

Maintenance & Improvement

Board Reporting

Additionally, the business continuity management process outlines 10 key steps financial institutions must complete to achieve a more enterprise-wide approach and meet examiner expectations. This is a bit more complicated than the process has been in the past and may require more time for plan preparation and annual maintenance.

The FFIEC handbook also provides a more detailed break-down of the BCM lifecycle:

Oversee and implement resilience, continuity and response capabilities

Align business continuity management elements with strategic goals and objectives

Develop a business impact analysis to identify critical functions, analyze interdependencies, and assess impacts

Conduct a risk assessment to identify risks and evaluate likelihood and impact of disruptions

Develop effective strategies to meet resilience and recovery objectives

Establish a business continuity plan that includes incident response, disaster recovery, & crisis/emergency management

Implement a business continuity training program for personnel and other stakeholders

Conduct exercises and tests to verify that procedures support established objectives

Review and update the business continuity program to reflect the current environment and

Monitor and report business resilience activities.

As many of these items were part of the previous guidance, here is a checklist consisting of required elements that may be missing from your program:

Have you conducted a formal business process-based Business Impact Analysis (BIA) that identifies all critical interdependencies?

Does the BIA produce sufficient information to establish the following?

Recovery point objectives (RPO)

Recovery time objectives (RTO) for each business process (prioritized)

Maximum tolerable (or allowable) downtime (MTD/MAD)

Does your risk/threat assessment measure both the impact and the probability (likelihood) of potential disruptive threats, including worst case (low probability, high impact) scenarios?

Do you use testing as employee training exercises to verify that personnel are knowledgeable of recovery priorities and procedures?

Do you track and resolve all issues identified during testing exercises, and use lesson-learned to enhance your program? (Must be documented)

Does your Board report include a written presentation providing the BIA, risk assessment, and exercise and test results, including any identified issues?

If you would like to make sure your BCM is up to date with the latest regulatory expectations, a complimentary plan review is the best place to start.

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.

21 May 2020

Banks, Compliance, Credit Unions Jamie Davis 0 comment

The Value of Network Reporting for Community Banks and Credit Unions

With increased cyber-attacks, shared data with third-party vendors, and strict regulatory requirements, community banks and credit unions have high standards to meet for information security. Adequate oversight and network reporting on the information security program is needed to ensure the proper controls are in place and that all stakeholders have visibility into the network.

In a recent webinar, Safe Systems shared some key observations on the need for financial institutions to have better communication and reporting between IT staff, the compliance department, and senior management. Here are a few key points to consider:

Gaps Between IT Staff and ISO/Compliance Teams

In many financial institutions, there is a lack of synergy and communication between the IT department and the information security/compliance team. Many ISOs simply do not have the technical background to fully understand how information is being protected. They tend to be more focused on vendor management, business continuity management, and performing risk assessments and less familiar with how systems are getting patched; if machines have antivirus; or if backups are updated consistently. It can be difficult to communicate effectively if ISOs don’t understand the IT world or don’t have visibility into network reports and the necessary information to do their job.

Oversight to Better Manage Controls

Because bank and credit union IT staff are human, sometimes errors will occur. While financial institutions have many technology solutions that automate IT functions and controls, oversight is required to ensure that the controls are adequate, working, and therefore mitigating risks. Without appropriate oversight, any gaps in the network can lead to a successful cyber-attack. Similarly, a finding during an exam that shows certain controls were implemented ineffectively can also leave the institution vulnerable.

Limited Access to Reports

Too often, when ISOs conduct a review of the information security program, the reports they receive are vague or too technical to decipher the key insights most important to the ISO role. Other key stakeholders, like the Board and senior management, also may need more access to high-level reports to better identify threats, assess risk, and make decisions on the appropriate controls to implement.

Without access to adequate reports, the ISO and other stakeholders can become overly reliant on the IT team to explain what is happening on the network without having the ability to verify that information independently.

To learn more about information security reporting and get a demo of our NetInsight ™ cyber risk reporting tool, watch our webinar, “NetInsight: Trust But Verify.”

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