Spending less than 5 minutes a week along
with a cup of coffee, you can monitor your IT security as
required by the FFIEC's "Interagency Guidelines Establishing
Information Security Standards."
information and to subscribe visit
Unlawful Internet Gambling Enforcement Act Examination Guidance and
Procedures - The FDIC and the other federal banking, thrift and
credit union regulatory agencies are issuing the attached guidance
and examination procedures related to the Unlawful Internet Gambling
Enforcement Act of 2006.
(This requires the Bank to
and implement policies and procedures, as appropriate,
to ensure that transactions of this nature are not accepted.)
Senate Committee passes major cybersecurity legislation - A U.S.
Senate committee on Thursday unanimously passed a controversial
cybersecurity bill, which would grant the president emergency power
over critical infrastructure networks, in addition to creating
cybersecurity offices within the White House and U.S. Department of
Homeland Security (DHS).
Scotland Yard cuffs teens for role in cybercrime forum - 65,000
stolen credit card numbers recovered - The pair were detained by
appointment in central London on Wednesday by the Police Central
e-Crime Unit (PCeU), a national unit based at Scotland Yard.
Accused Hacker Who Balked at 2-Year Prison Deal Now Faces Decades -
Hacks and Cracks - An alleged hacker who declined a 2-year plea deal
is facing decades behind bars after federal authorities added
multiple charges, including possession and distribution.
700-Plus Credit Cards Stolen from Hotel - Hundreds of Thousands of
Dollars Charged to Hotel Guests' Stolen Credit Cards Computer
hackers targeting travelers at luxury hotels across the country made
off with hundreds of thousands of dollars during the past three
months by breaking into the computer system of a national hotel
chain and stealing the guests' credit card information.
Garage card scammer jailed - 35,000 card details snaffled - Hayes
has been sentenced to four and a half years for his role in one of
the UK's biggest chip and pin scams.
Lafayette firm faces probation, $1M forfeiture over illegal exports
- The chief executive of Rocky Mountain Instrument Co. pleaded
guilty on behalf of the corporation Tuesday to exporting military
optical prisms and data to foreign nations without permission from
the U.S. State Department.
GAO - Federal Guidance Needed to Address Control Issues with
Implementing Cloud Computing.
Release - http://www.gao.gov/new.items/d10513.pdf
Highlights - http://www.gao.gov/highlights/d10513high.pdf
GAO - Governmentwide Guidance Needed to Assist Agencies in
Implementing Cloud Computing.
Release - http://www.gao.gov/new.items/d10855t.pdf
ATTACKS, INTRUSIONS, DATA THEFT & LOSS
Army intelligence analyst allegedly carried classified U.S. combat
video out on CD - An Army intelligence analyst arrested for leaking
classified U.S. combat videos and State Department records to
WikiLeaks.org reportedly carried the secret data out of secure areas
FBI Investigating Possible DSHS Hacker - The FBI is investigating
whether a hacker broke into the state's confidential cancer
registry, possibly holding personal information and medical records
Spanish firm raided in logic-bomb backdoor probe - Alert Print Post
commentAuto-fail programming alleged - Three managers at an unnamed
Spanish software developer have been arrested over allegations they
planted 'logic bombs' in software that meant clients were obliged to
pay for disruptive repairs and extended maintenance contracts.
Florida International University discovers sensitive database
unsecured -The personal information of Florida International
University students and faculty members was discovered in an
unsecure database that may have been accessible to the public.
Personal data exposed on Anthem Blue Cross website - The personal
information of hundreds of thousands of Blue Cross customers was
recently exposed following a website glitch made by a third party.
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of the newsletter
WEB SITE COMPLIANCE -
We continue our review of the
FFIEC interagency statement on "Weblinking:
Identifying Risks and Risk Management Techniques."
(Part 7 of 10)
B. RISK MANAGEMENT TECHNIQUES
Planning Weblinking Relationships
If a financial institution receives compensation from a third
party as the result of a weblink to the third-party's website, the
financial institution should enter into a written agreement with
that third party in order to mitigate certain risks. Financial
institutions should consider that certain forms of business
arrangements, such as joint ventures, can increase their risk. The
financial institution should consider including contract provisions
to indemnify itself against claims by:
1) dissatisfied purchasers of third-party products or services;
2) patent or trademark holders for infringement by the third party;
3) persons alleging the unauthorized release or compromise of their
confidential information, as a result of the third-party's conduct.
The agreement should not include any provision obligating the
financial institution to engage in activities inconsistent with the
scope of its legally permissible activities. In addition, financial
institutions should be mindful that various contract provisions,
including compensation arrangements, may subject the financial
institution to laws and regulations applicable to insurance,
securities, or real estate activities, such as RESPA, that establish
broad consumer protections.
In addition, the agreement should include conditions for terminating
the link. Third parties, whether they provide services directly to
customers or are merely intermediaries, may enter into bankruptcy,
liquidation, or reorganization during the period of the agreement.
The quality of their products or services may decline, as may the
effectiveness of their security or privacy policies. Also
potentially just as harmful, the public may fear or assume such a
decline will occur. The financial institution will limit its risks
if it can terminate the agreement in the event the service provider
fails to deliver service in a satisfactory manner.
Some weblinking agreements between a financial institution and a
third party may involve ancillary or collateral information-sharing
arrangements that require compliance with the Privacy Regulations.
For example, this may occur when a financial institution links to
the website of an insurance company with which the financial
institution shares customer information pursuant to a joint
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INFORMATION TECHNOLOGY SECURITY -
We continue our review of the OCC Bulletin about
Infrastructure Threats and Intrusion Risks. This week we review
Management should ensure that information system networks are tested
regularly. The nature, extent, and frequency of tests should be
proportionate to the risks of intrusions from external and internal
sources. Management should select qualified and reputable
individuals to perform the tests and ensure that tests do not
inadvertently damage information systems or reveal confidential
information to unauthorized individuals. Management should oversee
the tests, review test results, and respond to deficiencies in a
timely manner. In accordance with OCC's "Technology Risk Management:
PC Banking," management should ensure that an objective, qualified
source conducts a penetration test of Internet banking systems at
least once a year or more frequently when appropriate.
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INTERNET PRIVACY - We continue
our series listing the regulatory-privacy examination questions.
When you answer the question each week, you will help ensure
compliance with the privacy regulations.
Sharing nonpublic personal information with nonaffiliated third
parties under Sections 14 and/or 15 and outside of exceptions (with
or without also sharing under Section 13). (Part 2 of 3)
B. Presentation, Content, and Delivery of Privacy Notices
1) Review the financial institution's initial, annual and revised
notices, as well as any short-form notices that the institution may
use for consumers who are not customers. Determine whether or not
a. Are clear and conspicuous (§§3(b), 4(a), 5(a)(1), 8(a)(1));
b. Accurately reflect the policies and practices used by the
institution (§§4(a), 5(a)(1), 8(a)(1)). Note, this includes
practices disclosed in the notices that exceed regulatory
c. Include, and adequately describe, all required items of
information and contain examples as applicable (§6). Note that if
the institution shares under Section 13 the notice provisions for
that section shall also apply.
2) Through discussions with management, review of the institution's
policies and procedures, and a sample of electronic or written
consumer records where available, determine if the institution has
adequate procedures in place to provide notices to consumers, as
appropriate. Assess the following:
a. Timeliness of delivery (§§4(a), 7(c), 8(a)); and
b. Reasonableness of the method of delivery (e.g., by hand; by
mail; electronically, if the consumer agrees; or as a necessary step
of a transaction) (§9).
customers only, review the timeliness of delivery (§§4(d), 4(e),
5(a)), means of delivery of annual notice (§9(c)), and accessibility
of or ability to retain the notice (§9(e)).