Finding #26

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Lack of Ransomware and Threat Protection Alerts in Backup System

Priority Level: One

Category: Cybersecurity / Business Continuity

Description: The bank's backup system does not include ransomware detection, threat protection features, or alerting mechanisms. This gap allows malicious actors to target backups undetected, potentially encrypting, deleting, or tampering with data, which could render recovery impossible during a ransomware incident or other cyber threats. Without proactive monitoring and alerts, the organization remains exposed to evolving attack vectors that compromise data availability and integrity.

Impact:

  • Undetected threats to backups could lead to irrecoverable data loss, prolonged operational downtime, significant financial costs from recovery efforts or ransom demands, and lasting reputational damage.
  • Non-compliance with FFIEC expectations for resilient backup practices, increasing the likelihood of regulatory penalties, enforcement actions, and adverse examination findings.
  • Inability to respond swiftly to incidents, exacerbating disruptions to client services, internal processes, and overall business continuity.

FFIEC Reference:

  • FFIEC Joint Statement on Destructive Malware (2016): Intended to alert financial institutions to specific risk mitigation related to threats associated with destructive malware, emphasizing the need for monitoring and protection of critical systems including backups.
  • FFIEC Cybersecurity Resource Guide for Financial Institutions (2022): Includes ransomware-specific resources to address ongoing threats, recommending protections for backup systems to ensure data resilience and recovery.
  • Update to Cybersecurity Resource Guide for Financial Institutions (October 2022): Highlights the addition of ransomware-specific resources to help institutions protect against incidents, including safeguards for backup environments.

Recommendations:

  • Integrate ransomware detection and threat protection into the backup system (e.g., using solutions like Veeam with anomaly detection or Rubrik with threat monitoring) to enable real-time alerts for suspicious activities.
  • Adopt immutable and air-gapped backup strategies to prevent unauthorized modifications, combined with automated integrity checks and alerting.
  • Incorporate backup threat scenarios into regular BCDR testing and incident response plans, ensuring alerts are routed to security teams for prompt investigation.
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