Element 3: Risk and Control Assessment.
Identify functions, activities, products, and services—including interconnections, dependencies,
and third parties—prioritize their relative importance, and assess their respective cyber risks.
Identify and implement controls—including systems, policies, procedures, and training—to
protect against and manage those risks within the tolerance set by the governing authority.
Ideally as part of an enterprise risk management program, entities should evaluate the inherent
cyber risk (or the risk absent any compensating controls) presented by the people, processes,
technology, and underlying data that support each identified function, activity, product, and
service. Entities should then identify and assess the existence and effectiveness of controls to
protect against the identified risk to arrive at the residual cyber risk. Protection mechanisms can
include avoiding or eliminating risk by not engaging in an identified activity. They can also
include mitigating the risk through controls or sharing or transferring the risk. In addition to
evaluating an entity’s own cyber risks from its functions, activities, products, and services, risk
and control assessments should consider as appropriate any cyber risks the entity presents to
others and the financial sector as a whole. Public authorities should map critical economic
functions in their financial systems as part of their risk and control assessments to identify single
points of failure and concentration risk. The sector’s critical economic functions range from
deposit taking, lending, and payments to trading, clearing, settlement, and custody.
Element 4: Monitoring.
Establish systematic monitoring processes to rapidly detect cyber incidents and periodically
evaluate the effectiveness of identified controls, including through network monitoring, testing,
audits, and exercises.
Effective monitoring helps entities adhere to established risk tolerances and timely enhance or
remediate weaknesses in existing controls. Testing and auditing protocols provide essential
assurance mechanisms for entities and public authorities alike. Depending on the nature of an
entity and its cyber risk profile and control environment, the testing and auditing functions
should be appropriately independent from the personnel responsible for implementing and
managing the cybersecurity program. Through examinations, on-site and other supervisory
mechanisms, comparative analysis of entities’ testing results, and joint public-private exercises,
public authorities can better understand sector-wide cyber threats and vulnerabilities, as well as
individual entities’ relative risk profiles and capabilities.
Element 5: Response.
Timely (a) assess the nature, scope, and impact of a cyber incident; (b) contain the incident and
mitigate its impact; (c) notify internal and external stakeholders (such as law enforcement,
regulators, and other public authorities, as well as shareholders, third-party service providers, and
customers as appropriate); and (d) coordinate joint response activities as needed.
As part of their risk and control assessments, entities should implement incident response
policies and other controls to facilitate effective incident response. Among other things, these
controls should clearly address decision-making responsibilities, define escalation procedures,
and establish processes for communicating with internal and external stakeholders. Exercising
protocols within and among entities and public authorities contributes to more effective
responses. Exercising also enables entities and public authorities to identify how potential
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