Simplify Compliance for FFIEC-NCUA

The Federal Financial Institutions Examination Council (FFIEC) is the inter-agency body of the United States government empowered to prescribe uniform principles, standards, and report forms for the federal examination of financial institutions. It is empowered by various entities, including the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the Consumer Financial Protection Bureau (CPFB).

The FFIEC makes recommendations to promote uniformity in the supervision of financial institutions. Regulated financial institutions must comply with the guidelines of FFIEC consistent with the Gramm-Leach-Bliley Act of 1999 (GLBA). FFIEC documented the necessary controls for compliance in the “FFIEC Information Security Handbook” and subsequently provided a cybersecurity assessment tool to help financial institutions improve their cybersecurity postures.

Who Is Affected

The FFIEC/NCUA guidance and supervision affects federally supervised financial institutions, their holding companies, and the nonfinancial institution subsidiaries of those institutions and holding companies. This includes banks insured by the FDIC, credit unions supervised by the NCUA, and national banks and their subsidiaries supervised by the OCC. Complying with FFIEC/NCUA guidance can be a challenge for financial institutions that have limited resources, but Arctic Wolf helps organizations meet many of the FFIEC/ NCUA requirements with a turnkey SOC-as-a-service solution.

Mapping FFIEC/NCUA to Arctic Wolf SOC-as-a-Service

Arctic Wolf SOC-as-a-service helps companies with their FFIEC compliance projects with less complexity than traditional security tools, and at a fraction of the total cost and time. Arctic Wolf integrates cloud-based software, analytics, and expert services to assess risks, scan for vulnerabilities, and detect and block threats to applications and environments. In doing so, it helps your organization improve its security posture. Arctic Wolf provides you a dedicated Concierge Security™ Team (CST) of security experts who augment your in-house IT team by monitoring your internal and external networks, devices, and IT environment 24/7.

"Cybersecurity threats continually transform and mature. Arctic Wolf, however, delivers the tools and expertise to continually monitor our environment and alert on these threats. I rest easier knowing our operations are monitored 24x7 with the Arctic Wolf SOC-as-a-service."

AJ Tasker, Vice President and Director of IT, First United Bank & Trust

Your CST investigates alerts around the clock, and contacts you when suspicious activity, events, and alarms are detected, such as unauthorized access and exposure or modification of accounts, controls, or configurations. The table below maps the FFIEC Cybersecurity Assessment Tool version 1.1 requirements to functionality provided by the Arctic Wolf SOC-as-a-service.

 

FFIEC/NCUA Control Objective FFIEC/NCUA Control Activity (Abbreviated) Arctic Wolf SOC-as-a-Service Capabilities
Domain 1 – Cyber Risk Management and Oversight    
Governance/Oversight: Management provides a written report on the overall status of the information security and business continuity programs to the board or an appropriate board committee at least annually. Source: FFIEC Information Technology Examination Handbook on Information Security (IS). III.C:pg50: The sharing of attack data through organizations, such as FS-ISAC, may help industry institutions better assess and respond to current attacks. Management should consider information sharing as a part of its strategy. Arctic Wolf™ Managed Detection and Response and Managed Risk solutions provide visibility into a financial institution’s security posture through the Arctic Wolf customer portal, actionable dashboards, and executive summary reports.
Governance/Strategy-Policies: The institution has board- approved policies commensurate with its risk and complexity that address information security. Source: IS.I:pg4: Management also should establish appropriate policies, standards, and procedures to support the information security program. Arctic Wolf SOC-as-a-service provides procedures to monitor a financial institution’s environment, detect potential vulnerabilities, and respond to cybersecurity threats.
Governance/Strategy-Policies: The institution has policies commensurate with its risk and complexity that address the concepts of incident response and resilience. Source: IS.II.C.21:pg43: Management should establish and maintain policies that address incident response and resilience and test incident scenarios. The Arctic Wolf Concierge Security™ team (CST) works with you to identify the highest priority security risks and incidents, and helps you rapidly respond to them.
Risk Management/Risk Assessment: A risk assessment focused on safeguarding customer information identifies reasonable and foreseeable internal and external threats, the likelihood and potential damage of threats, and the sufficiency of policies, procedures, and customer information systems. Source: IS.I.B:pg4: Management should provide an annual report to the board covering its risk assessment process, including threat identification and assessment. The Arctic Wolf Managed Risk solution continuously scans your internal and external networks, and endpoints for vulnerabilities. Arctic Wolf’s Concierge Security team helps address a firm’s most critical vulnerabilities, and helps implement improvements.
Risk Management/Risk Assessment: The risk assessment identifies internet- based systems and high-risk transactions that warrant additional authentication controls. Source: IS.I.B:pg4: Management should provide an annual report to the board covering its risk assessment process, including threat identification and assessment. The Arctic Wolf Managed Risk solution continuously scans your internal and external networks and endpoints for vulnerabilities. Arctic Wolf’s Concierge Security team (CST) helps address a firm’s most critical vulnerabilities, and helps implement improvements.
Risk Management/Risk Assessment: The risk assessment is updated to address new technologies, products, services, and connections before deployment. Source: IS.II.A:pg7: The institution should factor in external events affecting IT and the institution’s ability to meet its operating objectives into the risk identification process. The Arctic Wolf Managed Risk solution helps reduce the impact of vulnerabilities by performing continuous 24/7 scans of internal and external networks and endpoints. The solution is continuously updated with information about new vulnerabilities to enhance the firm’s overall security posture.
Risk Management/Audit: Logging practices are independently reviewed periodically to ensure appropriate log management (e.g., access controls, retention, and maintenance). Source: FFIEC Information Technology Examination Handbook on Operations (OPS).B.29: Operations management should periodically review all logs. IS.II.C.22:pg43: Logging practices should be reviewed periodically by an independent party. The Arctic Wolf CST conducts monthly and quarterly risk reviews using analytics gathered from the Arctic Wolf Managed Risk solution. Event collection aggregates and retains raw telemetry, and operational data for the varying duration required by the financial institution (default is 90 days) if needed for forensics purposes.
Resources/Staffing: Processes are in place to identify additional expertise needed to improve information security defenses. Source: IS.I.C:pg5:. Management should provide, and the board should oversee, adequate funding to develop, implement, and maintain a successful information security program. Financial institution IT staff are augmented by the CST’s expertise in Managed Detection and Response and Managed Risk to better protect the financial institution’s information and infrastructure.
Domain 2 – Threat Intelligence and Collaboration    
Threat Intelligence/Threat Intelligence and Information: Threat information is used to monitor threats and vulnerabilities. Source: IS.III.A:pg47: Management should develop procedures for obtaining, monitoring, assessing, and responding to evolving threat and vulnerability information. Arctic Wolf Managed Detection and Response and Managed Risk solutions include subscriptions to best-of-breed threat intelligence to monitor events such as virus signatures, malicious IPs/domains, emerging network threats, and geolocations, which help identify the latest threats and vulnerabilities.
Threat Intelligence/Threat Intelligence and Information: Threat information is used to enhance internal risk management and controls. Source: IS.III.A:pg48: Once a threat is identified and vulnerabilities are assessed, the significance of the threat should trigger an appropriate response and include remediation options. Design policies to deal with immediate and consequential threats expeditiously, while addressing less significant threats as part of a broader risk management process. Arctic Wolf continuously monitors your IT environment and cloud resources, and displays insight in a customer portal with a rating of your financial institution’s security posture, including vulnerability management status, outstanding security incidents, and network activity.
Monitoring and Analyzing/ Monitoring and Analyzing: Audit log records and other security event logs are reviewed and retained in a secure manner. Source: IS.II.C.22:pg44: Management should have effective log retention policies that address the significance of maintaining logs for incident response and analysis needs. …Additionally, logging practices should be reviewed periodically by an independent party to ensure appropriate log management. … Regardless of the method of log management, management should develop processes to collect, aggregate, analyze, and correlate security information. Arctic Wolf Managed Detection and Response collects and manages log records from your IT environment and cloud sources. The event collection function aggregates and retains raw log records for the varying duration required by the financial institution (default is 90 days). Arctic Wolf Managed Detection and Response correlates activities to detect and respond to anomalies for on-premises systems and cloud resources, detecting and responding to anomalies located via sophisticated filtering, correlation, and threshold rules.
Monitoring and Analyzing/ Monitoring and Analyzing: Computer event logs are used for investigations once an event occurs. Source: IS.II.C.22:pg44: Log files are critical to successfully address security incidents and can potentially contain sensitive information. Security information and event management (SIEM) systems collect, aggregate, analyze, and correlate information from discrete systems and applications. The Arctic Wolf SOC-as-a-service uses human-assisted machine learning to accurately detect advanced threats and reduce false positives. It leverages a cloud-based SIEM that collects, aggregates, analyzes, and correlates information, allowing the Arctic Wolf CST to investigate and resolve events as they occur.
Information Sharing/ Information Sharing: Information security threats are gathered and shared with applicable internal employees. Source: IS.II.D:pg45: Risk reporting produces reports that address threats, capabilities, vulnerabilities, and inherent risk changes. It also evaluates the management’s response and resilience to those events. The Arctic Wolf CST is the primary contact to the Arctic Wolf SOC-as-a-service. the CST escalates security incidents to financial institution IT staff via trouble- tickets, or via phone. The Arctic Wolf customer portal provides an overview of a firm’s overall security posture, including a security incidents dashboard.
Domain 3 – Cybersecurity Controls    
Preventive Controls/ Infrastructure Management: All ports are monitored. Source: IS.II.C.12:pg26: Port monitoring to identify unauthorized network connections. The Arctic Wolf Managed Detection and Response solution scans for unauthorized services on internet-facing systems and flags suspicious ports.
Preventive Controls/ Infrastructure Management: Up-to-date antivirus and anti- malware tools are used. Source: IS.II.C.12:pg26: Management should implement defense-in-depth to protect, detect, and respond to malware. The Arctic Wolf CST can advise a financial institution’s IT staff on the optimal antivirus and anti-malware tools to use.
Detective Controls/Threat and Vulnerability Detection: Independent testing (including penetration testing and vulnerability scanning) is conducted according to the risk assessment for external- facing systems and the internal network. Source: ISIS.II.C.17:pg38: Management should perform appropriate tests (e.g., penetration tests, vulnerability assessments, and application security tests) before launching or making significant changes to external-facing applications. The Arctic Wolf CST runs periodic scans of the financial institution’s externally-exposed systems for vulnerabilities and continually monitors network traffic and log files for potential compromise.
Detective Controls/Threat and Vulnerability Detection: Anti- virus and anti-malware tools are used to detect attacks. Source: IS.II.C.12:pg26: Management should implement defense-in-depth to protect, detect, and respond to malware. Arcitc Wolf SOC-as-a-service checks for known malware (example: ransomware) by monitoring incoming network traffic and outgoing command- and-control traffic. Arctic Wolf SOC-as-a-service can also ingest malware alerts from an endpoint protection platform (EPP) or endpoint detection and response (EDR) solutions.
Detective Controls/Threat and Vulnerability Detection: Firewall rules are audited or verified at least quarterly. Source: IS.III:pg46: Security operations activities can include security software and device management (e.g., maintaining the signatures on signature-based devices and firewall rules). Arctic Wolf provides advisory services to audit firewall configurations, network zoning, and segmentation architecture, and can recommend changes that ensure business-critical assets are adequately protected from both internal and external cyberattacks.
Detective Controls/Anomalous Activity Detection: The institution is able to detect anomalous activities through monitoring across the environment. Source: IS.II.C.12:pg26: Management should implement defense-in-depth to protect, detect, and respond to malware. Arctic Wolf SOC-as-a-service continually monitors on-premises systems and cloud assets to detect anomalous activities.
Detective Controls/Anomalous Activity Detection: Logs of physical and/or logical access are reviewed following events. Source: ISIII.C.22:pg44: Institutions maintain event logs to understand an incident or cyber event after it occurs. Monitoring event logs for anomalies and relating that information with other sources of information broadens the institution’s ability to understand trends, react to threats, and improve stakeholder reports. Arctic Wolf SOC-as-a-service retains log data and network flow data for on-premises systems as well as available log data from cloud services. Such logs are maintained for threat detection and for subsequent incident response to broaden an institution’s ability to respond to cyberthreats.
Detective Controls/Event Detection: Processes are in place to monitor for the presence of unauthorized users, devices, connections, and software. Source: IS.Introduction:pg2: Management should be able to identify and characterize threats, assess risks, make decisions regarding the implementation of appropriate controls, and provide appropriate monitoring and reporting. Arctic Wolf audits changes to Active Directory (AD), group policies, Exchange and file servers, and flags unauthorized actions. Arctic Wolf monitors failed/ successful logins/logoffs and all password changes to prevent excessive help desk calls.
Domain 4 – External Dependency Management    
Relationship Management/ Ongoing Monitoring: Audits, assessments, and operational performance reports are obtained and reviewed regularly validating security controls for critical third parties. Source: IS.II.C.20:pg42: Management should oversee outsourced operations through an independent review of the third party’s security via appropriate reports from audits and tests. Arctic Wolf facilitates the development of financial institution policies and procedures related to security monitoring and incident response. The Arctic Wolf SOC-as-a-service monitors third-party cloud applications including SaaS applications (Office 365, G Suite, Box, Salesforce) as well as IaaS platforms (AWS, Azure) to minimize third-party cybersecurity risk. Arctic Wolf maintains written policies for the Managed Detection and Response service based on a risk assessment consistent with our SOC II Type 2 compliance certification. Arctic Wolf has strict security policies in place to prevent unauthorized access to SOC tools. Log data is encrypted in transit and at rest.
Domain 5 – Cyber Incident Management and Resilience    
Incident Resilience Planning and Strategy/Testing: Scenarios are used to improve incident detection and response. Source: IS.II.C.21:pg43: Management should test information security incident scenarios. Arctic Wolf facilitates incident response plans through its Incident Response Simulation Service that runs through live table-top exercises, makes recommendations, and addresses regulatory requirements.
Detection, Response and Mitigation/Detection: Alert parameters are set for detecting information security incidents that prompt mitigating actions. Source: IS.II.C.15(a):pg32: To prevent unauthorized access to or inappropriate activity on the operating system and system utilities, filter and review logs for potential security events and provide adequate reports and alerts. IS.II.C.15(b):pg33: Management should implement effective application access controls by logging access and events, defining alerts for significant events, and developing processes to monitor and respond to anomalies and alerts. Arctic Wolf’s managed detection and response service provides unlimited flexibility in tailoring services to a financial institution’s specific monitoring needs. The Arctic Wolf Customized Rule Engine (CRulE) allows the CST to apply precise security policies, updating them as needed to align with changing business needs. The Arctic Wolf Managed Detection and Response solution ingests, parses, and analyses network and log data and provides both automated and custom reports.
Detection, Response and Mitigation/Detection: Tools and processes are in place to detect, alert, and trigger the incident response program. Source: IS.III.D:pg50: The institution’s program should have defined protocols to declare and respond to an identified incident. The Arctic Wolf SOC-as-a-service provides an outcome-based service that detects, alerts, and responds to advanced attacks that may bypass existing perimeter controls. The Arctic Wolf CST functions as a single point of contact who can tailor the Arctic Wolf Managed Detetion and Response service to fit a financial institution’s needs.
Detection, Response and Mitigation/Response and Mitigation: Appropriate steps are taken to contain and control an incident to prevent further unauthorized access to or use of customer information. Source: IS.III.D:pg52: While containment strategies between institutions vary, they typically include isolation of compromised systems or enhanced monitoring of intruder activities, search for additional compromised systems, collection and preservation of evidence. The Arctic Wolf CST prioritizes incidents and identifies critical remediation steps that a financial institution IT team should take. The CST proactively hunts for hidden threats, performs remote forensics analysis of incidents, and provides actionable plans to help remediate incidents.
Escalation and Reporting / Escalation and Reporting: A process exists to contact personnel who are responsible for analyzing and responding to an incident. Source: IS.III.C:pg50: Escalation policies should address when different personnel within the organization will be contacted and the responsibilities those personnel have in incident analysis and response. The Arctic Wolf CST prioritizes incidents and identifies remediation steps needed to respond to an incident. Institutions have direct access to a CST—dedicated to their account—by phone or email.
Escalation and Reporting/ Escalation and Reporting: Incidents are classified, logged, and tracked. Source: OPS.B.28: Event/problem management plans should cover hardware, operating systems, applications, and security devices, and should address at a minimum: event/problem identification, etc. The Arctic Wolf CST tracks incidents in the customer portal, as well as through monthly check-ins and executive summary reports.

References:

About Arctic Wolf: Arctic Wolf Networks delivers the industry-leading security operations center (SOC)-as-a-service that redefines the economics of cybersecurity. The Arctic Wolf™ Managed Detection and Response and Managed Risk services are anchored by the Arctic Wolf Concierge Security Team™ who provides custom threat hunting, alerting, and reporting. Arctic Wolf’s purpose-built, cloud-based SOC-as-a-service offers 24×7 monitoring, risk management, threat detection, and response. For more information about Arctic Wolf, visit arcticwolf.com.

Previous Article
Why Choose MDR over MSSP or SIEM?
Why Choose MDR over MSSP or SIEM?

How managed detection and response services provide affordable cyber protection against today’s threats–and...

Next Article
Simplify Compliance for NY DFS Cybersecurity Requirements (23 NYCRR 500)