CPMI-IOSCO Report Assesses Cyber Risk at Financial Infrastructures
The Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) published a Level 3 assessment report on cyber resilience of financial market infrastructures. The review is intended to understand how and to what degree the guidance on cyber resilience for financial market infrastructures, which was published in June 2016, has been used by financial market infrastructures.
The Level 3 assessment report reviews the state of cyber resilience (as of February 2021) at 37 financial market infrastructures from 29 jurisdictions during 2020–22. The assessment was focused on the implementation of Principles 2 (Governance), 3 (Comprehensive framework for the management of risks), and 17 (Operational risk), in addition to the relevant key considerations of the principles for financial market infrastructures. The assessment focused on key components of the cyber resilience framework. Recognizing the challenges exacerbated by the increased remote working arrangements and the use of personal devices, the report outlines key measures implemented or being implemented to address potentially heightened cyber risks. The Level 3 assessment covered all types of financial market infrastructures, including systemically important payment systems, central securities depositories, securities settlement systems, central counterparties, and trade repositories.
The assessment report found that there was a reasonably high adoption of the Cyber Guidance, with a significant majority of financial market infrastructures indicating that they had adopted or referred to parts of the Cyber Guidance when designing their cyber resilience frameworks. The assessment report highlights five concerns, including one serious issue of concern. The serious issue of concern relates to a small number of financial market infrastructures that have not yet developed their cyber response and recovery plans to meet the criteria that critical information technology systems can resume operations within two hours following disruptive events, even in the case of extreme but plausible scenarios. Additionally, the four issues of concern relate to
- shortcomings in established response and recovery plans for meeting the two-hour recovery time objective under extreme cyber-attack scenario
- lack of cyber resilience testing after a significant system change
- lack of comprehensive scenario-based testing
- inadequate involvement of relevant stakeholders in testing of their responses.
Considering their aggregate impact, the serious issues of concern seem to pose clear challenges for cyber resilience of financial market infrastructures. The CPMI and IOSCO has urged the relevant financial market infrastructures and their relevant supervisory authorities to address these issues with the highest priority.
Keywords: International, Banking, Securities, Financial Market Infrastructure, Cyber Risk, Regtech, Systemic Risk, Cyber Guidance, Cyber Resilience Framework, Operational Resilience, Basel, CPMI, IOSCO
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Across 35 years in banking, Blake has gained deep insights into the inner working of this sector. Over the last two decades, Blake has been an Operating Committee member, leading teams and executing strategies in Credit and Enterprise Risk as well as Line of Business. His focus over this time has been primarily Commercial/Corporate with particular emphasis on CRE. Blake has spent most of his career with large and mid-size banks. Blake joined Moody’s Analytics in 2021 after leading the transformation of the credit approval and reporting process at a $25 billion bank.
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