July 03, 2014, Justin Orcutt, Regional Sales Manager
2014 is the year that the US Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) is turning its focus to cybersecurity, a looming threat to any and all companies that utilize the internet. In case you missed my last post, back in March the OCIE hosted a Cybersecurity Roundtable to discuss the importance of protecting consumer data and the security of market systems following a steep increase in breaches by its members. According to Securities and Exchange Commissioner Luis Aguilar:
“Cybersecurity has become an important topic in both the private and public sectors, and for good reason. Law enforcement and financial regulators have stated publicly that cyber-attacks are becoming both more frequent and more sophisticated. Indeed, according to one survey, U.S. companies experienced a 42% increase between 2011 and 2012 in the number of successful attacks they experienced per week.”
OCIE’s first initiative launched in April, when it announced plans to examine and assess the preparedness of over 50 registered broker-dealers and asset managers for a cyber-attack. They would look for specific documentation, including:
· Evidence of whether the organization conducts or requires risk assessments of vendors and business partners;
· Steps taken to detect unauthorized activity on networks and devices;
· Updates on whether the organization experienced any type of cyber-incident.
The announcement was a call for asset managers to officially step up their cybersecurity. It’s been almost three months since the SEC released the OCIE Cybersecurity Initiative in the National Exam Program Risk Alert National Program, and since then asset management companies have been moving quickly to address Cybersecurity. The Cybersecurity Initiative has elevated the issues of cybersecurity out of IT and into the board room (finally). The management at these firms are now acting swiftly to assess their firms’ level preparedness to defend against a cyber-attack and improve their security posture.
The Cybersecurity Initiative is helping identify a baseline that all broker-dealers need to have to protect against a breach. Awareness of the problem and a vision of the baseline, however, is only the first step to meeting the requirements of The Cybersecurity Initiative.
Coalfire has compiled a checklist to help those companies seeking to meet the guideline of The Cybersecurity Initiative:
1. Find a partner firm that is familiar with your business to help you
2. Quickly perform a review of your perimeter security via a penetration test
3. Notify your audit committee of your timeline to be prepared for an SEC Audit
4. Conduct a risk analysis
5. Update policies and procedures
6. Look to buy insurance (work with your partner to determine if it’s adequate for you)
7. See attached guidance on how to help audit departments
Read Aguilar’s entire speech: http://op.bna.com/ccw.nsf/id/mmey-9l6lwe/$File/Aguilar%20and%20Cyber.pdf
Read the OCIE’s Risk Alert here: http://www.sec.gov/ocie/announcement/Cybersecurity+Risk+Alert++%2526+Appendix+-+4.15.14.pdf
Justin Orcutt — Regional Sales Manager
Coalfire started in 2001 with a simple idea – cyber threats are increasing, compliance mandates are getting more complicated, and a well-designed cybersecurity program can help fuel your overall success.
Coalfire helps organizations comply with global financial, government, industry and healthcare mandates while helping build the IT infrastructure and security systems that will protect their business from security breaches and data theft. The company is a leading provider of IT advisory services for security in retail, payments, healthcare, financial services, higher education, hospitality, government and utilities.
The Coalfire Board of Directors provides invaluable guidance for the organization and reflects Coalfire’s dedication to achieving success for our customers.
Coalfire’s executive leadership team comprises some of the most knowledgeable professionals in cybersecurity, representing many decades of experience leading and developing teams to outperform in meeting the security challenges of commercial and government clients. With diverse backgrounds in IT systems security, governmental security, compliance, and reducing risk while implementing the latest enabling technologies (such as the Cloud and IoT), our leaders understand the challenges customers face.
With a passion for quality, Coalfire uses a process-driven quality approach to improve the customer experience and deliver unparalleled results.
Created in honor of the late co-founder of Coalfire, the Richard E. Dakin Fund at The Denver Foundation is supporting scholarship programs at several universities for promising college students studying cybersecurity and related fields.
Security is a team game. If your organization values both independence and security, perhaps we should become partners.
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Technology innovations are enabling new methods for corporations and governments to operate and driving changes in consumer behavior. The companies delivering these technology products are facilitating business transformation that provides new operating models, increased efficiency and engagement with consumers as businesses seek a competitive advantage.
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Cyber risk management, advisory, technology and compliance services. Manage risk and maximize return on investment to prevent data breaches and theft. Coalfire’s solutions are led by a team of industry experts that help enterprise organizations understand a wide range of compliance and risk management initiatives, which enables a consistent cybersecurity framework across the organization.
Expert assessments that provide an accurate understanding of what you are trying to protect, the inherent and residual cyber risk to your enterprise and the maturity of the your security program and underlying controls
Customized services to help CISOs and Senior Management develop cybersecurity strategy, implement controls, and govern a security program
Adopt a proactive approach to cybersecurity
Make more informed security-related decisions
Design, engineer, and scale with confidence
Certification and Accreditation (C&A) process for DoD
Get FedRAMP authorized with the leading 3PAO
Reducing Financial IT Security Risk
Meet your FISMA authorization needs
General Data Protection Regulation
Health data protection for all shapes and sizes
The most rigorous approach to meeting HIPAA requirements
An internationally recognized approach to information security
ITAR, EAR, and DFARS Advisory and Assessment
Cyber security for electric grid critical infrastructure
Protect Controlled Unclassified Information for Nonfederal
Payment Application Security Validation
PCI Data Security Standard Compliance
Have you suffered a data breach of cardholder data?
Establish and report controls to differentiate your organization
Demonstrate your commitment to cybersecurity
Malware and Vulnerability Research, Open Source Tools, and Opinions
Understand vulnerabilities and implement remediation before they’re exploited
Obtain, preserve, and examine digital evidence
Secure the design, development, and deployment of your applications
Test your organization’s defense against a simulated real-world attack
Secure physical and digital IoT solutions with advisory, assessment and technical testing for makers, operators and users to empower the way we live and work.
Control your Compliance
Easily identify IT vulnerabilities