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Topic: Cybercriminals

CFOs and CISOs: Boost Your SEC Cybersecurity Compliance with These 5 Best Practices

Key Takeaways:

  • New SEC cybersecurity rules require public companies to disclose material cybersecurity incidents, risk management processes, and governance.
  • Determining “materiality” of cyber incidents for disclosure is challenging and requires close collaboration between CISOs providing technical context and CFOs/executives making final determinations.
  • To comply, companies should take steps such as designating accountable leadership, adding specialized cybersecurity knowledge, and updating financial processes.

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For years, chief financial officers (CFOs) could afford to be removed from the daily cybersecurity efforts led by chief information security officers (CISOs). But, with new Securities and Exchange Commission (SEC) cybersecurity rules, those days are gone.

Adopted on July 26, 2023, the SEC’s “Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure” rules recognize cyber incidents can significantly impact public companies’ operations, finances, and reputations. The requirements push companies to be more transparent and accountable about cybersecurity.

While compliance with these rules falls squarely on publicly traded organizations, the impact extends to private-owned companies as well. If your company is a vendor or partner to public firms, you can expect inquiries and audits to verify you meet their security standards. Liabilities and risks permeate the entire supply chain.

SEC Cybersecurity Disclosure Requirements

If you are a public company, what do you need to report under the new rules? Here are the main requirements:

Cybersecurity Incident Disclosure

  • Report within four business days of determining the incident is “material”
  • Describe the nature, scope, timing, and impacts (or potential impacts)
  • Note any undetermined details at time of filing
  • Compliance required for SEC registrants as of December 18, 2023; smaller reporting companies (SRCs) have until June 15, 2024, to comply

Annual Risk Management & Strategy Disclosure

  • Outline processes to identify, assess, and manage material cyber risks
  • Explain how these processes integrate with overall risk governance
  • Detail impacts from previous material incidents
  • Disclose use of third-party security consultants/auditors and procedures
  • Compliance required for all registrants (including SRCs) beginning with annual reports for fiscal years ending on or after December 15, 2023

Annual Governance Disclosure

  • Describe board oversight and committee responsibilities for cyber risk
  • Identify management roles accountable for cybersecurity programs
  • Specify escalation protocols to board/committees on cyber issues
  • Compliance required for all registrants for fiscal years ending on or after December 15, 2023

Determining Cybersecurity “Materiality”

A central tenet of the SEC guidelines is the “materiality” concept regarding incident reporting. Essentially, cybersecurity events are considered “material” and require disclosure if they could sway investment decisions or shareholder votes. Think of materiality as anything significant enough to concern your board and executive team.

The tricky part is that materiality determinations do not solely rest with technology and security leaders. Corporate officers and boards make the ultimate call, despite often lacking full context into security event ramifications on financials and operations. Bridging this disconnect through close CISO collaboration is critical to set appropriate disclosure thresholds aligned with your company’s true risk profile. Ideally, final decisions should also be independently verified by an outside, nonbiased service provider.

The SEC final rule also makes extensive (more than 40) references to “third party” impacts. A breach or attack affecting a key vendor could very well represent a material event for your organization that necessitates SEC disclosure. Do not let third-party cybersecurity shortcomings undermine compliance.

Best Practices to Comply with New SEC Cybersecurity Rules

While no one-size-fits all checklist exists, your company and relevant vendors should consider these best practices on the path to cybersecurity rule compliance:

1. Designate Accountable Leadership

Empower specific business leaders as security program owners, not just technical teams. These individuals need to establish clear reporting and communication between security operations and the board/c-suite. Executive working sessions focused on cybersecurity scenario planning are also advised.

2. Add Cybersecurity Knowledge

The rules do not explicitly require it, but it is wise to have dedicated cybersecurity oversight at the board level. Bringing in third-party advisors can help boards understand cyber responsibilities and implement improved processes. This knowledge is often lacking today despite its importance.

3. Update Financial Processes

The speedy 8-K cybersecurity incident reporting necessitates updates to disclosure management procedures. Public companies should already have 8-K drafting processes, so adjusting for cyber specifics presents a modest lift. The key is removing bottlenecks to rapidly describe incident details.

4. Dedicate Compliance Resources

CISOs in many companies oversee skeletal teams lacking the bandwidth for major initiatives like interpreting new regulations, implementing new disclosures processes, conducting risk assessments, and more. Ensure your team has the resources needed to achieve compliance.

5. Build Cybersecurity Culture

Equip your leadership team, board, and financial executives with a comprehensive understanding of cyber risks and disclosure nuances. Implement ongoing education and guidance programs to keep them well-versed in cybersecurity threats, response procedures, and the latest developments in the field.

How MGO Can Expedite Your Compliance Journey

The SEC cybersecurity rules are a wake-up call to take cyber preparedness as seriously as any other existential risk to your organization. Let our team of security, financial, and regulatory professionals guide you toward proactive, comprehensive compliance. Reach out today to discuss your roadmap.

How a Cyber Maturity Assessment (CMA) Can Help Protect Your Government Against Security Threats

Executive Summary:

  • Cyber threats are increasingly elevating data and infrastructure risks for state and local governments. Proactive security standards and assessments can strengthen governmental defenses.
  • Cyber Maturity Assessments (CMAs) evaluate preparedness to safeguard against, detect, isolate, and respond to system threats holistically across staff, procedures, and tools.
  • Conducting a CMA can provide governments strategic advantages, such as: gauging risk management capabilities, fostering a security culture, mapping regulatory requirements, adapting to the evolving threat landscape, and informing cybersecurity strategies.

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Cyber threats grow more sophisticated every day, increasing risks to sensitive data and critical services at the state and local level. With public-sector cyberattacks on the rise, today’s governments need to reinforce their cyber defenses to protect government operations and maintain constituent trust.

In the realm of cybersecurity, staying ahead of the curve is not just advisable; it’s imperative. In 2016, the Department of Defense (DoD) introduced a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS). This rule mandated new cybersecurity safeguards and cyber incident reporting for controlled unclassified information (CUI).

Transitioning from DFARS, the DoD has now developed the Cybersecurity Maturity Model Certification (CMMC), a framework designed to enhance the cybersecurity of government contractors. While state and local governments are not beholden to the CMMC, your team can still benefit from embracing CMMC standards and proactively developing comprehensive security programs.

5 Benefits of a Cyber Maturity Assessment for Your State or Local Government

To check your government against CMMC standards, a powerful tool you can employ is a Cyber Maturity Assessment (CMA) — which examines your organization’s overall preparedness to safeguard against, recognize, isolate, and react to cyber threats that could compromise sensitive data and systems. Analyzing more than just adherence to regulations, a CMA is a holistic analysis of people, processes, and tools that assesses the entity’s broader cyber risk exposure and defenses.

Here are five ways a CMA can be a trusted ally in fortifying your cybersecurity defenses:

1. Risk Management

The CMA framework addresses the crucial question: Is your organization equipped to navigate evolving risks effectively? With the assistance of CMA, state and local governments can gain insights into the maturity of their current processes and mechanisms. This empowers them to make informed decisions on risk mitigation strategies, ensuring a robust defense against emerging cyber threats.

2. Strengthening Security Culture

Promoting a culture of security and privacy by design is paramount in today’s digital landscape. CMA serves as a catalyst in fostering this mindset within organizations. By assessing the maturity of security practices, it enables state and local governments to identify areas for improvement, laying the foundation for a resilient security culture.

3. Understanding of Multiple Regulatory Requirements

Navigating the complex web of regulatory requirements is a challenge for any government entity. CMA provides a comprehensive understanding of an organization’s capabilities to meet controls-based regulatory requirements. This not only ensures compliance but also establishes a framework for efficient regulatory adherence, minimizing vulnerabilities.

4. Proactiveness in an Ever-Evolving Cybersecurity Landscape 

As cyber threats continue to grow in scale and sophistication, organizations must be proactive in adapting to the evolving landscape. CMA equips state and local governments with the foresight needed to stay ahead of cybercriminals. By identifying potential threats and vulnerabilities, organizations can implement strategies to drive growth and transformation while safeguarding their digital assets.

5. Determining Considerations for a Cybersecurity Strategy 

Crafting an effective cybersecurity strategy requires a deep understanding of an organization’s capabilities and potential areas for improvement. CMA assists in identifying key considerations for a cybersecurity strategy, ensuring that state and local governments can rapidly adapt to the dynamic cybersecurity landscape.

Employing a Methodical Approach to CMA that Delivers Actionable Insights

Conducting a productive CMA that yields meaningful insights requires experience with security frameworks and familiarity with the latest threat trends impacting state and local governments. At MGO, our Technology and Cybersecurity Advisory (TCA) team approaches each CMA engagement through a consistent methodology focused on mapping security practices to leading industry standards, evaluating core capability areas, and developing practical recommendations tailored to the organization. 

Key elements of MGO’s CMA methodology include:

  • Utilization of NIST Cybersecurity Framework (CSF), ISO 27001 or CIS Controls as a Baseline – The TCA team will help you identify current gaps in the security of information assets and determine potential opportunities for improvement relative to your organization’s size and stage in the lifecycle.
  • Focus on Key Cybersecurity Capabilities – Emphasizing key cybersecurity capabilities including governance, detection, prevention, response and legal compliance, the TCA team will assist in aligning and mapping these capabilities against industry standards.
  • Recommend Prioritized Areas of a Management Action Plan – The TCA team will assist you in identifying key areas of improvement and provide a risk-ranking to help prioritize moving forward.
  • Maintaining Continuous Improvement – Instituting a recurring cycle of assessment and improvement is crucial, as cybersecurity maturity is a dynamic process that must adapt to evolving threats and business needs.

How We Can Help You Achieve Your Cybersecurity Goals 

Our highly skilled team delivers in-depth cybersecurity and business knowledge that translates to outside-the-box thinking and practical recommendations. We will work with your team to conduct deep-dive walkthroughs and technical testing to help you manage potential cybers

State and Local Cybersecurity Improvement Act Update: Get Started Protecting Sensitive Data and Systems

On May 18, 2021, the House of Representatives passed the State and Local Cybersecurity Improvement Act (SLCIA) to address cybersecurity vulnerabilities and promote additional cybersecurity collaborative efforts between the Department of Homeland Security (DHS) and state, local, tribal, and territorial governments. The bipartisan bill was received in the Senate on July 21, 2021, read twice, and then referred to the Committee on Homeland Security and government affairs, where it has been sitting since. Once it passes, it will go to the President’s desk, where it will then immediately provide incentives to address the increasing danger of malicious cyberattacks on state and local IT infrastructure.

Giving state and local governments the resources to protect against hackers

The SLCIA updates the Homeland Security Act of 2002 to give the DHS leeway to utilize centers like the Cybersecurity and Infrastructure Security Agency (CISA) and Multi-State Information Sharing and Analysis Center (MS-ISAC). This will allow them to work with state, local, tribal, and territorial governments as needed, upon request.

This collaboration will encourage conducting cybersecurity exercises and hosting trainings meant to address current or future cyber risks or incidents. It will also provide operational and technical assistance to state and local governments to implement security resources, tools, and procedures to improve overall protection against attacks. The goal is to provide state and local governments with the support they need to defend themselves from hackers.

Resources to bolster government security capabilities

The SLCIA establishes a $500 million DHS grant program that will empower government institutions to increase their focus on cybersecurity. The bill also:

  • Requires CISA to develop a strategy to improve cybersecurity of state, local, tribal, and territorial governments, enabling them to identify federal resources to capitalize on as well as set baseline objectives for their efforts;
  • Indicates state, local, tribal, and territorial governments must develop a comprehensive cybersecurity plan to guide their usage of any grant money they receive;
  • Establishes a state and local cybersecurity resiliency committee made up of representatives from state, local, tribal, and territorial governments to provide awareness of cybersecurity needs; and
  • Enjoins CISA to assess the feasibility of a rotational program for the detail of approved government employees holding cyber positions.

The bill gives state and local governments the push they need to begin defending their networks. This can include the development of new strategies to boost their cybersecurity capabilities and acquisition of the funding needed to ensure their implementation. By investing in cybersecurity ahead of an attack, an entity is more likely to save money and protect its data.

Assessing eligibility for cybersecurity grants

Cybersecurity grants are available to municipalities of all sizes — but it’s important to start strategizing now by considering your IT infrastructure and cybersecurity frameworks. By applying for the grants, you indicate that you are taking your entity’s security seriously and taking the proper steps to qualify.

The State and Local Cybersecurity Improvement Act will provide up to $1 billion in grants for state, local, tribal, and territorial governments, allowing them to directly address their cybersecurity threats and risks. The program’s funding starts at $2 million for 2022, $400 million for 2023, $300 million for 2024, and $100 million for 2025.

To be eligible, an entity must:

  • Maintain responsibility for monitoring, managing, and tracking its information systems, applications, and those user accounts owned and operated by the government;
  • Show it has a process of continuously prioritizing the assessment of its cybersecurity vulnerabilities and threat mitigation practices; and
  • Have a tangible plan that outlines:
    • How to manage and audit network traffic.
    • How the government plans to use the information to improve its systems’ resiliency and strength.

Our perspective

While the bill is still waiting on the Committee on Homeland Security and Governmental Affairs there are some things you can do to make sure you are ready. State and local governments should focus on building teams that can handle the grant application process — and be prepared to implement once awarded. This bill indicates that governments are past the point of merely updating a firewall or running a generic virus program — things like multifactor authentication and zero-trust architecture are viewed as the next steps (which was required for federal agencies in a 2021 executive order).

How we can help

Prior to starting the grant application process, your IT leaders should start thinking about how to handle security gaps with various procedures and consistent tests. MGO can help. Our Technology and Cybersecurity team can provide guidance as you prepare for the future.

About the authors

Francisco Colon is a Partner at MGO with extensive experience in external audit, fraud examinations, litigation support, operational and internal controls reviews, and buyer/seller due diligence. He specifically focuses on assisting organizations with evaluating and updating their internal controls with a focus on strategic alignment and fraud litigation deterrence management in a variety of industries, including tribal government, gaming, technology, cannabis, hospitality, government contracting, distribution, manufacturing, and private equity. Contact Francisco at [email protected].

Cybersecurity Best Practices When Working From Home

by Joshua Silberman, IT/Cyber Security Consultant, MGO Technology Group

As a large percentage of the US workforce transitions to work from home (WFH) situations due to the COVID-19 pandemic, we’ve looked at challenges that many organizations may face in setting up work from home (WFH) environments, as well as one of the most common tools used in making WFH resources available to your staff. Today, we’ll look at some of the best advice you, your IT team, or your managed service provider can provide your staff as they continue to work from home.

1. Turn on your corporate VPN, if provided, as soon as you login.

As stated in our previous article, the Virtual Private Network (VPN) is designed to make the connection between your employees and your corporate resources secure. Employees should get in the habit of activating the VPN as soon as their work or home laptops are turned on.

2. Change your password regularly

It is recommended that firms have a special procedure for incorporating password changes while employees are remote. For example, some setups require employees to be logged into the VPN before they initiate the password change on their own devices. Your employer’s technical staff or MSP should formalized the procedure and make it publicly available to you.

3. Avoid sharing your password

Sharing of passwords goes against almost everything we know about cybersecurity. However, in these times extraneous circumstances may require a transfer of passwords, especially in cases of troubleshooting. Try to avoid sharing your password, but if you must, follow these simple rules:

  1. ONLY share your password with a trusted source whose identity you can verify. This includes your local IT department or MSP. If you have any doubt about who you are sharing your password with, DO NOT SHARE IT. The inconvenience of not sharing your password is not worth the potential damage that could be caused by a data breach.
  2. ONLY share your password through a secure method. The safest is a phone call, but if you must use a messaging service, try to stick to simple SMS and do not use apps such as Facebook Messenger.
  3. As soon as the task requiring the password share is completed, change your password immediately. The longer this action is delayed the longer you and your firm are at risk.

4. Avoid letting other family members use your corporate laptop or devices.

It might be tempting to hand off your device to a family member for a simple task, but remember that in most cases you do not own your corporate devices and are liable for any damage or data leakage caused by your family members.

5. Be mindful of who is around you both virtually and in person.

Picture this scenario: You are on a call with someone in which confidential information is shared. A family member overhears and decides to share this information over their personal social media page for exposure, perhaps not understanding the confidential nature of this information. Suddenly you have a potential data breach of confidential information on your hands.

Though quarters might be tight, it’s important to be cognizant of who is around you at all times. This may include having discussions with family members so they understand that what might see or hear from you is confidential.

6. Remember that, in most cases, your work devices are not yours.

When you are issued a device, it usually comes the legal caveat that the device still belongs to the company along with anything that is introduced to that device. In most employment agreements the employer stipulates that they have the right to access, search, seize, and erase the device at any time. So if you have personal files and photos on any of your work devices, it would be prudent to move or back them up to a personal storage space.

7. Always listen to and follow the advice and notices of your IT staff.

As the COVID-19 situation progresses, new guidelines and rules may have to be developed. These should be communicated to you by your technical staff, HR personnel, or MSP. Assuming the source is verified, you should follow their guidance to the best of your abilities.

8. Never hesitate to ask questions of your IT staff if you are unsure of something.

In the realm of IT Security, there are no stupid questions. Your company has every interest in keeping you productive and safe. You can do your part by engaging with the IT staff or MSP through established channels. This can range from a critical system failure all the way down to reaching out to verify if new guidance you might have received did in fact come from the.

9. Consider how your family activities might affect available bandwidth in your home.

As you work from home, the strain on your home internet connection might become apparent as more devices are using the connection for longer periods of time. This will be especially true if you are home with other family members. You may notice lags on conference calls or the VPN taking longer to connect than usual.

While you can work with your internet service provider to see if you can increase the amount of bandwidth allocated to your house you may also want to consider network usability times with your family. This may be difficult, especially given the bandwidth resources needed for online school learning, but could be a necessary step in ensuring you have enough bandwidth during critical times such as video calls and high volume file transfers.

Ready to learn more? Join us for our up-coming webinar: Cultivating a Culture of Cybersecurity Awareness. Register here.

Or you can schedule a consultation with the MGO Technology Group here.

Cybersecurity Culture: Empowering Your Employees

by Joshua Silberman, IT / Cyber Security Consultant, MGO Technology Group

Are your employees comfortable telling leadership about a potential problem at your company? Now ask yourself, are they comfortable telling leadership about a potential mistake? A large number of today’s cyberbreaches often begin as the result of an innocent mistake by an employee. It might be sharing a password over an unprotected median, a nefarious actor grabbing a picture of an employee’s laptop screen while they are working in public, or as is most common, an employee clicks on an innocuous link from a phishing email. What most employers may not realize is that many employee’s common sense regarding breaches is actually pretty good. At the very least they will suspect that something is amiss, which could be the first step in detecting a potential breach. Empowering your employees to actively look for, and report on, potential breaches goes a long way to helping your organization build a strong cyber security culture.

Creating a positive cyber security culture

The first step is to educate your employees on what to look out for when it comes to cyber and information risk. Many firms employ some form of basic cyber-security training, mostly at the time of on-boarding, but training usually ends there. Cyber security is an ever-shifting landscape where threats are always evolving. This is why it is important for firms to enact a year-round cyber security awareness program based around employee activities. A good employee-based cyber security awareness program will be light on technical jargon and focused on highlighting the vulnerabilities of the processes and systems that all employees use in their day-to-day work, such as instant messaging, answering e-mails, browsing the web, and sending documents through authorized and unauthorized means of file sharing. There is no great need to get into the technical details of how an attack might happen, but rather acknowledge that the danger is out there and focus on what employees can do to look out for potential dangers, such as noticing strange URL’s and suspicious e-mail attachments from unrecognized users. Consistently educating employees on current cyber threats and methods will give them the tools to identify a threat and be proactive in helping your company stop it.

Encouraging active breach and threat reporting

Training employees to spot the dangers is only half the battle. The other half is generating an effective reporting culture. No cyber security strategy is complete without a good cyber security reporting culture that puts a premium on reporting potential breaches. Here are a few suggestions to create a positive culture of reporting:

Have the team that provides your first level IT Support lead awareness/education sessions, as they will mostly likely also be the first point of contact for reporting potential breaches. The sessions can be developed by an outside consultant or an internal cyber security professional, but building a repertoire between those who should be reporting the incident and that first point of contact provides a sense of comfort that your employees are reporting the issue to the right group in the correct way.

In training, the IT support staff should make clear that reporting a threat is NOT a burden and that employees should err on the side of caution. If an employee receives an e-mail they find suspect they should not hesitate to contact their IT department through the designated reporting means.

Everyone from the organization must know and believe that the consequences of reporting a potential mistake will not be dire. Beyond feeling comfortable reporting suspicious activities, employees must also feel comfortable in reporting suspicious behavior that might be a direct result of their own actions. If an employee feels that admitting a mistake will be detrimental to their career they will keep quiet and a potential breach oversight could occur. Admittedly, this strategy carries some risk as you do not want certain behaviors to be consequence-free. However, the scope of consequence must be weighed against the actual action.

For example, an employee need not be officially reprimanded for admitting to clicking on a suspicious link and reporting it, but it would be prudent for the IT support staff to point out what could have been done differently to avoid the infraction. If the employee becomes a repeat offender, then a more official process might be warranted. Until then, simply pointing out of the issue should be enough to change behavior while maintaining a culture where employees are not fearful of bringing an issue forward.

Strong and proactive cyber security culture starts at the top

When setting the company’s cyber security policy, upper management must keep an eye toward baseline employees who perform the day-to-day actions of the company. Clear signals about saying something if you think something is wrong can go a long way toward changing your company culture. Having a strong IT or Cyber Security group is simply not enough when your own staff could unknowingly be your cyber Achilles Heel. There is a saying in cyber security that “every employee is a potential vulnerability.” However, if trained and leveraged correctly, your employees can also act as another safeguard, actively working to protect your information technology environment.

If you have any questions or would like support developing and implementing an effective cyber security program, reach out to the MGO Technology Group for a consultation.

Credential Harvesting

For many years, malware viruses have been the go-to tool for cyber attackers – and as a result, cybersecurity protocols and training have been engineered to minimize the impact of malware. More recently, a new threat has emerged that is changing the landscape of cyber and information security: credential harvesting. To protect personal and/or company information and resources, you must familiarize yourself with this new data breaching method and ways to manage related risks.

What is credential harvesting?

Credential harvesting, also known as password harvesting, is the process of gathering valid usernames, passwords, private emails, and email addresses through infrastructure breaches. The possible motivations for such a breach are many: the hackers could sell delicate personal and financial data on the dark web; gain access to a company network for purposes of corporate espionage and steal IP or other assets; or use the data to embezzle money.

How credential harvesting occurs

A commonly cited source of credential harvesting is the use of phishing emails. These emails contain an attachment encoded with a hyperlink that, when clicked, uploads data-stealing programs onto your console. While phishing emails are the most common avenue, password harvesting can also be performed by malware viruses, cloned website links, the use of unsecure third party vendors, and ransomware. In many cases, the breached user has no knowledge that the malicious attack has occurred, and continues to believe they are shielded by cybersecurity measures.

This is especially accurate in cases when cloned websites are the source of the credential harvesting, as they are extremely similar in features and makeup to the real webpages they emulate. When a user logs into any account on a cloned website, their login information is directly sent to the attacker. The number of users who access accounts on phony websites can be significant and the stockpile of valuable data collected can have disastrous consequences.

Taking an active stance against credential harvesting scams

There are proactive steps anyone can take to mitigate the chances of falling prey to credential harvesting. Cloned websites can be detected by spotting an unusual URL unrelated to the actual website. For example, when using Google, instead of seeing a normal Google webpage, a cloned Google webpage will have a URL that is not Google related. Another common indicator that a webpage is cloned is if an unexpected web browser window pops up without a user physically opening it. For example, if the Google Chrome application randomly opens up as you are analyzing sensitive data vital to your company, your system may be infected. If caught in such a situation, it is best to not log into any accounts on the opened tab and instead force quit the application, and immediately notify your IT department of what happened.

When it comes to phishing emails, you must be vigilant when receiving emails and be sure not to click on any unknown or unusual links. This could lead to infected programs popping up that you did not intentionally download.

There a number of other ways a credential harvesting can occur. To protect your vital information from an instantaneous and anonymous breach, you should regularly back up your devices to the cloud and promptly install all security patches and upgrades.

Protecting your organization against credential harvesting

Credential harvesting is a real and rising threat … and anyone can be the next victim. Users must continually update their security software, backup their data, and be mindful of the links they follow and sites they visit. Following these simple steps will help protect you, and your business, from becoming the next victim of credential harvesting.

If you have any questions or fear your organization is at risk for credential harvesting, please reach out to the MGO Technology Group for a consultation.