CYBER PROGRAM DESIGN AND COMPLIANCE REVIEW

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CYBER PROGRAM DESIGN AND COMPLIANCE REVIEW

  • Julien Bonnay, Jayadevan Vijayakrishnan and Christopher Tecchio
  • Published: 30 March 2020


Cyber programs at financial institutions need to tackle the top cyber risks to the businesses, and address expectations of various stakeholder groups. Boards, customers, regulators, and third parties alike are increasingly looking for financial institutions to address cyber risks. As financial institutions contend with ever-increasing hacks and breaches, the Board is keen to ensure that the investments in cybersecurity are being directed to tackle the top cyber risks impacting the organization.

Organizations have not only had to address concerns of their Board but in light of the recent spate of significant impact and highly visible data breaches, customers are also looking to their financial institutions to define effective cyber programs. In response to the crippling effect of many cyber-attacks, regulators have also increased scrutiny on cyber programs, with bodies such as the New York State Department of Financial Services (NYDFS) mandating within the 23NYCRR500 regulation, a dedicated program to tackle cyber risk.

On top of all these expectations, financial institutions also need to work as an ideal partner with third parties who could also be subject to adverse impacts resulting from any cyber risks.