Strengthening a Cyber Security Program for compliance

Engagement Period:  2 Months

Background

Our client, a Foreign Banking Organization (FBO) requested NextAML to assist in identifying gaps and developing a roadmap for compliance with New York State Department of Financial Services (NYDFS) Cybersecurity Rule (Rule 500) and the National Institute of Standards and Technology Cybersecurity framework (NIST).

Approach

NextAML began with deploying a multi-disciplinary team with extensive expertise in providing cybersecurity and information technology in financial institutions. The team has worked with numerous financial institutions located in the United States to assess and develop roadmaps for Rule 500, conduct program reviews, and the development of related action plans to bring cybersecurity programs in alignment with regulatory guidance.

In addition, our team approached the assessment with an eye on the risk profile of the institution, tailoring the interviews, assessments and tests, in meeting the required regulatory requirements for such an institution to identify opportunities for strengthening the cybersecurity environment. 

Outcome

We developed a remediation roadmap that would resolve the gaps to specific requirements in Rule 500 and NIST, clearly delineating the gaps that existed and recommended activities to close each gap as well as enhancement opportunities to strengthen the BSA/AML and Sanctions Compliance Program.