Seven Trends . . .
…that small bank Information Security Officers face in 2023
Another one of those Dan’s New Leaf Posts, meant to inspire thought about IT Governance . . . .
Welcome to the Magnificent Seven, my annual predictive article about the seven trends in technology that will impact the Information Security Officers of small banks (under five billion in assets). My intent: help you organize your thoughts for the upcoming year.
So, what issues do we think Information Security Officers will tackle in 2023?
Normally we present our top seven trends in reverse order, in the spirit of a typical “David Letterman Top 10 List,” where we save the best for last, but including responding to risk, we feel the number one trend often has such a wide-reaching impact that it impacts the other six trends. So . . . no David Letterman Style list this time. Instead, let’s just jump to the number one trend of 2023.
And no, the number one trend is not the ongoing pandemic, though it was started and accelerated during the recovery. Instead, the number one trend is what I’m calling The Disappearance. The Disappearance is simply a reverse-way of saying, “the virtualization of everything.”
Everything physical is disappearing. Servers . . . disappeared. Phone systems. Gone. Conferences and workshops – virtual. Cameras . . . replaced by the webcams in our endpoints. I mean, when is the last time you saw your auditor in person? Your examiner?
Even our meetings are disappearing.
This started a decade ago, when our servers continued their increase in numbers, but not in physical rack-space, as virtualization became the norm. What started as virtual machines is now virtual meetings, virtual training, virtual phone systems, and even virtual security systems. Taking this further: cloud computing is now in the late majority phase of adoption, and we’re even putting our networks in the cloud with Azure, AWS, etc.
In 2023, even our employees are disappearing, adding to our stress, and increasing the risk of the insider threat.
The second trend is actually a superset of the first: the pent-up adoption of new technologies. The momentum of new technology adoption that we spoke of in recent years will continue to make this trend more and more pertinent, and we believe 2023 will see the continuing adoption of many new technologies including the virtualization of everything. As the “late majority” of many technologies was supposed to start over a year ago, we see small banks planning everything from finally pulling the trigger on new mobile banking products to identity access management to expanding and upgrading their security capabilities. Meanwhile, the paradigm shift created by the pandemic . . . with implications ranging from the final mobilization of endpoints to working from home . . . The Disappearance . . . is causing us to adopt new controls ranging from Network Access Control or Conditional Access on our perimeters to Endpoint Detection and Response (EDR), Data Loss Prevention (DLP), and Identity and Access Management (IAM). Meanwhile, new technologies leveraging big data, machine learning, neural networks and even the seeds of artificial intelligence tactics are still in the mix. And with an eye on the risk of this, many of us are planning to adopt new technologies as we “look forward to the recovery.” This leads to the third and fourth trends: MFA Everywhere, and Endpoint and Cloud Security. In 2022, we learned that this includes training our employees on MFA (and the risk of a silver bullet mentality). And most of us implemented endpoint detection and response.
All this adoption of new technologies right during The Disappearance is requiring us to “try a different perspective” on technology risk management. While we were already growing concerned that the FFIEC’s Cybersecurity Assessment Tool was antiquated, management is growing increasingly apt to “micro-manage” response to the ransomware threat, out of legitimate concern. Though the FFIEC’s release of the Architecture, Infrastructure, and Operations Guidance has been a step in the right direction and may end up changing how we do Technology Planning, it is always a good idea to look for other organizations maintaining well-refreshed bodies of knowledge. Thus, when we saw the Conference of State Bank Supervisors release the Ransomware Self-Assessment Tool (RSAT), we started suggesting that even non-state bank ISOs consider answering the 16 questions in an exercise with their management teams. But beyond that, we are starting to see banks look at adopting the NIST Cybersecurity Standard, the CIS Top 20 Controls, or even Cybersecurity Profile published by the ABA endorsed Cyber Risk Institute. Each of these frameworks are updated far more regularly than the FFIEC guidance has been. The CIS Top 20 has been updated at least nine times since 2014, if I counted right.
We still have not seen the FFIEC make good on their threat to update the vendor management guidance as well as Information Security handbook. We believe that an update to both of these critical frameworks are well overdue, and thus we are leaving space in our calendar for them to be updated in 2023. Given the current threat trends, we believe a focus on the CIS top 20 controls, the NIST cybersecurity framework, and the RSAT will be sufficient, until vendor management and Information Security is updated.
All three of these frameworks lead a community-based bank, by the way, to adopt MFA everywhere along with Endpoint and Cloud Security as basic controls. Beware: and maybe by way of disclosure, but each of these frameworks will also lead you to relying more heavily on the production of a good SIEM. While this is self-serving, we maintain the need to try a different perspective can be exuded by the sixth trend.
The sixth trend gives us pause. In the era of major breaches and ransomware attacks, we have come to the conclusion that in order to make our networks, and by extension our customer’s data, safer, we should start doing the sorts of things that we do when we suspect a breach. Acting like we’ve already been breached is a mindset that can help us think of the things that we may otherwise not in times of relative security. Things like Zero Trust, Network Segmentation, strengthened Admin account security, and heightened and more intense awareness. Doing all the due diligence on forensics firms and establishing a relationship with a good one is important, as well as interfacing with any MSSP or MSOCs you may have. If you have someone watching your network, isn’t it a good idea to ensure the lines of communication are open and well used?
Speaking of heightened and intense awareness, that brings us to our seventh and final trend. We should apply awareness in all directions! What does that mean exactly? Instead of doing awareness training once a year, we should take a “drip” approach to the process. Making sure that EVERYONE in the institution is made aware of awareness training topics is important, but beyond that you also need to give everyone this information regularly, teach them that information, and then test them on that information. It’s like making a dough. The water (awareness) is dripped into the flour (the bank) and the continuous kneading (testing) is what will make it dough and hold together when we introduce it against an outside force, like a fan (Technology Risk). Decreasing the audit cycle will help with the repetition to help people remember the training especially when focusing on social engineering. The testing could be ongoing and mixed social engineering, continuous penetration testing, and testing controls that we may feel are basic and easy. We also believe that Incident Response Testing is what we like to call the One Test and is extremely important.
In 2023, the Magnificent Seven as a Sentence:
So, to summarize, the top seven trends for 2023, according to Dan:
1) The Disappearance,
2) plus the Pent-up Adoption of New Technologies,
3) causes us to apply MFA Everywhere
4) and revisit Endpoint and Cloud Security,
5) as we try a different perspective . . .
6) like acting like we’ve already been breached
7) causing us to apply awareness in all directions!
Original article by Dan Hadaway CRISC CISA CISM. Founder and Managing Partner, infotex
“Dan’s New Leaf” is a “fun blog to inspire thought in the area of IT Governance.”