Cybersecurity Governance Update on New FFIEC Requirements



Similar documents
Current Trends in Cyber Crime & Payments Fraud cliftonlarsonallen.com

Cybersecurity Governance Update: New FFIEC Requirements cliftonlarsonallen.com

IT Security Risks & Trends

Managing the Operational Risk of Our Bank

Mobile Banking and Bring Your Own Device

Information Security Addressing Your Advanced Threats

Cybersecurity: What CFO s Need to Know

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

Cybersecurity Best Practices in Mortgage Banking. Article by Jim Deitch October 2015

Payment Fraud Trends

What s Wrong with Information Security Today? You are looking in the wrong places for the wrong things.

Today s Topics. Protect - Detect - Respond A Security-First Strategy. HCCA Compliance Institute April 27, Concepts.

RLI PROFESSIONAL SERVICES GROUP PROFESSIONAL LEARNING EVENT PSGLE 123. Cybersecurity: A Growing Concern for Small Businesses

THE CHANGING FACE OF CYBERCRIME AND WHAT IT MEANS FOR BANKS

CYBERSECURITY HOT TOPICS

PCI Compliance. What is New in Payment Card Industry Compliance Standards. October cliftonlarsonallen.com CliftonLarsonAllen LLP

Cyber Security, Fraud and Corporate Account Takeovers LBA Bank Counsel Conference December 2014

I ve been breached! Now what?

Who Drives Cybersecurity in Your Business? Milan Patel, K2 Intelligence. AIBA Quarterly Meeting September 10, 2015

Analyzing Security for Retailers An analysis of what retailers can do to improve their network security

Cybersecurity: A Growing Concern for All Businesses. RLI Design Professionals Design Professionals Learning Event DPLE 160 October 7, 2015

Cyber Security Metrics Dashboards & Analytics

Hack Proofing Your Organization

Internet threats: steps to security for your small business

FFIEC CONSUMER GUIDANCE

Cybersecurity: Protecting Your Business. March 11, 2015

Security and Privacy

Cybersecurity Awareness. Part 1

Don t Fall Victim to Cybercrime:

INCIDENT RESPONSE CHECKLIST

2012 Data Breach Investigations Report

DATA SECURITY HACKS, HIPAA AND HUMAN RISKS

Data Security for the Hospitality

THE SMARTEST WAY TO PROTECT WEBSITES AND WEB APPS FROM ATTACKS

Cybersecurity. Regional and Community Banks. Inherent Risks and Preparedness.

Cyber Security 2014 SECURE BANKING SOLUTIONS, LLC

Top Fraud Trends Facing Financial Institutions

Information Technology

2012 CliftonLarsonAllen LLP. Ensuring Internal Controls in an Electronic Age

Risks and Trends in Network Security. Credit Unions

Presented by: Mike Morris and Jim Rumph

Defending Against Data Beaches: Internal Controls for Cybersecurity

CYBERSECURITY: PROTECTING YOUR ORGANIZATION AGAINST CYBER ATTACKS. Viviana Campanaro CISSP Director, Security and Compliance July 14, 2015

Small Firm Focus: A Practical Approach to Cybersecurity Friday, May 29 9:00 a.m. 10:15 a.m.

Here are two informational brochures that disclose ways that we protect your accounts and tips you can use to be safer online.

Questions You Should be Asking NOW to Protect Your Business!

Real World Healthcare Security Exposures. Brian Selfridge, Partner, Meditology Services

Information Technology. A Current Perspective on Risk Management

KEY STEPS FOLLOWING A DATA BREACH

Auditing After a Cyber Attack JAX IIA Chapter Meeting Cybersecurity and Law Enforcement

Guidelines for Website Security and Security Counter Measures for e-e Governance Project

Honeywell Industrial Cyber Security Overview and Managed Industrial Cyber Security Services Honeywell Process Solutions (HPS) June 4, 2014

Franchise Data Compromise Trends and Cardholder. December, 2010

How to complete the Secure Internet Site Declaration (SISD) form

Get on First Base with your Regulators and Cyber Security

What is Management Responsible For?

Simplifying Security & Compliance Innovating IT Managed Services. Data Security Threat Landscape and IT General Controls

safe and sound processing online card payments securely

Building The Human Firewall. Andy Sawyer, CISM, C CISO Director of Security Locke Lord

WHAT EVERY CEO, CIO AND CFO NEEDS TO KNOW ABOUT CYBER SECURITY.

How are we keeping Hackers away from our UCD networks and computer systems?

How To Protect Yourself From A Hacker Attack

Host Hardening. Presented by. Douglas Couch & Nathan Heck Security Analysts for ITaP 1

Data Breach Response Planning: Laying the Right Foundation

Cyber Exploits: Improving Defenses Against Penetration Attempts

September 20, 2013 Senior IT Examiner Gene Lilienthal

A practical guide to IT security

Presented by Evan Sylvester, CISSP

SECURITY CONSIDERATIONS FOR LAW FIRMS

Making the difference between read to output, and read to copy GOING BEYOND BASIC FILE AUDITING FOR DATA PROTECTION

Corporate Account Take Over (CATO) Guide

PCI Compliance. How to Meet Payment Card Industry Compliance Standards. May cliftonlarsonallen.com CliftonLarsonAllen LLP

Top Five Data Security Trends Impacting Franchise Operators. Payment System Risk September 29, 2009

FIREWALL CHECKLIST. Pre Audit Checklist. 2. Obtain the Internet Policy, Standards, and Procedures relevant to the firewall review.

Cyber Self Assessment

Network/Cyber Security

PCI Compliance for Healthcare

Logging In: Auditing Cybersecurity in an Unsecure World

Top Ten Fraud Risks That Impact Your Financial Institution. Presented by Ann Davidson - VP Risk Consulting Allied Solutions LLC.

Practice Good Enterprise Security Management. Presented by Laurence CHAN, MTR Corporation Limited

Network Security Forensics

Cybersecurity and Technology Update. Paul Rainbow, Information Security Supervisor, Umpqua Bank Francis Tam, Partner, Moss Adams LLP

How To Find Out If You Were Hacked By An Employee Of Ancient.Com

Cybersecurity. Are you prepared?

FFIEC BUSINESS ACCOUNT GUIDANCE

Cyber Insurance: How to Investigate the Right Coverage for Your Company

Applying the 80/20 approach for Operational Excellence. How to combat new age threats, optimize investments and increase security.

Incident Response. Six Best Practices for Managing Cyber Breaches.

Who s Doing the Hacking?

Cyber - Security and Investigations. Ingrid Beierly August 18, 2008

How-To Guide: Cyber Security. Content Provided by

Web application security Executive brief Managing a growing threat: an executive s guide to Web application security.

Overcoming PCI Compliance Challenges

Presented By: Corporate Security Information Security Treasury Management

PCI Compliance. How to Meet Payment Card Industry Compliance Standards. June 5, CliftonLarsonAllen LLP

IBM Security Strategy

Enterprise Cybersecurity: Building an Effective Defense

Big Data, Big Risk, Big Rewards. Hussein Syed

IT AUDIT WHO WE ARE. Current Trends and Top Risks of /9/2015. Eric Vyverberg. Randy Armknecht. David Kupinski

Why The Security You Bought Yesterday, Won t Save You Today

Transcription:

Cybersecurity Governance Update on New FFIEC Requirements cliftonlarsonallen.com Our perspective CliftonLarsonAllen Started in 1953 with a goal of total client service Today, Professional Services Firm with three lines of business: Wealth Management Outsourcing Traditional Assurance and Consulting Information Security offered as specialized service offering for over 15 years 1

Overview Three most common cyber fraud scenarios we see affecting our banks customers Theft of PII and PFI Corporate Account Take Overs Ransomware Defensive Measures to support Incident Response Examples and Case Studies 3 Strategies Our information security strategy should have the following objectives: Users who are more aware and savvy Networks that are resistant to malware Be Prepared Monitoring, Incident Response, and Forensic Capabilities 4 2

Cyber Fraud Risk Themes Hackers have monetized their activity More hacking More sophistication More hands on effort Smaller organizations targeted Social engineering on the rise Hackers targeting YOUR businesses customers In the News Theft of PFI and PII Active campaigns involving targeted phishing and hacking focused on common/known vulnerabilities. Target Goodwill Jimmy Johns University of Maryland University of Indiana Anthem Blue Cross Primera Olmsted Medical Center Community Health Systems 6 3

Timeline of a Breach and Missed Opportunities 1. Attacked/compromised vendor remote access 2. Missed AV/IDS warnings 1 3 3. Attacked/compromised internal vulnerabilities 4. Missed IDS warnings 2 4 7 Credit Card Data For Sale A peek inside a carding operation: http://krebsonsecurity.com/2014/06/peek inside a professional carding shop/ 4

Corporate Account Takeover Catholic church parish Hospice Finance company Main Street newspaper stand Electrical contractor Utility company Industry trade association Rural hospital Mining company On and on and on and on.. CATO Lawsuits UCC a payment order received by the [bank] is effective as the order of the customer, whether or not authorized, if the security procedure is a commercially reasonable method of providing security against unauthorized payment orders, and the bank proves that it accepted the payment order in good faith and in compliance with the security procedure and any written agreement or instruction of the customer restricting acceptance of payment orders issued in the name of the customer. 5

CATO Lawsuits UCC Electrical Contractor vs Bank > $300,000 stolen via ACH through CATO Internet banking site was down DOS? Contractor asserting Bank processed bogus ACH file without any call back CATO Lawsuits UCC Escrow company vs Bank > $400,000 stolen via single wire through CATO CE passed on dual control offered by the bank Court ruled in favor of bank Companies attorneys failed to demonstrate bank s procedures were not commercially reasonable 6

Case Study Please Wire $ to. CEO asks the CFO Common mistakes 1. Use of private email 2. Don t tell anyone http://www.csoonline.com/article/2884339/malware cybercrime/omahas scoular co loses 17 million afterspearphishing attack.html 13 CATO Defensive Measures Multi layer authentication Multi factor authentication Out of band authentication 14 7

CATO Defensive Measures Positive pay ACH block and filter IP address filtering Dual control Defined processes for payments Activity monitoring Manual vs. Automated controls Combination of preventative and detective controls 15 Ransomware Malware encrypts everything it can interact with i.e. anything the infected user has access to CryptoLocker May 20, 2014 Ransomware attacks doubled in last month (7,000 to 15,000) http://insurancenewsnet.com/oarticle/2014/05/20/cryptolocker goes spearphishing infections soar warns knowbe4 a 506966.html 16 8

Ransomware Zip file is preferred delivery method Helps evade virus protection Working (tested) backups are key Keys to Successful Breaches 2013 2014 https://www2.trustwave.com/gsr2014. 18 9

Keys to Successful Breaches Reliance/dependence on 3 rd party service providers is at root of most breaches 19 How do hackers and fraudsters break in? Amateurs hack systems, professionals hack people. Bruce Schneier Social Engineering relies on the following: The appearance of authority People want to avoid inconvenience Timing, timing, timing 10

Pre text Phone Calls Hi, this is Randy from Fiserv users support. I am working with Dave, and I need your help Name dropping Establish a rapport Ask for help Inject some techno babble Think telemarketers script Home Equity Line of Credit (HELOC) fraud calls Ongoing high profile ACH frauds Email Attacks Spoofing and Phishing Impersonate someone in authority and: Ask them to visit a web site Ask them to open an attachment or run update Examples Better Business Bureau complaint http://www.millersmiles.co.uk/email/visa usabetterbusiness bureaucall for action visa Microsoft Security Patch Download 11

Email Phishing Targeted Attack Strategies to Combat Social Engineering (Ongoing) user awareness training SANS First Five Layers behind the people 1. Secure/Standard Configurations (hardening) 2. Critical Patches Operating Systems 3. Critical Patches Applications 4. Application White Listing 5. Minimized user access rights No browsing/email with admin rights Logging, Monitoring, and Alerting capabilities The 3 R s : Recognize, React, Respond More on this at the end 12

Key Defensive Strategies cliftonlarsonallen.com 25 Strategies Our information security strategy should have the following objectives: Users who are more aware and savvy Networks that are resistant to malware Be Prepared Monitoring, Incident Response, and forensic Capabilities 13

Ten Keys to Mitigate Risk 1. Strong policies 6. Perimeter security layers 2. Defined user access roles Minimum Access 3. Hardened internal systems and end points 4. Encryption strategy data centered 5. Vulnerability management process 7. Centralized logging, analysis and alerting capabilities 8. Incident response capabilities 9. Know / use online banking tools 10.Test, Test, Test Independent validation that it works Verizon Report is analysis of intrusions investigated by Verizon and US Secret Service. KEY POINTS: Time from successful intrusion to compromise of data was days to weeks. Log files contained evidence of the intrusion attempt, success, and removal of data. Most successful intrusions were not considered highly difficult. 14

Centralized Logging, Analysis, and Alerting Centralized audit logging, analysis, and automated alerting capabilities (SIEM) Firewalls Security appliances Routing infrastructure Network authentication Servers Applications *** Archiving vs. Reviewing FFIEC Executive Leadership of Cybresecurity cliftonlarsonallen.com 30 15

Cybersecurity Leadership FFIEC https://www.fdic.gov/news/news/financial/2014/fil14021.html 31 Cybersecurity Leadership FFIEC https://www.fdic.gov/news/news/financial/2014/fil14021.html 32 16

Cybersecurity Leadership FFIEC Governance and Threat Intelligence https://www.fdic.gov/news/news/financial/2014/fil14021.html 33 Cybersecurity Leadership FFIEC https://www.fdic.gov/news/news/financial/2014/fil14021.html 34 17

Cybersecurity Leadership FFIEC https://www.fdic.gov/news/news/financial/2014/fil14021.html 35 Cybersecurity Leadership FFIEC https://www.fdic.gov/news/news/financial/2014/fil14021.html 36 18

Very Recent Examiner Supplemental Cyber Security Request List 37 Very Recent Examiner Supplemental Cyber Security Request List 38 19

Very Recent Examiner Supplemental Cyber Security Request List 39 Call To Action Policies to set foundation Train your users Thoroughly assess your risks Three R s: Recognize, React, Respond Thoroughly validate your controls High expectations of your vendors Penetration testing and vulnerability assessment Social engineering testing People Tools ` Rules 40 20

Questions? Randy Romes, CISSP, CRISC, MCP, PCI QSA Principal Information Security Services Randy.romes@cliftonlarsonallen.com 888.529.2648 cliftonlarsonallen.com twitter.com/ CLA_CPAs facebook.com/ cliftonlarsonallen linkedin.com/company/ cliftonlarsonallen 42 21

Resources Hardening Checklists Hardening checklists from vendors CIS offers vendor neutral hardening resources http://www.cisecurity.org/ Microsoft Security Checklists http://www.microsoft.com/technet/archive/security/chklist/default.mspx?mfr=true http://technet.microsoft.com/en us/library/dd366061.aspx Most of these will be from the BIG software and hardware providers Three Security Reports Trends: Sans 2009 Top Cyber Security Threats http://www.sans.org/top cyber security risks/ Intrusion Analysis: TrustWave (Annual) https://www.trustwave.com/whitepapers.php Intrusion Analysis: Verizon Business Services (Annual) http://www.verizonenterprise.com/dbir/ 22