R. Kinney Williams - Yennik, Inc.
R. Kinney Williams
Yennik, Inc.

Internet Banking News
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Remote offsite and Onsite FFIEC IT Audits

July 25, 2021

Newsletter Content FFIEC IT Security FFIEC & ADA Web Site Audits
Web Site Compliance NIST Handbook Penetration Testing
Does Your Financial Institution need an affordable cybersecurity Internet security audit?  Yennik, Inc. has clients in 42 states that rely on our cybersecurity audits to ensure proper Internet security settings and to meet the independent diagnostic test requirements of FDIC, OCC, FRB, and NCUA, which provides compliance with Gramm-Leach Bliley Act 501(b) as well as the penetration test complies with the FFIEC Cybersecurity Assessment Tool regarding resilience testing The cybersecurity penetration audit and Internet security testing is an affordable-sophisticated process than goes far beyond the simple scanning of ports.  The audit focuses on a hacker's perspective, which will help you identify real-world cybersecurity weaknesses.  For more information, give R. Kinney Williams a call today at Office/Cell 806-535-8300 or visit http://www.internetbankingaudits.com/.
Virtual/remote IT audits - I am performing virtual/remote FFIEC IT audits for banks and credit unions.  I am a former bank examiner with 40 years of IT auditing experience.  Please contact R. Kinney Williams at examiner@yennik.com from your bank's email and I will send you information and fees.  All correspondence is confidential.FYI - Two cyber insurance industry initiatives grapple with rise of ransomware - Twice in the past few weeks, insurers have joined together in response to the spiraling ransomware attacks that have rocked their industry. https://www.cyberscoop.com/cyberacuview-apcia-cyber-insurance-ransomware/

FYI - US government launches plans to cut cybercriminals off from cryptocurrency - The White House on Thursday announced a flurry of actions launched by a new interagency task force to combat ransomware. https://www.cyberscoop.com/us-government-crypocurrency-ransomware-criminals-treasury-state-reward/

CISA orders federal agencies to patch Windows PrintNightmare bug - A new emergency directive issued by the Cybersecurity and Infrastructure Security Agency (CISA) orders federal agencies to mitigate the actively exploited Window Print Spooler vulnerability on their networks. https://www.bleepingcomputer.com/news/security/cisa-orders-federal-agencies-to-patch-windows-printnightmare-bug/

Cybersecurity risk: The number of employees going around IT security may surprise you - The findings detail a complex security balancing act between IT teams and users; especially in the age of remote work and virtual collaboration at scale. https://www.techrepublic.com/article/cybersecurity-risk-the-number-of-employees-going-around-it-security-may-surprise-you/

Pittsburgh medical center to pay $2.65M in settlement for 2014 data breach - The University of Pittsburgh Medical Center has agreed to a $2.65 million settlement with the 66,000 employees impacted by the theft of data from its human resource database in 2014. https://www.scmagazine.com/news/backup-and-recovery/pittsburgh-medical-center-to-pay-2-65m-in-settlement-for-2014-data-breach

ATTACKS, INTRUSIONS, DATA THEFT & LOSS

FYI - Summer of SAM - incorrect permissions on Windows 10/11 hives - If you opened Twitter today you were probably flooded with news about the latest security issue with Windows. For those that have ISC as their home page (yay!) the issue is the following: apparently starting with Windows 10 1809 (hey, that’s a version from 2018) Microsoft messed up permissions on the SAM and SYSTEM hives which became readable for any user on the system. https://isc.sans.edu/forums/diary/Summer+of+SAM+incorrect+permissions+on+Windows+1011+hives/27652/

Law firm for Ford, Boeing, Exxon, Marriott, Walgreens, and more hacked in ransomware attack - The law firm said attackers may have accessed Social Security numbers, passport numbers, payment card information, medical information and biometric data. https://www.zdnet.com/article/law-firm-for-ford-boeing-exxon-marriott-walgreens-and-more-hacked-in-ransomware-attack/

Cyberattack on Moldova's Court of Accounts destroyed public audits - Moldova's "Court of Accounts" has suffered a cyberattack leading to the agency's public databases and audits being destroyed. https://www.bleepingcomputer.com/news/security/cyberattack-on-moldovas-court-of-accounts-destroyed-public-audits/

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WEB SITE COMPLIANCE -
Over the next few weeks, we will cover some of the issues discussed in the "Risk Management Principles for Electronic Banking" published by the Basel Committee on Bank Supervision.
  
  Executive Summary
  
  
Continuing technological innovation and competition among existing banking organizations and new entrants have allowed for a much wider array of banking products and services to become accessible and delivered to retail and wholesale customers through an electronic distribution channel collectively referred to as e-banking. However, the rapid development of e-banking capabilities carries risks as well as benefits. 
  
  The Basel Committee on Banking Supervision expects such risks to be recognized, addressed and managed by banking institutions in a prudent manner according to the fundamental characteristics and challenges of e-banking services. These characteristics include the unprecedented speed of change related to technological and customer service innovation, the ubiquitous and global nature of open electronic networks, the integration of e-banking applications with legacy computer systems and the increasing dependence of banks on third parties that provide the necessary information technology. While not creating inherently new risks, the Committee noted that these characteristics increased and modified some of the traditional risks associated with banking activities, in particular strategic, operational, legal and reputational risks, thereby influencing the overall risk profile of banking. 
  
  Based on these conclusions, the Committee considers that while existing risk management principles remain applicable to e-banking activities, such principles must be tailored, adapted and, in some cases, expanded to address the specific risk management challenges created by the characteristics of e-banking activities. To this end, the Committee believes that it is incumbent upon the Boards of Directors and banks' senior management to take steps to ensure that their institutions have reviewed and modified where necessary their existing risk management policies and processes to cover their current or planned e-banking activities. The Committee also believes that the integration of e-banking applications with legacy systems implies an integrated risk management approach for all banking activities of a banking institution.


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FFIEC IT SECURITY - We continue our series on the FFIEC interagency Information Security Booklet.  
   
   SECURITY CONTROLS - IMPLEMENTATION
   

   LOGICAL AND ADMINISTRATIVE ACCESS CONTROL 
   
   Access Rights Administration (3 of 5)
   
   
The enrollment process establishes the user's identity and anticipated business needs to information and systems. New employees, IT outsourcing relationships, and contractors may also be identified, and the business need for access determined during the hiring or contracting process.
   
   During enrollment and thereafter, an authorization process determines user access rights. In certain circumstances the assignment of access rights may be performed only after the manager responsible for each accessed resource approves the assignment and documents the approval. In other circumstances, the assignment of rights may be established by the employee's role or group membership, and managed by pre - established authorizations for that group. Customers, on the other hand, may be granted access based on their relationship with the institution.
   
   Authorization for privileged access should be tightly controlled. Privileged access refers to the ability to override system or application controls. Good practices for controlling privileged access include
   
   ! Identifying each privilege associated with each system component,
   
   ! Implementing a process to allocate privileges and allocating those privileges either on a need - to - use or an event - by - event basis,! Documenting the granting and administrative limits on privileges,
   
   ! Finding alternate ways of achieving the business objectives,
   
   ! Assigning privileges to a unique user ID apart from the one used for normal business use,
   
   ! Logging and auditing the use of privileged access,
   
   ! Reviewing privileged access rights at appropriate intervals and regularly reviewing privilege access allocations, and
   
   ! Prohibiting shared privileged access by multiple users.


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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 15 - PHYSICAL AND ENVIRONMENTAL SECURITY
 
 15.7 Mobile and Portable Systems
 
 The analysis and management of risk usually has to be modified if a system is installed in a vehicle or is portable, such as a laptop computer. The system in a vehicle will share the risks of the vehicle, including accidents and theft, as well as regional and local risks.
 
 Portable and mobile share an increased risk of theft and physical damage. In addition , portable systems can be "misplaced" or left unattended by careless users. Secure storage of laptop computers is often required when they are not in use.
 
 If a mobile or portable system uses particularly valuable or important data, it may be appropriate to either store its data on a medium that can be removed from the system when it is unattended or to encrypt the data. In any case, the issue of how custody of mobile and portable computers are to be controlled should be addressed. Depending on the sensitivity of the system and its application, it may be appropriate to require briefings of users and signed briefing acknowledgments.
 
 Encryption of data files on stored media may also be a cost-effective precaution against disclosure of confidential information if a laptop computer is lost or stolen.
 
 15.8 Approach to Implementation
 

 Like other security measures, physical and environmental security controls are selected because they are cost-beneficial. This does not mean that a user must conduct a detailed cost-benefit analysis for the selection of every control. There are four general ways to justify the selection of controls:
 
 1) They are required by law or regulation. Fire exit doors with panic bars and exit lights are examples of security measures required by law or regulation. Presumably, the regulatory authority has considered the costs and benefits and has determined that it is in the public interest to require the security measure. A lawfully conducted organization has no option but to implement all required security measures.
 
 2) The cost is insignificant, but the benefit is material. A good example of this is a facility with a key-locked low-traffic door to a restricted access. The cost of keeping the door locked is minimal, but there is a significant benefit. Once a significant benefit/minimal cost security measure has been identified, no further analysis is required to justify its implementation.
 
 3) The security measure addresses a potentially "fatal" security exposure but has a reasonable cost. Backing up system software and data is an example of this justification . For most systems, the cost of making regular backup copies is modest (compared to the costs of operating the system), the organization would not be able to function if the stored data were lost, and the cost impact of the failure would be material. In such cases, it would not be necessary to develop any further cost justification for the backup of software and data. However, this justification depends on what constitutes a modest cost, and it does not identify the optimum backup schedule. Broadly speaking, a cost that does not require budgeting of additional funds would qualify.
 
 4) The security measure is estimated to be cost-beneficial. If the cost of a potential security measure is significant, and it cannot be justified by any of the first three reasons listed above, then its cost (both implementation and ongoing operation) and its benefit (reduction in future expected losses) need to be analyzed to determine if it is cost-beneficial. In this context, cost-beneficial means that the reduction in expected loss is significantly greater than the cost of implementing the security measure.
 
 Arriving at the fourth justification requires a detailed analysis. Simple rules of thumb do not apply. Consider, for example, the threat of electric power failure and the security measures that can protect against such an event. The threat parameters, rate of occurrence, and range of outage durations depend on the location of the system, the details of its connection to the local electric power utility, the details of the internal power distribution system, and the character of other activities in the building that use electric power. The system's potential losses from service interruption depends on the details of the functions it performs. Two systems that are otherwise identical can support functions that have quite different degrees of urgency. Thus, two systems may have the same electric power failure threat and vulnerability parameters, yet entirely different loss potential parameters.
 
 Furthermore, a number of different security measures are available to address electric power failures. These measures differ in both cost and performance. For example, the cost of an uninterruptible power supply (UPS) depends on the size of the electric load it can support, the number of minutes it can support the load, and the speed with which it assumes the load when the primary power source fails. An on-site power generator could also be installed either in place of a UPS (accepting the fact that a power failure will cause a brief service interruption) or in order to provide long-term backup to a UPS system. Design decisions include the magnitude of the load the generator will support, the size of the on-site fuel supply, and the details of the facilities to switch the load from the primary source or the UPS to the on-site generator.
 
 This example shows systems with a wide range of risks and a wide range of available security measures (including, of course, no action), each with its own cost factors and performance parameters.

PLEASE NOTE:
 
Some of the above links may have expired, especially those from news organizations.  We may have a copy of the article, so please e-mail us at examiner@yennik.com if we can be of assistance.