FFIEC information
technology audits -
As a former bank examiner
with over 40 years IT audit experience, I will bring an examiner's
perspective to the FFIEC information technology audit for bankers in
Texas, New Mexico, Colorado, and Oklahoma. For more information go
to
On-site FFIEC IT Audits.
FYI
- Despite increased cyber-risk awareness, poor password hygiene
still rules - It was often suggested in the past by many that lack
of appreciation of true cyber-threats posed by hackers made people
complacent about their password habits, but new research has
revealed that even though people are now more aware of security best
practices than in the past, their password management has remained
largely unchanged.
https://www.scmagazine.com/despite-increased-cyber-risk-awareness-poor-password-hygiene-still-rules/article/763215/
Trump administration looking to rescind cyberwarfare approval
process - The Trump administration is reportedly looking to rescind
Presidential Policy Directive 20 an important policy memorandum that
currently guides the approval process for government-backed
cyberattacks.
https://www.scmagazine.com/the-framework-in-question-has-been-a-point-of-frustration-inside-the-pentagon-long-before-trump-came-into-office/article/763394/
After Equifax breach, major firms still rely on same flawed software
- At least seven tech giants still use the vulnerable software that
hackers exploited to attack Equifax last year.
https://www.zdnet.com/article/after-equifax-breach-companies-rely-on-same-flawed-software/
FBI Latest Internet Crime Report Released - IC3 Says Victim Losses
Exceeded $1.4 Billion in 2017.
https://www.fbi.gov/news/stories/2017-internet-crime-report-released-050718
Georgia governor vetoes anti-bug bounty bill - Cybersecurity
officials breathed a sigh of relief as Georgia Governor Nathan Deal
vetoed state bill 315 that would have essentially have made it a
crime to hack into a computer system, even to simply find its
weaknesses, and gave the O.K. for companies to hack back against
hackers.
https://www.scmagazine.com/georgia-governor-vetoes-anti-bug-bounty-bill/article/764858/
ATTACKS, INTRUSIONS, DATA THEFT & LOSS
FYI
- Twitter urges users to change passwords after finding bug in
password storage system - Whether serendipitous or ironic, Global
Password Day found Twitter advising users to change their passwords
after a bug in its password storage system “unmasked” the passwords
in an internal log.
https://www.scmagazine.com/twitter-urges-users-to-change-passwords-after-finding-bug-in-password-storage-system/article/763431/
FLEETCOR Technologies gift card systems breached - FLEETCOR
Technologies, a $2.25 billion company specializing in fuel cards and
workforce payment products and services, publicly disclosed this
past Thursday that its gift card systems were accessed last month by
an unauthorized party.
https://www.scmagazine.com/fleetcor-technologies-gift-card-systems-breached/article/763965/
Trojanized CMS plug-ins infect thousands of websites in tech support
scam campaign - A recently uncovered tech support scam campaign has
compromised thousands of websites with malicious ad injections that
redirect users to a browser locker page that claims their computers
are infected.
https://www.scmagazine.com/trojanized-cms-plug-ins-infect-thousands-of-websites-in-tech-support-scam-campaign/article/764473/
Cryptojacking campaign hits 400 Drupal-based sites, many run by
governments and universities - Nearly 400 websites running outdated
and vulnerable versions of the Drupal content management system,
many affiliated with governments and educational institutions, were
recently discovered to be infected with Coinhive-based cryptomining
software.
https://www.scmagazine.com/cryptojacking-campaign-hits-400-drupal-based-sites-many-run-by-governments-and-universities/article/764827/
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WEB SITE COMPLIANCE -
This week continues our series on
the FDIC's Supervisory Policy on Identity Theft.
(Part
4 of 6)
Supervisory Action
As a result of guidelines issued by the FDIC, together with other
federal agencies, financial institutions are required to develop and
implement a written program to safeguard customer information,
including the proper disposal of consumer information (Security
Guidelines).5 The FDIC considers this programmatic requirement to be
one of the foundations of identity theft prevention. In guidance
that became effective on January 1, 2007, the federal banking
agencies made it clear that they expect institutions to use stronger
and more reliable methods to authenticate the identity of customers
using electronic banking systems. Moreover, the FDIC has also issued
guidance stating that financial institutions are expected to notify
customers of unauthorized access to sensitive customer information
under certain circumstances. The FDIC has issued a number of other
supervisory guidance documents articulating its position and
expectations concerning identity theft. Industry compliance with
these expectations will help to prevent and mitigate the effects of
identity theft.
Risk management examiners trained in information technology (IT)
and the requirements of the Bank Secrecy Act (BSA) evaluate a number
of aspects of a bank's operations that raise identity theft issues.
IT examiners are well-qualified to evaluate whether banks are
incorporating emerging IT guidance into their Identity Theft
Programs and GLBA 501(b) Information Security Programs; responsibly
overseeing service provider arrangements; and taking action when a
security breach occurs. In addition, IT examiners will consult with
BSA examiners during the course of an examination to ensure that the
procedures institutions employ to verify the identity of new
customers are consistent with existing laws and regulations to
prevent financial fraud, including identity theft.
The FDIC has also issued revised examination procedures for the
Fair Credit Reporting Act (FCRA), through the auspices of the
Federal Financial Institutions Examination Council's (FFIEC)
Consumer Compliance Task Force. These procedures are used during
consumer compliance examinations and include steps to ensure that
institutions comply with the FCRA's fraud and active duty alert
provisions. These provisions enable consumers to place alerts on
their consumer reports that require users, such as banks, to take
additional steps to identify the consumer before new credit is
extended. The procedures also include reviews of institutions'
compliance with requirements governing the accuracy of data provided
to consumer reporting agencies. These requirements include the
blocking of data that may be the result of an identity theft.
Compliance examiners are trained in the various requirements of the
FCRA and ensure that institutions have effective programs to comply
with the identity theft provisions. Consumers are protected from
identity theft through the vigilant enforcement of all the
examination programs, including Risk Management, Compliance, IT and
BSA.
The Fair and Accurate Credit Transactions Act directed the FDIC
and other federal agencies to jointly promulgate regulations and
guidelines that focus on identity theft "red flags" and customer
address discrepancies. As proposed, the guidelines would require
financial institutions and creditors to establish a program to
identify patterns, practices, and specific forms of activity that
indicate the possible existence of identity theft. The proposed
joint regulation would require financial institutions and creditors
to establish reasonable policies to implement the guidelines,
including a provision requiring debit and credit card issuers to
assess the validity of a request for a change of address. In
addition, the agencies proposed joint regulations that provide
guidance regarding reasonable policies and procedures that a user of
consumer reports must employ when the user receives a notice of
address discrepancy. When promulgated in final form, these joint
regulations and guidelines will comprise another element of the
FDIC's program to prevent and mitigate identity theft.
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FFIEC IT SECURITY -
We continue our review of the OCC Bulletin about
Infrastructure Threats and Intrusion Risks. This week we review
security strategies and plans.
Senior management and the board of directors are responsible for
overseeing the development and implementation of their bank's
security strategy and plan. Key elements to be included in those
strategies and plans are an intrusion risk assessment plan, risk
mitigation controls, intrusion response policies and procedures, and
testing processes. These elements are needed for both internal and
outsourced operations.
The first step in managing the risks of intrusions is to assess
the effects that intrusions could have on the institution. Effects
may include direct dollar loss, damaged reputation, improper
disclosure, lawsuits, or regulatory sanctions. In assessing the
risks, management should gather information from multiple sources,
including (1) the value and sensitivity of the data and processes to
be protected, (2) current and planned protection strategies, (3)
potential threats, and (4) the vulnerabilities present in the
network environment. Once information is collected, management
should identify threats and the likelihood of those threats
materializing, rank critical information assets and operations, and
estimate potential damage.
The analysis should be used to develop an intrusion protection
strategy and risk management plan. The intrusion protection strategy
and risk management plan should be consistent with the bank's
information security objectives. It also should balance the cost of
implementing adequate security controls with the bank's risk
tolerance and profile. The plan should be implemented within a
reasonable time. Management should document this information, its
analysis of the information, and decisions in forming the protection
strategy and risk management plan. By documenting this information,
management can better control the assessment process and facilitate
future risk assessments.
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NATIONAL INSTITUTE OF STANDARDS
AND TECHNOLOGY -
We continue
the series on the National Institute of Standards and Technology
(NIST) Handbook.
Chapter 16 - TECHNICAL CONTROLS - IDENTIFICATION AND
AUTHENTICATION
16.1.2 Cryptographic
Keys
Although the authentication derived from the knowledge of a
cryptographic key may be based entirely on something the user knows,
it is necessary for the user to also possess (or have access to)
something that can perform the cryptographic computations, such as a
PC or a smart card. For this reason, the protocols used are
discussed in the Smart Tokens section of this chapter. However, it
is possible to implement these types of protocols without using a
smart token. Additional discussion is also provided under the Single
Log-in section.
16.2 I&A Based on Something the User Possesses
Although some techniques are based solely on something the user
possesses, most of the techniques described in this section are
combined with something the user knows. This combination can provide
significantly stronger security than either something the user knows
or possesses alone.
Objects that a user possesses for the purpose of I&A are called
tokens. This section divides tokens into two categories: memory
tokens and smart tokens, which we will cover in the next two issues. |