+Anomalous Behavior
---+Unusual Transactions
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Anomalous Behavior
Description
Mechanisms exist to utilize User & Entity Behavior Analytics (UEBA) and/or User Activity Monitoring (UAM) solutions to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Indicators of Compromise (IoC)
∙ Indicators of Exposure (IoE)
∙ Managed Security Services Provider (MSSP)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Indicators of Compromise (IoC)
∙ Indicators of Exposure (IoE)
∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Indicators of Compromise (IoC)
∙ Indicators of Exposure (IoE)
∙ Security Incident Event Manager (SIEM)
∙ Extended Detection and Response (XDR)
∙ Managed Security Services Provider (MSSP)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Indicators of Compromise (IoC)
∙ Indicators of Exposure (IoE)
∙ Security Incident Event Manager (SIEM)
∙ Extended Detection and Response (XDR)
∙ Managed Security Services Provider (MSSP)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Indicators of Compromise (IoC)
∙ Indicators of Exposure (IoE)
∙ Security Incident Event Manager (SIEM)
∙ Extended Detection and Response (XDR)
∙ Managed Security Services Provider (MSSP)
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.
Level 2 Planned Tracked
Continuous Monitoring (MON) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Continuous monitoring may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
Level 3 Well Defined
Continuous Monitoring (MON) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM)).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with MON domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to utilize User & Entity Behavior Analytics (UEBA) and/or User Activity Monitoring (UAM) solutions to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities.
Level 4 Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
1. Overview
| Summary |
Standard |
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Unusual Transactions
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Description
Mechanisms exist to define "normal business activities" to identify anomalous transaction activities that can reduce the opportunity for sending (outbound) and/or receiving (inbound) hostile and/or fraudulent actions.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Indicators of Fraud (IoF) (e.g., fraud "red flags")
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Indicators of Fraud (IoF) (e.g., fraud "red flags")
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Indicators of Fraud (IoF) (e.g., fraud "red flags")
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Indicators of Fraud (IoF) (e.g., fraud "red flags")
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Indicators of Fraud (IoF) (e.g., fraud "red flags")
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
SCR-CMM Level 1 criteria definitions are not available for this control:
▪ A reasonable person would conclude this control requires a structured process.
▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.
Level 2 Planned Tracked
Data Classification & Handling (DCH) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with DCH domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations.
Level 3 Well Defined
Continuous Monitoring (MON) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM)).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with MON domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to establish organization-defined "normal business activities" to identify anomalous transaction activities that can reduce the opportunity for sending (outbound) and/or receiving (inbound) fraudulent actions.
Level 4 Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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1.1 References
1.2 Identified Requirements
1.3 Related Regulations
2. Identified Requirements
Requirements
| Source |
Requirement |
3. Related Regulations
Regulations
| Source |
Regulation |
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EULAW
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Article 10 1
1. Financial entities shall have in place mechanisms to promptly detect anomalous activities, in accordance with Article 17, including ICT network performance issues and ICT-related incidents, and to identify potential material single points of failure.
All detection mechanisms referred to in the first subparagraph shall be regularly tested in accordance with Article 25.
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EULAW
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Article 22 ICT-related incident management policy
Article 22
ICT-related incident management policy
As part of the mechanisms to detect anomalous activities, including ICT network performance issues and ICT-related incidents, financial entities shall develop, document, and implement an ICT-related incident policy through which they shall:
(a)
document the ICT-related incident management process referred to in Article 17 of Regulation (EU) 2022/2554;
(b)
establish a list of relevant contacts with internal functions and external stakeholders that are directly involved in ICT operations security, including on:
(i)
the detection and monitoring of cyber threats;
(ii)
the detection of anomalous activities;
(iii)
vulnerability management;
(c)
establish, implement, and operate technical, organisational, and operational mechanisms to support the ICT-related incident management process, including mechanisms to enable a prompt detection of anomalous activities and behaviours in accordance with Article 23 of this Regulation;
▼C1
(d)
retain all evidence relating to ICT-related incidents for a period that shall be no longer than necessary for the purposes for which the data are collected, commensurate with the criticality of the affected business functions, supporting processes, and ICT and information assets, in accordance with Article 8(2) of Commission Delegated Regulation (EU) 2024/1772 (
2
) and with any applicable retention requirement pursuant to Union law;
▼B
(e)
establish and implement mechanisms to analyse significant or recurring ICT-related incidents and patterns in the number and the occurrence of ICT-related incidents.
For the purposes of point (d), financial entities shall retain the evidence referred to in that point in a secure manner.
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EULAW
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Article 23 Anomalous activities detection and criteria for ICT-related incidents detection and response
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EULAW
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Article 23 Anomalous activities detection and criteria for ICT-related incidents detection and response
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EULAW
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Article 34 ICT operations security
Article 34
The financial entities referred to in Article 16(1) of Regulation (EU) 2022/2554 shall, as part of their systems, protocols, and tools, and for all ICT assets:
(a)
monitor and manage the lifecycle of all ICT assets;
(b)
monitor whether the ICT assets are supported by ICT third-party service providers of financial entities, where applicable;
(c)
identify capacity requirements of their ICT assets and measures to maintain and improve the availability and efficiency of ICT systems and prevent ICT capacity shortages before they materialise;
(d)
perform automated vulnerability scanning and assessments of ICT assets commensurate to their classification as referred to in Article 30(1) and to the overall risk profile of the ICT asset, and deploy patches to address identified vulnerabilities;
(e)
manage the risks related to outdated, unsupported, or legacy ICT assets;
(f)
log events related to logical and physical access control, ICT operations, including system and network traffic activities, and ICT change management;
(g)
identify and implement measures to monitor and analyse information on anomalous activities and behaviour for critical or important ICT operations;
(h)
implement measures to monitor relevant and up-to-date information about cyber threats;
(i)
implement measures to identify possible information leakages, malicious code and other security threats, and publicly known vulnerabilities in software and hardware, and check for corresponding new security updates.
For the purposes of point (f), financial entities shall align the level of detail of the logs with their purpose and usage of the ICT asset producing those logs.
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EULAW
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Article 10 Detection
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Linked Issues
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