Wikipedia defines social engineering, in the context of information security, as the “psychological manipulation of people into performing actions or divulging confidential information.” Our increasing reliance on vast networks of digital technology for information storage, research, controls, and transactions makes organizations highly vulnerable to social engineering fraud.
There is a strong urge to combat this risk with a technological fix like stronger encryption or better management controls. The problem is not a technical one because social engineering fraud is based on the exploitation of human interactions and human frailties.
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The on-going regulatory response to the 2008 financial crisis includes the Office of the Comptroller of the Currency (OCC) Risk Management Guidance on third-party relationships, issued in October 2013. The bulletin states that the OCC expects a bank to practice effective risk management regardless of whether the bank performs the activity internally or through a third party.
“A bank’s use of third parties does not diminish the responsibility of its board of directors and senior management to ensure that the activity is performed in a safe and sound manner and in compliance with applicable laws.”
In a recent speech before the Risk Management Association, Thomas J. Curry, Comptroller of the Currency, emphasized the importance of managing the risks “associated with bank systems and processes” even above credit risk. He noted banks’ “increasing reliance on third parties” and the systemic risks they impose. … Continue reading
In general, compliance is conforming to particular expectations, standards, or behaviors, where risk is an exposure to potential loss or injury. When we think of compliance in the security arena, it often means that you are following prescribed standards, which could be regulatory, industry best practices, or standards that are otherwise customized or company specific.
While compliance and risk often follow the same path, a compliance audit or survey is often performed with a one-size-fits-all “compliance only” approach, as opposed to one that requires more complex reasoning.
Some may question the rationale of compliance if risk is not a constant consideration. Lack of experience, industry knowledge, or even simply lack of time can hinder the ability to take a more risk-based direction. After all, taking a compliance only approach simplifies the security audit process by allowing for uniform application, reduced subjectivity and error in assessment, and strong performance metrics capability.
Is the added complexity of a risk-based approach worth the effort? … Continue reading