Understanding the FFIEC Cybersecurity Assessment Tool

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FFIEC Cyber Security

Assessment Tool

Overview and Key

Considerations

Agenda

Overview of assessment tool

Review inherent risk profile categories

Review domain 1-5 for cyber security maturity

Summary of risk/maturity relationships

Overview of use case performed

Final thoughts Q&A

Overview of FFIEC Cybersecurity Assessment Tool

Benefits to Institutions

Identifying factors contributing to and determining the institution’s overall cyber risk

Assessing the institution's cybersecurity preparedness.

Evaluating whether the institutions cybersecurity preparedness is aligned with its risks

Determining risk management practices and controls that could be taken to achieve the institutions desired state of cyber preparedness

Informing risk management strategies.

Not just for Finance!

Don’t tune out if your not in the financial services sector!!

Throughout the presentation you can see that risk assessment and preparedness is a major theme in any industry. Feel free to ask particular questions about your company and industry.

Inherent Risk Profile

Inherent Risk Profile Categories

Technologies and Connection Types

Delivery Channels

Online/Mobile Products and Technology Services

Organizational Characteristics

External Threats

Inherent Risk Profile – Risk Levels

Inherent Risk Profile Excerpt

Inherent Risk Profile

Technologies and Connection Types

Internet service providers

Third party connections

Internal vs outsourced hosted systems

Wireless access points

Network devices

EOL Systems

Cloud services

Personal Devices

Inherent Risk Profile

Delivery Channels

Online and mobile products and services delivery channels

 ATM operations

Inherent Risk Profile

Online/Mobile Products and

Technology Services

Credit and debit cards

P2P payments

ACH

Wire transfers

Wholesale payments

Remote deposit

Treasury and trust

Global remittances

Correspondent banking

Merchant acquiring activities

Inherent Risk Profile

Organizational Characteristics

Mergers and acquisitions

Direct employees and contractors

IT environment

Business presence and locations od operations and data centers

Inherent Risk Profile

Cybersecurity

Maturity

Assessment

Cybersecurity Maturity Overview

Cybersecurity maturity is evaluated in 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.

Each domain has five levels of maturity: baseline, evolving, intermediate, advanced, and innovative.

Cybersecurity Maturity Domain Coverage

Domain 1

Cyber Risk Management &

Oversight

Governance

Risk Management

Resources

Training and Culture

Domain 2

Threat Intelligence and

Collaboration

 Threat Intelligence

 Monitoring and Analyzing

 Information Sharing

Domain 3

Cyber Security Controls

Preventative

• Infrastructure management

• Access and asset management

• Device/endpoint security

• Secure coding practices

Detective

• Threat and vulnerability detection

• Anomalous behavior activity detection

• Event detection

Corrective

• Patch management

• Remediation

Domain 4

External Dependency

Management

Connections

• Identifications

• Monitoring

• Management of external connections and data flows to third parties

Relationship

Management

• Due diligence

• Contracts

• Ongoing monitoring

Domain 5

Cyber Incident Management and

Response

Incident Resilience Planning &

Strategy

Detection, Response, &

Mitigation

Escalation & Reporting

Risk Maturity

Relationship

Risk Maturity Matrix

National Bank Case

Study

ABC National Bank Business Profile

Background

 5000+ employees

 1000+ banking locations

 HQ in Central US

 Est. 1967

Banking Operations

 Branch Banking

 Commercial Banking

 Consumer Lending

 Investment Advisors

Current State

 EOL systems still in use, no upgrade plan

 Mobile banking applications and some BYOD

 Previous security incidents -phishing attempts and internal hacking attempts via ATM’s being infected with malware

 IT Security Director has left the Bank

Inherent Risk Score

Inherent Risk Score

507.69

legend

Category

Technologies and connection Types

Delivery Channels

Organizational

Characteristics

Online/Mobile Products and Technological

Services

<=200 201-400 401-600 601-800

Data

Weights Points Least Minimal Moderate Significant

1

1

1

1

14

3

7

14

0

0

1

3

8

0

0

3

4

1

6

8

External Threats

Totals

1

5

1 0 0 1

39 4 11 20

10.26

% 28.21% 51.28%

2

2

0

0

0

4

10.26%

801-

1000

Most

0

0

0

0.00%

0

0

0

Cybersecurity Maturity Assessment

Maturity Achieved Against Defined Targets

81.06%

Domain

Cyber Risk

Management and Oversight

Desired Target %Achieved Maturity Achieved Statements Least Minimal Moderate Significant Most

Intermediate 64.89% Innovative 1 15 6.67% 6.67%

Advanced

Intermediate

5

7

32

29 24.14%

15.63%

24.14%

15.63% 15.63%

24.14%

Evolving 23

Threat

Intelligence and

Collaboration

Baseline

Intermediate 88.46% Innovative

Advanced

Intermediate

31

0

2

8

34 67.65% 67.65% 67.65%

31

100.00

%

100.00

%

8

11

11 72.73%

0.00% 0.00%

18.18% 18.18% 18.18%

72.73% 72.73%

Cyber Security

Controls

Intermediate 80.62%

Evolving

Baseline

Innovative

Advanced

Intermediate

Evolving

7

8

2

5

23

30

7

100.00

%

100.00

%

100.00

% 100.00%

100.00

% 8

20

25

39

20.00%

10.00% 10.00%

20.00% 20.00%

58.97% 58.97% 58.97%

39 76.92% 76.92% 76.92%

100.00

100.00

External

Dependency

Management

Cyber Incident

Management and Resilience

Baseline

Intermediate 86.84% Innovative

Advanced

Intermediate

Evolving

Baseline

Intermediate 84.48% Innovative

Advanced

51

0

3

6

11

16

1

3

16

10

15

51

7

7

9

% %

42.86%

0.00% 0.00%

42.86% 42.86%

66.67% 66.67% 66.67%

13 84.62% 84.62% 84.62%

100.00

%

100.00

%

20.00%

10.00% 10.00%

20.00% 20.00%

Key Considerations While Using the CAT

Being Innovative in Cybersecurity

Maturity

Real time detection and response

Always be updating for changes

Automatic metrics and reporting

Threat analytics that matter

Baseline risk measurement

Not just for Finance!

Industry’s can use the tool to fit their inherent risk profile by changing the criteria that best fits them.

Eg, healthcare can tailor their inherent risk based on the nature of health services provided, number of devices connected to the network including medical devices, the number of sensitive patient files, and number of medical services locations as a start .

Same goes for the cyber security assessment maturity questionnaire, you can tailor the questionnaire using the controls for HIPAA, PCI, and

NIST and any other standard that pertains to your industry.

Questions & Answers

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