Federal Financial Institutions Examination Council 3501 Fairfax Drive • Room B7081a • Arlington VA 22226-3550 • 703 516-5588 • FAX 703 562-6446 • http www ffiec gov Joint Statement Destructive Malware PURPOSE The Federal Financial Institutions Examination Council FFIEC on behalf of its members 1 is issuing this statement to notify financial institutions of the increasing threat of cyber attacks involving destructive malware Financial institutions and technology service providers should enhance their information security programs to ensure they are able to identify mitigate and respond to this type of attack In addition business continuity planning and testing activities should incorporate response and recovery capabilities and test resilience against cyber attacks involving destructive malware This statement does not contain any new regulatory expectations It is intended to alert financial institutions to specific risk mitigation related to the threats associated with destructive malware Financial institutions should refer to the appropriate FFIEC Information Technology IT Examination Handbook booklets referenced in this statement for information on regulatory expectations regarding IT risk management BACKGROUND Over the past two years cyber attacks on businesses have increased in frequency and severity In some cases destructive malware used in these attacks successfully compromised large quantities of data and rendered supporting systems inoperable Malware can be introduced into systems through a variety of mechanisms including through employees downloading attachments in phishing or spear-phishing emails connecting external devices e g USB drives or visiting compromised Web sites or through unauthorized parties using stolen employee or third-party credentials to install malware directly on systems Once introduced destructive malware may be further distributed through compromised enterprise system management technologies Historically business continuity plans have focused on restoring operations after physical events such as a natural disaster or other geographically centered infrastructure disruptions In today’s rapidly evolving cyber threat landscape however comprehensive resilience depends on the ability to identify and contain damage recover data and restore operations from a broader set of scenarios that include cyber attacks involving destructive malware on critical information systems or the institution’s underlying infrastructure To ensure that critical backup data are not 1 The FFIEC comprises the principals of the following The Board of Governors of the Federal Reserve System Federal Deposit Insurance Corporation National Credit Union Administration Office of the Comptroller of the Currency Consumer Financial Protection Bureau and State Liaison Committee destroyed or corrupted by destructive malware financial institutions and their technology service providers should ensure that recovery strategies address the potential for simultaneous cyber attacks on backup data centers e g mirrored sites2 or the potential for corrupted data to replicate to backup systems RISKS Financial institutions face a variety of risks from cyber attacks involving destructive malware including liquidity capital operational and reputation risks due to such events as fraud data loss and disruption of customer service RISK MITIGATION Financial institutions should ensure that their risk management processes and business continuity planning address the risk from this type of cyber attack consistent with the risk management guidance contained in the FFIEC IT Examination Handbook specifically the booklets on “Business Continuity Planning” and “Information Security” and their appendixes such as Appendix J Strengthening the Resilience of Outsourced Technology Services An institution’s management is expected to maintain sufficient business continuity planning processes to ensure the rapid recovery resumption and maintenance of the institution’s operations after a cyber attack involving destructive malware A financial institution should develop appropriate processes that enable recovery of data and business operations and that address rebuilding network capabilities and restoring data if the institution or its critical service providers fall victim to this type of cyber attack This should include the ability to protect offline data backups from destructive malware In accordance with regulatory requirements and FFIEC guidance financial institutions should consider taking the following steps • Securely configure systems and services Protections such as logical network segmentation hard backups air gapping 3 maintaining an inventory of authorized devices and software physical segmentation of critical systems and other controls may mitigate the impact of a cyber attack involving destructive malware Consistency in system configuration promotes the implementation and maintenance of a secure network Essential components of a secure configuration include the removal or disabling of unused applications functions or components • Review update and test incident response and business continuity plans Test the effectiveness of incident response plans at the financial institution and with third-party processors to ensure that all employees including individuals responsible for managing 2 Data mirroring is the replication of data to alternate processing sites or storage systems at regular intervals defined by recovery time periods of an organization 3 An air gap is a security measure that isolates a secure network from unsecure networks physically electrically and electromagnetically 2 liquidity and reputation risk information security vendor management fraud detection and customer inquiries understand their respective responsibilities and their institution’s protocols Conduct an exercise at the financial institution that simulates a cyber attack involving destructive malware • Conduct ongoing information security risk assessments Maintain an ongoing information security risk assessment program that considers new and evolving threats to online accounts and adjust customer authentication layered security and other controls in response to identified risks Identify prioritize and assess the risk to critical systems including threats to applications that control various system parameters and other security and fraud prevention measures In addition ensure that third-party service providers o Perform effective risk management and implement controls o Properly maintain and conduct regular testing of their security controls simulating potential risk scenarios o Are contractually obligated to provide security incident reports when issues arise that may affect the institution • Perform security monitoring prevention and risk mitigation Ensure protection and detection systems such as intrusion detection systems and antivirus protection are up-to-date and firewall rules are configured properly and reviewed periodically Establish a baseline environment to enable the ability to detect anomalous behavior Monitor system alerts to identify prevent and contain attack attempts from all sources In addition o Follow software assurance industry practices for internally-developed applications o Conduct due diligence of third-party software and services o Conduct penetration testing and vulnerability scans as necessary o Promptly manage vulnerabilities based on risk and track mitigation progress including implementing patches for all applications services and systems o Review reports generated from monitoring systems and third parties for unusual behavior • Protect against unauthorized access Limit the number of credentials with elevated privileges across the institution especially administrator accounts and the ability to easily assign elevated privileges to access critical systems Review access rights periodically to reconfirm approvals are still appropriate to the job function Establish stringent expiration periods for unused credentials monitor logs for use of old credentials and promptly terminate unused or unwarranted credentials Establish authentication rules such as time-ofday and geolocation controls or implement multifactor authentication protocols for webbased control panels In addition o Conduct regular audits to review the access and permission levels to critical systems for employees and contractors Implement least privileges access policies4 across the 4 Principles of least privilege refers to the security objective of granting users only the access needed to perform official duties 3 o o o o entire enterprise In particular do not allow users to have local administrator rights on workstations Change default password and settings for system-based credentials Prevent unpatched systems such as home computers and personal mobile devices from connecting to internal-facing systems Implement monitoring controls to detect unauthorized devices connected to internal networks Use secure connections when remotely accessing systems and services e g virtual private networks • Implement and test controls around critical systems regularly Ensure appropriate controls such as access control segregation of duties audit and fraud detection and monitoring systems are implemented for systems based on risk Limit the number of sign-on attempts for critical systems and lock accounts once such thresholds are exceeded Implement alert systems to notify employees when baseline controls are changed on critical systems Test the effectiveness and adequacy of controls periodically Report test results to senior management and if appropriate to the board of directors or a committee of the board of directors Include in the report recommended risk mitigation strategies and progress to remediate findings In addition o Encrypt sensitive data on internal- and external-facing systems in transit and where appropriate at rest o Implement an adequate password policy o Review the business processes around password recovery o Regularly test security controls such as web application firewalls o Implement procedures for the destruction and disposal of media containing sensitive information based on risk relative to the sensitivity of the information and the type of media used to store the information o Filter Internet access through Web site whitelisting5 where appropriate to limit employees access to only those Web sites necessary to perform their job functions o Conduct incremental and full backups of important files and store the backed-up data offline • Enhance information security awareness and training programs Conduct regular mandatory information security awareness training across the financial institution including how to identify and prevent successful phishing attempts Ensure training reflects the functions performed by employees • Participate in industry information-sharing forums Incorporate information sharing with other financial institutions and service providers into risk mitigation strategies to identify respond to and mitigate cybersecurity threats and incidents Since threats and tactics can change rapidly participating in information-sharing organizations such as the Financial Services Information Sharing and Analysis Center FS-ISAC can improve an institution’s 5 A computer administration practice used to permit users the ability to access only authorized Web sites 4 ability to identify attack tactics and to successfully mitigate cyber attacks involving destructive malware on its systems In addition to the FS-ISAC there are government resources such as the U S Computer Emergency Readiness Team US-CERT that provide information on vulnerabilities The US-CERT portal may be found at www us-cert gov ADDITIONAL RESOURCES The following government resources provide assistance to institutions for mitigating destructive malware US-CERT Security Tip ST13-003 “Handling Destructive Malware” https www uscert gov ncas tips ST13-003 Joint Security Awareness Report JSAR-12-241-01B “Shamoon DstTrack Malware” https icscert us-cert gov jsar JSAR-12-241-01B National Institute of Standards and Technology “Cybersecurity Framework” http www nist gov cyberframework US-CERT “Cyber Resilience Review” https www us-cert gov ccubedvp self-service-crr NSA CWW Information Assurance Directorate MIT-001R-2015 “Defensive Best Practices for Destructive Malware” https www nsa gov ia _files factsheets Defending_Against_Destructive_Malware pdf REFERENCES FFIEC Information Technology Examination Handbook booklet “Business Continuity Planning” http ithandbook ffiec gov it-booklets business-continuity-planning aspx FFIEC Information Technology Examination Handbook booklet “Information Security” http ithandbook ffiec gov it-booklets information-security aspx FFIEC Cybersecurity Threat and Vulnerability Monitoring and Sharing Statement http www ffiec gov press PDF FFIEC_Cybersecurity_Statement pdf 5
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