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GET PREPARED:
FFIEC’s Cybersecurity Assessment
JAY McLAUGHLIN
SENIOR VICE PRESIDENT,
CHIEF SECURITY OFFICER
Jay has over 15 years of technology
and security experience. He is highly
visible and frequently speaks at
industry conferences and summits.
His dynamic, balanced, insightful
presentations and writings cover
topics from perimeter security to
application layer security analytics.
Jay has been featured and quoted in
various publications including
ComputerWorld, CSO Magazine,
Credit Union Times, Credit Union
Magazine, American Banker, and the
ABA Banking Journal.

Jay holds a Bachelor of Science
degree in Management Information
Systems from the University of
Central Florida.
#q2connect15
! " ?
Rapidly evolving
cyber risks
Financial institutions
are critically
dependent upon
technology solutions
A fundamental lack of
understanding of cyber
security threats &
vulnerabilities
CURRENT STATE
#q2connect15
Overview of threat landscape
Increase in number
of attacks and
attack methods
$ % &
ARMS RACE
#q2connect15
Attackers are
becoming increasingly
adept at defeating
security practices
New & evolving
techniques

and vectors
Attacks pose risks to
financial services &
critical infrastructure
Institutions are not staying ahead of cybersecurity threats
'
STATS
#q2connect15
Reference points from studies & publications
About 110M Americans
– equivalent to roughly
48% of U.S. adults –
had some form of their
personal data exposed
in 2014.
110M
Source: Ponemon Institute study,

reported by CNN, May 2014
Of hacking victims in the
business community didn't
even realize they'd been
hacked until they were told
by vendors, government
investigators or consumers.

80%
Source: 2014 Verizon Data
Breach Investigations Report
And according to a recent
report, banks are being hit
with cyber attacks “every
minute of every day”.

(
Source: Telegraph news report, Oct 2013
)
Risk
management

& oversight
 +
,-
CYBERSECURITY BEST PRACTICES
Threat intelligence,
information sharing &
collaboration
Incident detection

& response
Security

Controls
Business continuity

& cyber resiliency
What you should be doing today
#q2connect15
1. RISK MANAGEMENT & OVERSIGHT
#q2connect15
LACK OF OVERALL
UNDERSTANDING OF
INHERENT RISK
$ .
Significant concerns
OVERSIGHT OF

THIRD-PARTY

PROVIDERS
RISK MANAGEMENT & OVERSIGHT
#q2connect15
⋆
Critical to success
ENGAGE EXECUTIVE
MANAGEMENT

& BOARD
INVOLVE KEY
STAKEHOLDERS
ACROSS THE ENTIRE
ORGANIZATION
"
0
Gathering, monitoring, analyzing, and sharing
information from multiple sources on cyber
threats and vulnerabilities
#q2connect15
2. THREAT INTEL, INFO SHARING & COLLABORATION
Definition
FAILING TO KEEP

UP-TO-DATE

ON THREATS
ABILITY TO CONSUME
THREAT FEEDS &
INCORPORATE INTO
MONITORING TOOLS
NOT
PARTICIPATING IN
VERTICAL SHARING
ORGANIZATIONS
THREAT INTEL, INFO SHARING & COLLABORATION
#q2connect15
Call to action
&
1
2
 4 5
#q2connect15
INCORPORATE INTO
CYBERSECURITY
MONITORING TOOLS

(SIEM)
PARTICIPATE IN
INDUSTRY
VERTICAL SHARING
ORGANIZATIONS

(FS-ISAC)
AVOID
INFORMATION
OVERLOAD
6
THREAT INTEL, INFO SHARING & COLLABORATION
Crawl, walk, run
SUBSCRIBE TO
THREAT
INTELLIGENCE
DATA FEEDS
Implement controls
based on risk assessment
activities
7
#q2connect15
Deploy preventative,
detective, &
corrective controls
8
Invest in appropriate
staffing & expertise
3. SECURITY CONTROLS
Starting point
9
Accept overall

residual risk
$
4. INCIDENT DETECTION & RESPONSE
#q2connect15
RELY TOO HEAVILY
ON SECURITY
CONTROLS
: ;
Problems we are seeing
IMPLEMENT
FRAMEWORK TO
MATURE IR PROGRAM
#q2connect15
DETECT AND ISOLATE
THREAT VECTOR
○ =
Establish a process
REMEDIATION
EFFORTS MITIGATE
REOCCURRENCE OF
THE THREAT
PERFORM TRIAGE, ANALYSIS
AND INVESTIGATION BY
SECURITY RESPONSE TEAMS
>
INCIDENT DETECTION & RESPONSE
Ability to resume services or
operations following an event
#q2connect15
0
5. BUSINESS CONTINUITY & CYBER RESILIENCY
Definition
#q2connect15
LACK A STRATEGY TO
KEEP ORGANIZATION
FUNCTIONAL AFTER
AN EVENT
? ?
Challenges we face
MAY NOT FULLY
UNDERSTAND
OPERATIONAL SIDE
BUSINESS CONTINUITY & CYBER RESILIENCY
#q2connect15
@
Establish a plan to
weather the attack while
incurring minimal impact
to the organization
BUSINESS CONTINUITY & CYBER RESILIENCY
Institutions must begin to focus on resiliency, not recovery
#q2connect15
FFIEC CYBERSECURITY ASSESSMENT BASICS
FFIEC CYBERSECURITY ASSESSMENT BASICS
#q2connect15
In 2014, the FFIEC piloted a
cybersecurity examination
work program at more than
500 community institutions
Purpose of assessment:
evaluate institutions’
preparedness to mitigate
cybersecurity risks
>$
! A +
Rapidly evolving
cyber threats are
facing FIs
FFIEC INVOLVEMENT
#q2connect15
Not a matter of if,
but when an
attack will occur
Must increase the
readiness and
capabilities
FFIEC wants to help financial
institutions enhance their
cyber security risk capabilities
and overall preparedness
FFIEC CYBERSECURITY ASSESSMENTS
#q2connect15
;
Created in response
to growing risks and
complexity of attacks
B C
Coordinate with
intelligence/law
enforcement/
homeland security
A dedicated support
for community FI’s
lacking resources
D
E
F
FFIEC CYBERSECURITY ASSESSMENTS
Round 1
#q2connect15
FIs need to increase the focus
of risk management / oversight
Must increase the
readiness and
capabilities
Overall preparedness
and capability to
respond to these risks
G
IDENTITY

risk awareness,
organizational
understanding
H ☼
=+
PROPOSED FRAMEWORK
The FFIEC Cybersecurity Assessment’s Suggestions
PROTECT

develop and implement
appropriate safeguards
DETECT

early alerting of
cybersecurity events
RESPOND

appropriate activities
to take action
RECOVER

resiliency; ability

to restore services
& capabilities
#q2connect15
#q2connect15
FFIEC ASSESSMENTS



WHAT SHOULD FINANCIAL INSTITUTIONS EXPECT?

HOW CAN YOU BE PREPARED?
#q2connect15
Exhibit a fundamental understanding of inherent cyber risks
1
FFIEC ASSESSMENTS
#q2connect15
Be prepared to communicate
and articulate your FI’s process
for conducting and revisiting
technology risk assessments
HOW TO
Demonstrate fundamental

understanding of inherent risks
#q2connect15
Organizational units
must be involved in the
risk assessment process
Must be able to convey the bank’s
awareness and identification of potential
risks, including any third-party risks that
may result from vendor relationships
*This is the first place
examiners will focus.
Unfamiliarity or lack of
knowledge related to
this process will raise a
red flag to dig deeper.
#q2connect15
2
#q2connect15
FFIEC ASSESSMENTS
#q2connect15
Articulate approach for implementing controls to address risks
Staff must be show
they are well-versed
in cyber security
controls and industry
recommendations
ARTICULATE
Approach for implementing

controls to address risks
#q2connect15
Be ready to show how the
bank has aligned its cyber
security strategy with its
business strategy
For example, how
risks will be managed
now and in the future
#q2connect15
3
#q2connect15
FFIEC ASSESSMENTS
#q2connect15
Demonstrate maturity readiness & preparation for adapting to threats
Need to have evidence of
programs for continuously
monitoring the latest risks
& threats to determine
(along with the process for)
implementing mitigations
EXHIBIT
Maturity readiness

and preparation for

adapting to threats
#q2connect15
Must show how
you’re leveraging
and incorporating
threat intelligence
Show involvement in
industry information
sharing groups (FS-ISAC)
#q2connect15
4
Show how executive management & board members are being engaged
#q2connect15
FFIEC ASSESSMENTS
#q2connect15
Show how board members are
being brought in specifically for
their experience and
knowledge around information
technology and security
CONVEY
How executive level management

and board level are being engaged
#q2connect15
Must educate existing
board members

• Inform and engage

• Share facts, speak in
their language (RISK)
#q2connect15
Updated BCP Booklet that
contains 16-page appendix
around business continuity
was released in Feb 2015;
continued emphasis on
planning and resiliency
Increased scrutiny on
third-party relationships
and how the FI is managing
the oversight processes


FFIEC plans to issue a cyber
security self assessment tool
this year to assist institutions
in evaluating their inherent
cybersecurity risk and their
risk management capabilities.
6
ALSO FOR CONSIDERATION
Expect more to come
J0
CLOSING THOUGHTS
#q2connect15
F
Institutions are
struggling to stay
ahead of cyber
security threats
K
Implement a
framework for

building a robust
security strategy
.
Engage Executive
Management
'
Attackers becoming
increasingly adept at
defeating security
practices
$
Proper assessment
of risk is critical!
+Threat landscape will
continue to evolve
WE MUST ADAPT
Q & AQ & A

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Evaluating your Cybersecurity Preparedness - FFIEC Assessment

  • 2. JAY McLAUGHLIN SENIOR VICE PRESIDENT, CHIEF SECURITY OFFICER Jay has over 15 years of technology and security experience. He is highly visible and frequently speaks at industry conferences and summits. His dynamic, balanced, insightful presentations and writings cover topics from perimeter security to application layer security analytics. Jay has been featured and quoted in various publications including ComputerWorld, CSO Magazine, Credit Union Times, Credit Union Magazine, American Banker, and the ABA Banking Journal.
 Jay holds a Bachelor of Science degree in Management Information Systems from the University of Central Florida. #q2connect15
  • 3. ! " ? Rapidly evolving cyber risks Financial institutions are critically dependent upon technology solutions A fundamental lack of understanding of cyber security threats & vulnerabilities CURRENT STATE #q2connect15 Overview of threat landscape
  • 4. Increase in number of attacks and attack methods $ % & ARMS RACE #q2connect15 Attackers are becoming increasingly adept at defeating security practices New & evolving techniques
 and vectors Attacks pose risks to financial services & critical infrastructure Institutions are not staying ahead of cybersecurity threats '
  • 5. STATS #q2connect15 Reference points from studies & publications About 110M Americans – equivalent to roughly 48% of U.S. adults – had some form of their personal data exposed in 2014. 110M Source: Ponemon Institute study,
 reported by CNN, May 2014 Of hacking victims in the business community didn't even realize they'd been hacked until they were told by vendors, government investigators or consumers.
 80% Source: 2014 Verizon Data Breach Investigations Report And according to a recent report, banks are being hit with cyber attacks “every minute of every day”.
 ( Source: Telegraph news report, Oct 2013
  • 6. ) Risk management
 & oversight  + ,- CYBERSECURITY BEST PRACTICES Threat intelligence, information sharing & collaboration Incident detection
 & response Security
 Controls Business continuity
 & cyber resiliency What you should be doing today #q2connect15
  • 7. 1. RISK MANAGEMENT & OVERSIGHT #q2connect15 LACK OF OVERALL UNDERSTANDING OF INHERENT RISK $ . Significant concerns OVERSIGHT OF
 THIRD-PARTY
 PROVIDERS
  • 8. RISK MANAGEMENT & OVERSIGHT #q2connect15 ⋆ Critical to success ENGAGE EXECUTIVE MANAGEMENT
 & BOARD INVOLVE KEY STAKEHOLDERS ACROSS THE ENTIRE ORGANIZATION "
  • 9. 0 Gathering, monitoring, analyzing, and sharing information from multiple sources on cyber threats and vulnerabilities #q2connect15 2. THREAT INTEL, INFO SHARING & COLLABORATION Definition
  • 10. FAILING TO KEEP
 UP-TO-DATE
 ON THREATS ABILITY TO CONSUME THREAT FEEDS & INCORPORATE INTO MONITORING TOOLS NOT PARTICIPATING IN VERTICAL SHARING ORGANIZATIONS THREAT INTEL, INFO SHARING & COLLABORATION #q2connect15 Call to action & 1 2
  • 11.  4 5 #q2connect15 INCORPORATE INTO CYBERSECURITY MONITORING TOOLS
 (SIEM) PARTICIPATE IN INDUSTRY VERTICAL SHARING ORGANIZATIONS
 (FS-ISAC) AVOID INFORMATION OVERLOAD 6 THREAT INTEL, INFO SHARING & COLLABORATION Crawl, walk, run SUBSCRIBE TO THREAT INTELLIGENCE DATA FEEDS
  • 12. Implement controls based on risk assessment activities 7 #q2connect15 Deploy preventative, detective, & corrective controls 8 Invest in appropriate staffing & expertise 3. SECURITY CONTROLS Starting point 9 Accept overall
 residual risk $
  • 13. 4. INCIDENT DETECTION & RESPONSE #q2connect15 RELY TOO HEAVILY ON SECURITY CONTROLS : ; Problems we are seeing IMPLEMENT FRAMEWORK TO MATURE IR PROGRAM
  • 14. #q2connect15 DETECT AND ISOLATE THREAT VECTOR ○ = Establish a process REMEDIATION EFFORTS MITIGATE REOCCURRENCE OF THE THREAT PERFORM TRIAGE, ANALYSIS AND INVESTIGATION BY SECURITY RESPONSE TEAMS > INCIDENT DETECTION & RESPONSE
  • 15. Ability to resume services or operations following an event #q2connect15 0 5. BUSINESS CONTINUITY & CYBER RESILIENCY Definition
  • 16. #q2connect15 LACK A STRATEGY TO KEEP ORGANIZATION FUNCTIONAL AFTER AN EVENT ? ? Challenges we face MAY NOT FULLY UNDERSTAND OPERATIONAL SIDE BUSINESS CONTINUITY & CYBER RESILIENCY
  • 17. #q2connect15 @ Establish a plan to weather the attack while incurring minimal impact to the organization BUSINESS CONTINUITY & CYBER RESILIENCY Institutions must begin to focus on resiliency, not recovery
  • 19. FFIEC CYBERSECURITY ASSESSMENT BASICS #q2connect15 In 2014, the FFIEC piloted a cybersecurity examination work program at more than 500 community institutions Purpose of assessment: evaluate institutions’ preparedness to mitigate cybersecurity risks >$
  • 20. ! A + Rapidly evolving cyber threats are facing FIs FFIEC INVOLVEMENT #q2connect15 Not a matter of if, but when an attack will occur Must increase the readiness and capabilities FFIEC wants to help financial institutions enhance their cyber security risk capabilities and overall preparedness
  • 21. FFIEC CYBERSECURITY ASSESSMENTS #q2connect15 ; Created in response to growing risks and complexity of attacks B C Coordinate with intelligence/law enforcement/ homeland security A dedicated support for community FI’s lacking resources
  • 22. D E F FFIEC CYBERSECURITY ASSESSMENTS Round 1 #q2connect15 FIs need to increase the focus of risk management / oversight Must increase the readiness and capabilities Overall preparedness and capability to respond to these risks
  • 23. G IDENTITY
 risk awareness, organizational understanding H ☼ =+ PROPOSED FRAMEWORK The FFIEC Cybersecurity Assessment’s Suggestions PROTECT
 develop and implement appropriate safeguards DETECT
 early alerting of cybersecurity events RESPOND
 appropriate activities to take action RECOVER
 resiliency; ability
 to restore services & capabilities #q2connect15
  • 24. #q2connect15 FFIEC ASSESSMENTS
 
 WHAT SHOULD FINANCIAL INSTITUTIONS EXPECT?
 HOW CAN YOU BE PREPARED?
  • 25. #q2connect15 Exhibit a fundamental understanding of inherent cyber risks 1 FFIEC ASSESSMENTS #q2connect15
  • 26. Be prepared to communicate and articulate your FI’s process for conducting and revisiting technology risk assessments HOW TO Demonstrate fundamental
 understanding of inherent risks #q2connect15 Organizational units must be involved in the risk assessment process Must be able to convey the bank’s awareness and identification of potential risks, including any third-party risks that may result from vendor relationships *This is the first place examiners will focus. Unfamiliarity or lack of knowledge related to this process will raise a red flag to dig deeper.
  • 28. Staff must be show they are well-versed in cyber security controls and industry recommendations ARTICULATE Approach for implementing
 controls to address risks #q2connect15 Be ready to show how the bank has aligned its cyber security strategy with its business strategy For example, how risks will be managed now and in the future
  • 30. Need to have evidence of programs for continuously monitoring the latest risks & threats to determine (along with the process for) implementing mitigations EXHIBIT Maturity readiness
 and preparation for
 adapting to threats #q2connect15 Must show how you’re leveraging and incorporating threat intelligence Show involvement in industry information sharing groups (FS-ISAC)
  • 31. #q2connect15 4 Show how executive management & board members are being engaged #q2connect15 FFIEC ASSESSMENTS #q2connect15
  • 32. Show how board members are being brought in specifically for their experience and knowledge around information technology and security CONVEY How executive level management
 and board level are being engaged #q2connect15 Must educate existing board members
 • Inform and engage
 • Share facts, speak in their language (RISK)
  • 33. #q2connect15 Updated BCP Booklet that contains 16-page appendix around business continuity was released in Feb 2015; continued emphasis on planning and resiliency Increased scrutiny on third-party relationships and how the FI is managing the oversight processes 
 FFIEC plans to issue a cyber security self assessment tool this year to assist institutions in evaluating their inherent cybersecurity risk and their risk management capabilities. 6 ALSO FOR CONSIDERATION Expect more to come J0
  • 34. CLOSING THOUGHTS #q2connect15 F Institutions are struggling to stay ahead of cyber security threats K Implement a framework for
 building a robust security strategy . Engage Executive Management ' Attackers becoming increasingly adept at defeating security practices $ Proper assessment of risk is critical! +Threat landscape will continue to evolve WE MUST ADAPT
  • 35. Q & AQ & A