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One interesting thing about working in the banking industry is the evolution of the “annual security assessment” mandated by the FDIC. Each year we find that the auditors usually emphasize a different information security issue in addition to the fundamentals (e.g., external penetration test, internal penetration test, Risk Assessment, FFIEC information security handbook, etc.). This approach makes sense and reflects the evolving threats of the day. Over the last few years we have seen an additional emphasis on areas like WLAN security, Social Engineering, and malware.
In speaking with some of our clients this year we are hearing that there is an increased emphasis on Quarterly Vulnerability Scans (both internally and externally). Many of our banking clients that have more mature Information Security Management Systems have been taking this approach for the last few years. The approach is consistent with prevailing good practice and is a very effective means of reducing a bank’s information security risk between annual penetration tests. If you are going to move in this direction you should consider the additional benefits of using credentialed vulnerability assessments as they more accurately identify a much wider array of vulnerabilities.
I’m impressed with the FDIC’s approach. Some might argue that they could have pushed for all (or most) of these incremental improvements years ago; however, their “continuous improvement” approach is consistent with the world’s leading information security management standard (ISO-27001). We have found that a slower, steady approach of this nature is far less disruptive and gives an organization the time to fully “operationalize” each improvement before taking on a new challenge.