R7-2021

Top Seven Risks . . .

that small bank Information Security Officers face in 2021
Another one of those Dan’s New Leaf Posts, meant to inspire thought about IT Governance . . . .

Once again, I compile this list in preparation for updating our normal board of directors awareness training PowerPoints and movies and such.  This list is meant for community-based banks, but could apply to small businesses.  But how this works can be illustrated with our decision to NOT include this new risk:

“Very well-funded nation state actors will continue to perform high profile attacks.”

While this is indeed a very important risk we are all worrying about now, the nation states are going after targets less hardened than banks, which unfortunately happen to be our nation’s networks.

While we agree there is a slight likelihood banks can be affected by this, we believe there are bigger fish for smaller banks to fry.  (However: please note we disagree with the notion that there is simply no way to defend against a well-funded nation state.)

So let’s just cut to this year’s list:

Ransomware. Three controls to focus on . . . vulnerability management, awareness training, and a new guidance called the RSAT for state-chartered financial institutions. The Ransomware Self-Assessment Tool is something you might want to consider using even if you are not a state-chartered bank. And while “vulnerability management” and previously “patch management” has been on this list in the past, we decided to combine it all into one risk trend: Ransomware.

Working from Home Risk, which can be mitigated by awareness training, multifactor authentication, and endpoint security controls including endpoint scanning or network access controls. Cloud security risk controls are also important here.

Cloud Security Risk is finally on the top half of this list. See “The Disappearance” in our trend article (m7.infotex.com).  Mitigation should include inventorying cloud sites and insisting on MFA everywhere PII is stored. The movement to Zero Trust Architecture will definitely assist with this.  But for now, configuration audits (like the CISA O365 Mitigations) will ensure proper security.

The Insider Threat was already starting to emerge as a high risk yet to be mitigated prior to the pandemic, when insiders are now working at home and may be more emboldened. To mitigate: put fraud on your incident response team and reach out to your MSSP.

The next two risks (5 and 6) have been on my annual Top Seven Risks list since I first started publishing it. Users will still make mistakes. Vendors will still make mistakes.  It’s why vulnerability management is so important.  And know that supply chain attacks are on the rise.  The Solar Winds incident shows us again that even if we did nothing wrong, we could be spending hours responding to vendor incidents.  In other words, if you as a bank are worried about nation states, be worried about them attacking your vendors, more than them attacking you.  Sorry to bore technical people with the need for vendor management, but defending our supply chain is more about reviewing audit reports than configuring our own networks.  However, these risks are exacerbated by the fact that they are working at home and they are FATIGUED. This pandemic is hard on everybody, especially “people-people” like bankers. The risk has never been this high. We need to patiently increase our awareness efforts, while streamlining and simplifying the message. Awareness programs have never been more important.

Which brings me to the final risk: we are adopting a lot of new technologies right when our employees are least able to absorb and handle change. Again, awareness is nine elevenths of the battle, so as long as we are aware of this heightened risk, we can get through it. But we must recognize it. Our employees are fatigued. New Technology Adoption will be more risky than normal, and it is already a high risk.

So, to summarize, the top seven risks community-based banks face in 2021 are:

1) Ransomware
2) Working from Home
3) Cloud Security
4) Insider Threat
5) Fatigue and User Errors
6) Fatigue and Vendor Errors
7) Fatigue and New Technology Adoption

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.”