By: Gerald Gagne. Community Bank Auditors Group Cybersecurity What you need to do now. June 9, 2015

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1 Community Bank Auditors Group Cybersecurity What you need to do now June 9, 2015 By: Gerald Gagne MEMBER OF PKF NORTH AMERICA, AN ASSOCIATION OF LEGALLY INDEPENDENT FIRMS 2015 Wolf & Company, P.C.

2 Cybersecurity - the Unknown As we know, There are known knowns. There are things we know we know. We also know There are known unknowns. That is to say We know there are some things We do not know. But there are also unknown unknowns, The ones we don't know We don't know. Donald Rumsfeld, Feb. 12, 2002, Department of Defense news briefing 2

3 Today s Agenda Cybersecurity today How do I measure my readiness Cybersecurity To Do List 3

4 In the News 4

5 Definitions Per NIST Cybersecurity: The ability to protect or defend the use of cyberspace from cyber attacks. Cyberspace: A global domain within the information environment consisting of the interdependent network of information systems infrastructures including the Internet, telecommunications networks, computer systems, and embedded processors and controllers. Information Security (1): The protection of information and information systems from unauthorized access, use, disclosure, disruption, modification, or destruction in order to provide confidentiality, integrity, and availability. SOURCE: NIST IR 7298 Revision 2, Glossary of Key Information Security Terms 5

6 The Threats Hacktivists Organized Crime Nations and Foreign Competitors 6

7 2015 Verizon Data reach Investigation Report Incident Frequency by Industry 7

8 What Banks Need to Know 1. Hackers increasingly have more than one motive and method of attack. 2. The use of memory scraping in data breaches has increased. 3. More cyber threat information is being shared, but there is a need for faster sharing. 4. Too many people still fall for phishing attacks. 5. Old software vulnerabilities are going unpatched. 6. Mobile malware is not statistically significant yet, but it's still a concern. 7. Ongoing Web app attacks point to a need for two-factor authentication. American Banker Bank Technology News: April 16,

9 Primary types of Breaches Corporate Account Take-over (CATO) Accidents/Unintentional Breaches Social Engineering Malware/Viruses ATM/Card Skimming 9

10 Another Compliance Requirement? 10

11 Regulatory Concerns Cyber Criminals Likely to Target Smaller Banks As large banks improve their resistance to cyber attacks, cyber criminals are very likely [to] turn their attention to community banks These smaller institutions can provide a point of entry into larger networks, and they may have less sophisticated defenses than large banks - Thomas Curry, Comptroller of the Currency 5/8/14 11

12 12

13 Examiners want Banks Setting the tone from the top and building a security culture Identifying, measuring, mitigating, and monitoring risks Developing risk management processes commensurate with the risks and complexity of the institutions Aligning cybersecurity strategy with business strategy and accounting for how risks will be managed both now and in the future Creating a governance process to ensure ongoing awareness and accountability Ensuring timely reports to senior management that include meaningful information addressing the institution s vulnerability to cyber risks 13

14 Exam Expectations 1. Risk Management and Oversight 2. Threat Intelligence and Collaboration 3. Cybersecurity Controls 4. External Dependency Management 5. Cyber Incident Management and Resilience 14

15 Risk Assessment Has Changed Inventories of assets must support an inventory of threats and security controls Need to know how to defend and respond to these cyber threats Build into your process risk assessment update based on Threat Intelligence Cybersecurity events Identify the threat for each asset with and ensure specific controls mitigate the threat Understanding the demographics of each asset Identify behavior that would indicate you were compromised Impacts other risk management programs Vendor management BCP 15

16 Key Indicators of Compromise (IOC) Key IOC What type of activity would indicate that you have a breach Based on IT operations and processes Security information and event management (SIEM) Logging configuration Correlate events from assets (servers, workstations, routers, IDS/IPS, etc ) Network time protocol (NTP) synchronization Incident Response Procedures Known and common events IOC IOC examples Electronic banking activity Failed or successful login to default administrator user accounts Unauthorized change to security settings Suspicious transactions initiated from new IP address Suspicious transactions new payee Customer notifies FI there is a fraudulent transaction 16

17 Key IOC Continued IOC examples Network activity Failed or successful login to default administrator user accounts Attempt to login to a disabled user account Successful login to non-domain (or local) user account (i.e. Administrator user account on member server) Member added to privilege group (user account privilege escalation) Audit log cleared Audit policy change Unauthorized change to security settings Suspicious transactions Unusual outbound network activity (where is your data going?) Anti-virus alert IDS/IPS alert Web filter alert Employee notifies IT that they may have clicked on a link or divulged sensitive information 17

18 Cybersecurity Risk Assessment Connection types From mobile devices (BYOD) VPNs Internet Portals sites, web based applications, telnet, FTP Wireless networks Direct connections to other networks or ISP s Product and services Target a specific product or service (i.e. Business Online Banking, Wire Transfer system) Technologies Used Each type of technology introduces its own set of vulnerabilities 18

19 Risk Management and Oversight Governance More frequent Board and Senior management education Define roles and responsibilities that assign accountability regarding cyber risks Reporting structure of CISO/ISO Management of cyber security issues (interaction between information security and core business functions) Allocation of resources Time and energy Training and awareness of employees Onboarding and ongoing training More frequent and relevant training Training for information security professionals Test training effectiveness 19

20 Training Objectives When Security Training is for Compliance we document our threats and controls. we understand who is in charge of security. we document our confidential information. we are informed on the threats to our business. we are informed on the risks we will take. When Security Training is a core competency we maintain processes and procedures to manage safely. we understand our role in operating securely. we understand how to properly secure our confidential information. we evaluate threats before we make changes to our business. we participate in evaluating the risks we will take. 20

21 Threat Intelligence External sources of threat intelligence Media reports Third party service providers Financial Services Information Sharing and Analysis (FS-ISAC) InfraGard Secret Service US Cert Internal sources of threat intelligence Fraud detection tools Anti-Money Laundering/Office of Foreign Assets Control/Bank Secrecy Security information and event management (SIEM) Sharing information with law enforcement 21

22 Cybersecurity Controls Preventive controls Identity and access management systems (includes MFA) Restricting access (i.e. network segmentation, ACL s, web filtering) CISO or ISO reporting lines Data Classification Patch management program Secure software development life cycle Encryption Detective controls Increased security testing and monitoring, penetration testing Incident detection and monitoring Corrective controls Incident response Cyber security insurance BCP/DRP (incorporate security into plan) 22

23 External Dependency Management Identify connections: ISP Third party service providers Business partners Customers Other Financial Institutions Evaluate third party cybersecurity preparedness Using the right to audit clause / penetration testing Membership to FS-ISAC, InfraGard, etc Incident response / communication plans on vulnerability management Reviewing third party risk assessment results / Audit reports (above and beyond SOC reports) Build expectations into contract (testing incident response, vulnerability scanning / penetration testing frequency, fill out annual security questionnaire) Subcontractors 23

24 Cyber Incident Management and Resilience Developing specific plans for common cybersecurity events CATO, DoS, malware, ATM cash-out scams, etc Communication with employees, customers, third parties, regulators, law enforcement Identify your computer forensic third party in advance Incorporating incident response into BCP and DRP, consider these unique factors: Customers/Clients affected by cyber incident Consideration for employee hit by ID Theft Third party providers/suppliers affected by cyber incident Transportation affected by cyber incident Remote working capabilities affected by cyber incident Consider utilities and availability of employee homes Plan for loss of personnel and key and backup locations for extended periods of time Test your plans! 24

25 NIST Cybersecurity Framework President issued Executive Order on February 12, 2013 NIST Framework for Improving Critical Infrastructure Cybersecurity version 1 publish on February 12, 2014 Relies and maps to existing standards, guidelines, and practices Describe their current cybersecurity posture Describe their target state for cybersecurity Identify and prioritize opportunities for improvement within the context of a continuous and repeatable process Assess progress toward the target state Communicate among internal and external stakeholders about cybersecurity Risk-based approach to managing cybersecurity 25

26 Framework Components Framework Core Functions (Identify, Protect, Detect, Respond, Recover) Categories (i.e. Access control) Subcategories (i.e. Remote access is managed) Information References Framework Implementation Tiers Partial (Tier 1) Risk Informed (Tier 2) Repeatable (Tier 3) Adaptive (Tier 4) Framework Profiles Current Target Comparison Each Framework component reinforces the connection between business drivers and cybersecurity activities 26

27 NIST Core Framework 27

28 Sample Framework Core 28

29 NIST Implementation Tiers Risk Management Process Integrated Risk Management Program 1. Partial 2. Risk Informed 3. Repeatable 4. Adaptive External Participation 29

30 Vendor Management Enhanced Due Diligence and Ongoing Monitoring Activities How do you vet, select and monitoring third party service providers Vulnerability management (i.e. recent SSL vulnerabilities) Integrating Incident Response Plans and Tests Cybersecurity questionnaires Cyber insurance Contract language Termination clauses Right to audit (required remediation) Security report and questionnaires Event log BCP documentation Vulnerability responses Cyber insurance 30

31 Enhancements To Your BCP 31

32 Think about this 32

33 Important Resources FFIEC Cybersecurity guidance-http://www.ffiec.gov/cybersecurity.htm NIST Cybersecurity Framework-http://www.nist.gov/cyberframework/ Executive Order http://www.whitehouse.gov/the-pressoffice/2013/02/12/executive-order-improving-critical-infrastructure-cybersecurity FBI InfraGard-https://www.infragard.org/ U.S. Computer Emergency Readiness Team-https://www.us-cert.gov/ U.S. Secret Service Electronic Crimes Task Forcehttp://www.secretservice.gov/ectf.shtml Department of Homeland Security-http://www.dhs.gov/about-critical-infrastructurecyber-community-c%C2%B3-voluntary-program NY State Department of Financial Services Memohttps://www.njbankers.com/WCM/njbadocs/Operations%20Technology%20Commit tee/ny%20cyber%20security%20exam%20process.pdf 33

34 Questions / Thank You! Gerald R. Gagne, CPA, CISA Member of the Firm

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