Finding #25

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Lack of Endpoint Detection and Response (EDR), Behavioral Analysis, Malware, or Ransomware Detection

Priority Level: 1

Category: Cybersecurity / Threat Detection

Description: The bank lacks advanced security measures such as Endpoint Detection and Response (EDR) tools, behavioral analysis capabilities, and dedicated malware or ransomware detection systems. Traditional antivirus solutions alone are inadequate against modern threats, leaving endpoints vulnerable to sophisticated attacks that evade signature-based detection. This deficiency increases the risk of undetected intrusions, allowing threat actors to persist, exfiltrate data, or deploy ransomware without timely intervention.

Impact:

  • Undetected malware or ransomware infections could result in data encryption, theft, or destruction, leading to operational downtime, financial losses exceeding millions, and severe reputational damage.
  • Non-compliance with FFIEC requirements for robust detection and response mechanisms, potentially incurring regulatory fines, enforcement actions, and negative audit results.
  • Prolonged incident response times, disrupting client services, business operations, and overall resilience against cyber threats.

FFIEC Reference:

  • FFIEC Joint Statement on Destructive Malware (2016): "Financial institutions should establish a baseline environment to detect anomalous behavior and monitor system alerts for attack attempts. Use up-to-date intrusion detection systems, antivirus protection, and properly configured firewall rules reviewed periodically."
  • FFIEC Cybersecurity Resource Guide for Financial Institutions (2022): Recommends the Ransomware Readiness Assessment (RRA) to "help organizations better assess how well they are equipped to defend and recover from a ransomware incident," including detection practices.
  • FFIEC Statement on Cybersecurity Awareness: "Use monitoring tools to capture events, and to identify anomalous behaviors and attacks" as part of incident management and resilience.

Recommendations:

  • Deploy EDR platforms with behavioral analysis features (e.g., CrowdStrike Falcon, Microsoft Defender for Endpoint, or similar) to enable real-time monitoring, threat hunting, and automated response on endpoints.
  • Integrate malware and ransomware detection into Security Information and Event Management (SIEM) systems for centralized alerting and correlation of suspicious activities.
  • Perform regular self-assessments using FFIEC-endorsed tools like the Ransomware Self-Assessment Tool (R-SAT) and incorporate detection testing into incident response drills to ensure effectiveness against evolving threats.
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