In remarks to the American Bankers Association Summer Leadership Meeting on July 14, 2015, Deputy Secretary of the Treasury Sarah Bloom Raskin addressed issues especially timely and important to financial institutions — cybersecurity and cyber-resiliency. Recognizing the unique threat cyber-attacks pose to the banking system, the Treasury Department has made ensuring cybersecurity a high priority. Deputy Secretary Raskin noted that the litany of cyber-risks could be “uniquely devastating” to the financial sector, which is heavily invested in e-commerce and e-banking.
Based on the assessment of the unique risks to the financial sector, Deputy Secretary Raskin posed 10 questions designed to better equip the banking leaders in their efforts to oversee cybersecurity efforts at their respective institutions:
- Does our bank embed cybersecurity into our governance, control and risk management systems?
- Have we remained vigilant about systematically identifying our key assets, those that provide high-value targets for malicious cyber actors?
- Have we tailored our security controls to the specific cyber risks presented by each key network, system or set of sensitive data?
- How do we prioritize the implementation of enhanced controls around key networks, systems and sensitive data?
- Have we reviewed the FFIEC Cybersecurity Assessment Tool and appropriately incorporated it into our approach to cyber-risk management?
- Have we designated specific professionals to handle our cybersecurity strategy and provided them with the authority, resources and access they need to effectively perform their work?
- Have we trained our personnel on our cybersecurity policies?
- How do we ensure that our insurance coverage matches our cyber-related risks?
- Does our cyber-risk insurance impose “minimum required practices,” which may lead to denial of coverage if not followed?
- Do we practice basic cyber hygiene?
- Do we require multi-factor authentication before allowing access to our networks, systems and data?
- Have we restricted special, high-level access to only those who need it?
- Are we doing regular maintenance and consistently patching our software?
- Are we effectively scanning our systems for malicious activity?
Deputy Secretary Raskin’s entire remarks can be found here.
For more information on other financial institution cybersecurity and privacy matters, please contact the author, Anthony McFarland.