Effectively Utilizing the New FFIEC Cybersecurity ... · 10/20/2015  · •Cyber risk management...

Effectively Utilizing the New

FFIEC Cybersecurity

Assessment Tool

Michael Barnsback, Esquire

and

David Reed, Esquire

October 20, 2015 1

Your Presenters

David Reed, Esq.

Partner

Reed & Jolly, PLLC

David@reedandjolly.com

Michael Barnsback, Esq.,

CIPP/US

LeClairRyan

Michael.Barnsback@lecla

irryan.com

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The contents of this presentation are intended

to provide you with a general understanding

of the subject matter. However, it is not

intended to provide legal, accounting, or other

professional advice and should not be relied

on as such.

Any views or opinions expressed are those of

the presenters and do not necessarily reflect

the views of NAFCU.

Overview

• Assessment is an all hands on deck

exercise

• Not simply an IT issue

• Establishing the responsibility and

accountability of key stakeholders is

essential to success

• Assessments, audits and examinations

are different processes

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Know Your Credit Union

• Understand your cyber footprint

– Products, services and delivery mechanisms

– All areas are impacted by internet access or

remote access

– In-house versus outsourced IT services

• Recent GAO Study and

Recommendations

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Polling Question

• Do you have a complete network map that

shows all of your devices, networks, IP

addresses, controls, end users and

vendors?

a. Yes

b. No

c. Working on it now

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What We Know • Increasing volume and sophistication of cyber

threats

• Existing cyber security vulnerabilities are known

• New remote platforms create new opportunities for cyber attacks

• Bad guys evolve as they observe online behavior

• Evolving malware risks

• Government sponsored cyber attacks

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Recent NCUA Guidance

• January 15, 2015, NCUA Letter No.: 15-CU-01,

provided guidance to CU Boards of Directors and

Chief Executive Officers on the NCUA

examinations in 2015

• The first item in the guidance letter: Cybersecurity

• “In 2015, NCUA will redouble efforts to ensure that

the credit union system is prepared for a range of

cybersecurity threats.

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Recent NCUA Guidance

• Guidance letter identified 6 “proactive measures credit unions can take to protect their data and their members: – encrypting sensitive data;

– developing a comprehensive information security policy;

– performing due diligence over third parties that handle credit union data;

– monitoring cybersecurity risk exposure;

– monitoring transactions; and,

– testing security measures.”

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What Is the FFIEC?

• The FFIEC comprises key representatives of

The Board of Governors of the Federal

Reserve System, Federal Deposit Insurance

Corporation, National Credit Union

Administration, Office of the Comptroller of

the Currency, Consumer Financial Protection

Bureau, and State Liaison Committee (for

state banks and credit unions)

• When they speak, our world listens!

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FFIEC Risk Assessment Tool

• Goal is to help institutions identify their risks and determine their cybersecurity preparedness (maturity)

• Assessment Tool provides a repeatable and measurable process for institutions to measure their cybersecurity preparedness over time

• Draws heavily on other sources, including:

– FFIEC Information Technology (IT) Examination Handbook

– National Institute of Standards and Technology (NIST) Cybersecurity Framework

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Is It Voluntary?

• Existing IT Security Requirements and

Guidance

• Part 748 NCUA Regulations

• FFIEC IT Examination Handbook

• AIRES Examination Questionnaires

• Two part logic: Internal value and

examination value

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Assessment Overview

• Make sure you have ALL the tools before

you initiate the assessment

– Overview for CEOs and Boards

– User’s Guide

– Assessment Tool

– CS Maturity Scale and Inherent Risk Profiles

– Appendices A and B

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Polling Question

• Does your CU have a bring your own

device policy?

a. Yes

b. No

c. Maybe

d. Working on one

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A Tale of Two Parts

The Assessment Tool consists of two parts

1. Inherent Risk Profile

2. Cybersecurity Maturity

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5 Risk Profile Levels

Least

Inherent

Risk

Minimal

Inherent

Risk

Moderate

Inherent

Risk

Significant

Inherent

Risk

Most

Inherent

Risk

Risk Levels incorporate the type, volume, and

complexity of the credit union’s operations and

threats directed at the institution.

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Let’s Begin

• To complete the Assessment,

management first assesses the credit

union’s Inherent Risk Profile based on five

categories:

– Technologies and Connection Types

– Delivery Channels

– Online/Mobile Products and Technology

Services

– Organizational Characteristics

– External Threats 17

All images from FFIEC CS Overview

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Technologies and Connection

Types

• “This category includes the number of

Internet service provider (ISP) and third-party

connections, whether systems are hosted

internally or outsourced, the number of

unsecured connections, the use of wireless

access, volume of network devices, end-of-

life systems, extent of cloud services, and

use of personal devices.”

• Key Stakeholders: Information Technology

Source: FFIEC Cybersecurity Assessment Tool

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Delivery Channels

• “This category addresses whether

products and services are available

through online and mobile delivery

channels and the extent of automated

teller machine (ATM) operations.”

• Key Stakeholders: IT, card services,

service delivery, ATM, operations, etc.

Source: FFIEC Cybersecurity Assessment Tool

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Online/Mobile Products and

Technology Services

• “This category includes various payment services,

such as debit and credit cards, person-to-person payments, originating automated clearing house (ACH), retail wire transfers, wholesale payments, merchant remote deposit capture, treasury services and clients and trust services, global remittances, correspondent banking, and merchant acquiring activities. This category also includes consideration of whether the institution provides technology services to other organizations.”

• Key Stakeholders: IT, card services, payment systems, ACH, wires, deposits, trusts (CUSO), merchant services or business services, etc.

Source: FFIEC Cybersecurity Assessment Tool

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Organizational Characteristics

• “This category considers organizational

characteristics, such as mergers and acquisitions, number of direct employees and cybersecurity contractors, changes in security staffing, the number of users with privileged access, changes in information technology (IT) environment, locations of business presence, and locations of operations and data centers.”

• Key Stakeholders: CEO, HR, IT, service delivery, operations, etc.

Source: FFIEC Cybersecurity Assessment Tool

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External Threats

• “The volume and type of attacks

(attempted or successful) affect an

institution’s inherent risk exposure. This

category considers the volume and

sophistication of the attacks targeting the

institution.”

• Key Stakeholders: IT, security, BSA

officer, etc.

Source: FFIEC Cybersecurity Assessment Tool

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It Rhymes! Cybersecurity Maturity

After determining the Inherent Risk Profile, the credit union transitions to the Cybersecurity Maturity part of the Assessment to determine the institution’s maturity level within each of the following five domains:

– Domain 1: Cyber Risk Management and Oversight

– Domain 2: Threat Intelligence and Collaboration

– Domain 3: Cybersecurity Controls

– Domain 4: External Dependency Management

– Domain 5: Cyber Incident Management and Resilience

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Domain 1: Cyber Risk

Management and Oversight • Cyber risk management and oversight

addresses the board of directors’ (board’s) oversight and management’s development and implementation of an effective enterprise-wide cybersecurity program with comprehensive policies and procedures for establishing appropriate accountability and oversight.

• Key Stakeholders: Board, CEO, IT, security (BSA), HR, CFO, internal audit, risk manager, etc.

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Polling Question

• What types of third party IT vendors does

your credit union utilize?

a. Network Administrator

b. IT Security

c. Penetration testing

d. Cloud applications

e. All of the above

f. More than one of the above

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Domain 2: Threat Intelligence and

Collaboration

• Threat intelligence and collaboration

includes processes to effectively discover,

analyze, and understand cyber threats,

with the capability to share information

internally and with appropriate third

parties.

• Key Stakeholders: IT, security (BSA), third

party resources, etc.

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Domain 3: Cybersecurity Controls

• Cybersecurity controls are the practices

and processes used to protect assets, infrastructure, and information by strengthening the institution’s defensive posture through continuous, automated protection and monitoring.

• Key Stakeholders: SC, IT, security (BSA), internal audit, facilities, operations, branch, third party resources, etc.

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Domain 4: External Dependency

Management

• External dependency management involves

establishing and maintaining a

comprehensive program to oversee and

manage external connections and third-party

relationships with access to the institution’s

technology assets and information.

• Key Stakeholders: CEO, IT, vendor

management, security, internal audit, legal,

external resource (?)

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Domain 5: Cyber Incident

Management and Resilience • Cyber incident management includes establishing,

identifying, and analyzing cyber events; prioritizing

the institution’s containment or mitigation; and

escalating information to appropriate stakeholders.

Cyber resilience encompasses both planning and

testing to maintain and recover ongoing operations

during and following a cyber incident.

• Key Stakeholders: Board, IT, business continuity,

security (BSA), internal audit, facilities, operations,

branch, third party resources, etc.

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How Mature Are You?

• Each domain and maturity level has a set of declarative statements organized by assessment factor.

• It looks like this:

Domains

Assessment Factors

Components

Declarative Statements

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Work Through the Assessment

• Within each domain are assessment

factors and contributing components.

• Under each component, there are

declarative statements describing an

activity that supports the assessment

factor at that level of maturity.

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Domains and Assessment Factors

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Definition and Assessment Factors

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Maturity Levels

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Example of Maturity Assessment

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Bringing It Together

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Third Party Vendors

• It is always advisable to understand the

benefits and risks of third party IT

specialists

• Specialized due diligence and analysis

• Arms length transactions

• Contract language

• Regular communication and reporting

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The Moving Parts of Security

• Part 748 Security Program

• Part 748.1 Filing of Reports

– Compliance Report

– Catastrophic Act

– Suspicious Activity Report

• Part 748.2 BSA Compliance

– Establish a compliance program

– CIP

• Appendix A Safeguarding Member Information

• Appendix B Response Program – Unauth. Access

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The Certification

“The chairperson of the Credit Union’s Board of Directors is required to certify compliance with Part 748 each year. The statement of compliance is provided at the bottom of the Credit Union Profile Form that is submitted annually to the regional director following the credit union’s election of officials.”

Source: NCUA CU Profile Form 6/14

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I hereby certify to the best of my knowledge and belief that this credit union has developed and administers a security program that equals or exceeds the standards prescribed by Part 748.0of the NCUA Rules and Regulations; that such security program has been reduced to writing, approved by this credit union's Board of Directors; and this credit union has provided for the installation, maintenance, and operation of security devices, if appropriate, in each of its offices. Further, I certify that I am the president or managing official of the credit union or that the president or managing official has authorized me to make this submission on his/her behalf.

______________________________________________

VOLUNTEER’S NAME HERE

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Questions?

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