FFIEC CAT App B Mapping to NIST CSF DRAFT 06_15_15

FFIEC Cybersecurity Assessment Tool

FFIEC CAT App B Mapping to NIST CSF DRAFT 06_15_15

OMB: 1557-0328

Document [pdf]
Download: pdf | pdf
Appendix B: Mapping Cybersecurity Assessment Tool to NIST
Cybersecurity Framework
In 2014, the National Institute of Standards and Technology (NIST) released a Cybersecurity
Framework for all sectors. The following provides a mapping of the FFIEC Cybersecurity
Assessment Tool to the statements included in the NIST Cybersecurity Framework. NIST
reviewed and provided input on the mapping to ensure consistency with Framework principles
and to highlight the complementary nature of the two resources. As the Assessment is based on a
number of declarative statements that address similar concepts across maturity levels, the
mapping references the first time the concept arises beginning with the lowest maturity levels.
As such, statements at higher level of maturities may also map to the NIST Cybersecurity
Framework.
References for the NIST Cybersecurity Framework are provided by page number and, if
applicable, by the reference code given to the statement by NIST. The Assessment Tool is
referenced by its location in the tool. Following the mapping is the guide to the development of
the reference codes for the Assessment Tool.
The mapping is in the order of the NIST Cybersecurity Framework.
NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

A clear understanding of the organization’s business
drivers and security considerations specific to use of
informational technology and industrial control systems.
(p. 4)

Accomplished by completing the Inherent Risk Profile
part of the Assessment Tool.

Describe current cybersecurity posture (p. 4)

Accomplished by completing the Cybersecurity Maturity
part of the Assessment Tool.

Describe target state for cybersecurity (p. 4)

Accomplished if an institution implements the
assessment tool as described in the User’s Guide.

Identify and prioritize opportunities for improvement with
the context of a continuous and repeatable process (p.
4)

Accomplished if an institution implements the
assessment tool as described in the User Guide.

Assess progress toward the target state (p. 4)

Accomplished if an institution implements the
assessment tool as described in the User Guide.

Communicate among internal and external stakeholders
about cybersecurity risk (p. 4)

D1.TC.Tr.B.3: Situational awareness materials are
made available to employees when prompted by highly
visible cyber events or by regulatory alerts.
D1.TC.Tr.B.4: Customer awareness materials are
readily available (e.g., DHS’ Cybersecurity Awareness
Month materials).

June 2015

DRAFT

1

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

Risk-based approach to managing cybersecurity risk (p.
4)

D1.RM.RA.B.1: A risk assessment focused on
safeguarding customer information identifies reasonable
and foreseeable internal and external threats, the
likelihood and potential damage of threats and the
sufficiency of policies, procedures and customer
information systems.
D1.RM.RA.B.2: The risk assessment identifies internetbased systems and high-risk transactions that warrant
additional authentication controls.
D1.RM.RA.B.3: The risk assessment is updated to
address new technologies, products, services, and
connections before deployment.

Express a risk tolerance (p. 5)

D1.G.Ov.Int.1: The institution has a cyber risk appetite
statement approved by the board or an appropriate
board committee.

Determine how to handle risk (mitigate, transfer, avoid,
accept) (p. 5)

Accomplished by completing the Cybersecurity Maturity
part of the Assessment Tool.

Develop the organizational understanding to manage
cybersecurity risk to systems, assets, data and
capabilities (p. 8)

Accomplished by completing the Cybersecurity Maturity
Domain 1, Assessment Factor Governance.

Develop and implement the appropriate safeguards to
ensure delivery of critical infrastructure services (p. 8)

Accomplished by completing the Cybersecurity Maturity
Domain 3, Assessment Factor Preventative Controls.

Develop and implement the appropriate activities to
identify the occurrence of a cybersecurity event. (p. 8)

Accomplished by completing the Cybersecurity Maturity
Domain 3, Assessment Factor Detective Controls, and
Domain 5, Assessment Factor Detection, Response and
Mitigation.

Develop and implement the appropriate activities to take
action regarding a detected cybersecurity event. (p. 8)

Accomplished by completing the Cybersecurity Maturity
Domain 5, Assessment Factor Detection, Response and
Mitigation and Assessment Factor Escalation and
Reporting.

Develop and implement the appropriate activities to
maintain plans for resilience and to restore capabilities
or services that were impaired due to a cybersecurity
event. (p.9)

Accomplished by completing the Cybersecurity Maturity
Domain 5, Assessment Factor Incident Resilience
Planning and Strategy.

Tier 1: Partial
NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

Cybersecurity risk management is not formalized and
risks are managed in an ad hoc and sometimes reactive
manner. (p. 10)

This falls below Baseline.

Prioritization of cybersecurity activities may not be
directly informed by organizational risk objectives, the
threat environment or business/mission requirements.
(p. 10)

This falls below Baseline.

Limited awareness of cybersecurity risk at the
organizational level. (p. 10)

This falls below Baseline.

June 2015

DRAFT

2

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

Organization-wide approach to managing cybersecurity
risk has not been established. (p. 10)

This falls below Baseline.

Organization implements cybersecurity risk
management on an irregular, case-by-case basis due to
varied experience or information gained from outside
sources. (p. 10)

This falls below Baseline.

Organization may not have processes that enable
cybersecurity information to be shared within the
organization. (p. 10)

This falls below Baseline.

Organization may not have the processes in place to
participate in coordination or collaboration with other
entities. (p. 10)

This falls below Baseline

Tier 2: Risk Informed
NIST Cybersecurity Framework

5/13 Cybersecurity Assessment Tool

Risk management practices are approved by
management but may not be established as
organizational-wide policy. (p. 10)

D1.RM.RMP.B.1: An information security and business
continuity risk management function(s) exists within the
institution.

Prioritization of cybersecurity activities is directly
informed by organizational risk objectives, the threat
environment, or business/mission requirements. (p. 10)

D2.TI.Th.B.3: Threat information is used to enhance
internal risk management and controls.
D1.G.Ov.Int.5: The board or an appropriate board
committee ensures management’s annual cybersecurity
self-assessment evaluates the institution’s ability to
meet its cyber risk management standards.
D1.G.SP.Int.2: Management periodically reviews the
cybersecurity strategy to address evolving cyber threats
and changes to the institution’s inherent risk profile.

There is an awareness of cybersecurity risk at the
organizational level but an organization-wide approach
to managing cybersecurity risk has not been
established. (p. 10)

D1.G.Ov.B.2: Information security risks are discussed in
management meetings when prompted by highly visible
cyber events or regulatory alerts.
D1.TC.Tr.B.1: Annual information security training is
provided.
D1.TC.Tr.E.2: Management is provided cybersecurity
training relevant to their job responsibilities.

Risk-informed, management-approved processes and
procedures are defined and implemented, and staff has
adequate resources to perform their cybersecurity
duties. (p. 10)

D1.RM.RMP.E.1: The risk management program
incorporates cyber risk identification, measurement,
mitigation, monitoring and reporting.

Cybersecurity information is shared within the
organization on an informal basis. (p. 10)

D1.TC.Tr.B.3: Situational awareness materials are
made available to employees when prompted by highly
visible cyber events or regulatory alerts.

The organization knows its role in the larger ecosystem,
but has not formalized its capabilities to interact and
share information externally. (p. 10)

D1.G.SP.A.3: The cybersecurity strategy identifies and
communicates the institution’s role as a component of
critical infrastructure in the financial services industry.

D1.R.St.E.3: Staff with cybersecurity responsibilities
have the requisite qualifications to perform the
necessary tasks of the position.

D1.G.SP.Inn.1: The cybersecurity strategy identifies and
communicates the institution’s role as it relates to other

June 2015

DRAFT

3

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework
critical infrastructures.
D2.TI.Th.B.1: The institution belongs or subscribes to a
threat and vulnerability information sharing source(s)
that provides information on threats (e.g., FS-ISAC, USCERT).

Tier 3: Repeatable
NIST Cybersecurity Framework

5/13 FFIEC Cybersecurity Assessment Tool

The organization’s risk management practices are
formally approved and expressed as policy. (p. 10)

D1.G.SP.B.2: The institution has policies commensurate
with its risk and complexity that address the concepts of
information technology risk management.

Organizational cybersecurity practices are regularly
updated based on the application of risk management
processes to changes in business/mission requirements
and a changing threat and technology landscape. (p. 10)

D1.G.SP.E.3: A formal process is in place to update
policies as the institution’s inherent risk profile changes.

There is an organization-wide approach to manage
cybersecurity risk. Risk-informed policies, processes,
and procedures are defined, implemented as intended,
and reviewed. (p. 10)

D1.G.SP.Int.4: Management links strategic
cybersecurity objectives to tactical goals.

Consistent methods are in place to respond effectively
to changes in risk. (p. 10)

D1.G.SP.E.3: A formal process is in place to update
policies as the institution’s inherent risk profile changes.

Personnel possess the knowledge and skills to perform
their appointed roles and responsibilities. (p. 10)

D1.R.St.E.2: Management with appropriate knowledge
and experience leads the institution’s cybersecurity
efforts.

D1.G.RM.Au.B.1: Independent audit or review
evaluates policies, procedures, and controls across the
institution for significant risks and control issues
associated with the institution's operations, including
risks in new products, emerging technologies, and
information systems.

D1.R.St.E.3: Staff with cybersecurity responsibilities
have the requisite qualifications to perform the
necessary tasks of the position.
The organization understands its dependencies and
partners and receives information from these partners
that enables collaboration and risk-based management
decisions within the organization in response to events.
(p. 10)

D4.C.Co.B.1: The critical business processes that are
dependent on external connectivity have been identified.
D2.TI.Th.B.1: The institution belongs or subscribes to a
threat and vulnerability information sharing source(s)
that provides information on threats (e.g., FS-ISAC, USCERT).
D2.TI.Th.Int.1: A formal threat intelligence program is
implemented and includes subscription to threat feeds
from external providers and internal sources.
D4.RM.Co.E.2: Responsibility for notification of direct
and indirect security incidents and vulnerabilities is
documented in contracts or SLAs.

June 2015

DRAFT

4

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

Tier 4: Adaptive
NIST Cybersecurity Framework

5/13 FFIEC Cybersecurity Assessment Tool

Adapt cybersecurity practices based on lessons learned
and predictive indicators derived from previous and
current cybersecurity activities. (p. 11)

D5.DE.Re.E.8: Analysis of events is used to improve the
institution's security measures and policies.
D5.IR.Pl.Int.4: Lessons learned from real-life cyber risk
incidents and attacks on the institution and other
institutions improve the institution’s risk mitigations
capabilities and response plan.
D1.TC.Tr.Int.1: Management incorporates lessons
learned from social engineering and phishing exercises
to improve the employee awareness programs.

Continually incorporates advanced technologies and
practices, adapting to a changing cybersecurity
landscape. (p. 11)

D1.G.SP.A.5: Management is continuously improving
the existing cybersecurity program to adapt as the
desired cybersecurity target state changes.

Responds to evolving and sophisticated threats in a
timely manner. (p. 11)

D5.IR.Pl.B.1: The institution has documented how it will
react and respond to cyber incidents.
D5.IR.Pl.A.2: Multiple systems, programs, or processes
are implemented into a comprehensive cyber resilience
program to sustain, minimize and recover operations
from an array of potentially disruptive and destructive
cyber incidents.

Manages cybersecurity risk through an organizationwide approach using risk-informed policies, processes,
and procedures to address potential cybersecurity
events. (p.11)

D5.IR.Pl.B.1: The institution has documented how it will
react and respond to cyber incidents
D1.TC.Cu.E.1: The institution has formal standards of
conduct that hold all employees accountable for
complying with all cybersecurity policies and
procedures.
D1.RM.RMP.Int.2: The risk management program
specifically addresses cyber risks beyond the
boundaries of the technological impacts (e.g., financial,
strategic, regulatory, compliance).
D1.G.Ov.A.5: Management and the board or an
appropriate board committee hold business units
accountable for effectively managing all cyber risks
associated with their activities.

Encourage cybersecurity risk management as part of
culture. (p.11)

D1.TC.Cu.Int.2: The risk culture requires formal
consideration of cyber risks in all business decisions.
D1.TC.Cu.A.1: Management ensures continuous
improvement of cyber risk cultural awareness.

Evolve process from an awareness of previous
activities, information shared by other sources, and
continuous awareness of activities on systems and
networks. (p. 11)

D1.G.Ov.A.2: Management has a formal process to
continuously improve cybersecurity oversight.

Actively share information with partners to ensure that
accurate, current information is being distributed and
consumed to improve cybersecurity before a
cybersecurity event occurs. (p. 11)

D2.IS.Is.Int.3: Information is shared proactively with the
industry, law enforcement, regulators, and information
sharing forums.

June 2015

DRAFT

5

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

Framework Profile
NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

Establish a roadmap for reducing cybersecurity risk. (p.
11)

Discussed in the User’s Guide.

Develop a Current Profile. (p. 11)

Discussed in the User’s Guide.

Develop a Target Profile. (p. 11)

Discussed in the User’s Guide.

Identify and remediate gaps in Current and Target
Profiles. (p. 11)

Discussed in the User’s Guide.

Develop a risk-management approach to achieve
cybersecurity goals in a cost-effective, prioritized
manner (p. 11)

Discussed in the User’s Guide.

Executive leadership communicates the mission
priorities, available resources, and overall risk tolerance
to the business/process level. (p. 12)

Discussed in the User’s Guide and the Overview for
CEOs and Boards of Directors.

Business/Process managers collaborates with the
implementation/operations level to communicate
business needs and create a risk Profile using the input
from the Executive leadership. (p. 12)

Discussed in the User’s Guide and the Overview for
CEOs and Boards of Directors.

Business/process managers perform an impact
assessment from the implementation progress provided
by the implementation/operations group. (p. 12)

Discussed in the User’s Guide and the Overview for
CEOs and Boards of Directors.

Business/process managers perform an impact
assessment from the implementation progress provided
by the implementation/operations group. (p. 12)

Discussed in the User’s Guide and the Overview for
CEOs and Boards of Directors.

Business/process managers report the outcomes of that
impact assessment to the executive level to inform the
organization’s overall risk management process. (p. 12)

Discussed in the User’s Guide and the Overview for
CEOs and Boards of Directors.

Business/process managers notify the
implementation/operations level to raise awareness of
business impact. (p. 12)

Discussed in the User’s Guide and the Overview for
CEOs and Boards of Directors.

Operations group communicates the risk Profile
implementation progress to the business/process level.
(p. 12)

Discussed in the User’s Guide and the Overview for
CEOs and Boards of Directors.

Create or improve a cybersecurity program. (p. 13)

Discussed in the user’s guide.

Organization identifies its business/mission objectives
and high-level organizational priorities. (p. 14)

Discussed in the user’s guide.

Organization identifies related systems and assets,
regulatory requirements, and overall risk approach. (p.
14)

Accomplished by completing the Inherent Risk Profile
part of the Tool.

Organization identifies threats to, and vulnerabilities of,
identified systems and assets (p. 14)

Accomplished if an institution completes the Inherent
Risk Profile part of the Cybersecurity Assessment.

Develop a Current Profile. (p. 14)

Accomplished if an institution implements the
Cybersecurity Assessment tool as described in the User
Guide.

Conduct a risk assessment. (p. 14)

Accomplished if an institution completes the Inherent
Risk Profile part of the Cybersecurity Assessment.

Create a Target Profile. (p. 14)

Accomplished if an institution implements the
assessment tool as described in the User Guide.

June 2015

DRAFT

6

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

Compare the Current and Target Profile to determine
gaps. (p. 14)

Accomplished if an institution implements the
assessment tool as described in the User Guide.

Create a prioritized action plan to address gaps. (p. 14)

Accomplished if an institution implements the
assessment tool as described in the User Guide.

Implement action plan. (p. 14)

Accomplished if an institution implements the
assessment tool as described in the User Guide.

Repeat as needed to continuously assess and improve
cybersecurity. (p. 14)

Accomplished if an institution implements the
assessment tool as described in the User Guide.

Communicate cybersecurity requirements with
interdependent stakeholders responsible for the delivery
of essential critical infrastructure services. (p. 15)

D4.RM.Co.B.1: Formal contracts that address relevant
security and privacy requirements are in place for all
third parties that process, store, or transmit confidential
data or provide critical services.
D4.RM.Co.E.2: Responsibility for notification of direct
and indirect security incidents and vulnerabilities is
documented in contracts or SLAs.

Identify and address individual privacy and civil liberties
implications that may result from cybersecurity
operations (p. 15)
Governance of cybersecurity risk
Identifying and authorizing access
Awareness and training measures
Anomalous activity detection reviewed for privacy
concerns.
Review of the sharing of personal information within and
outside of the organization.

D4.RM.Co.B.1: Formal contracts that address relevant
security and privacy requirements are in place for all
third parties that process, store, or transmit confidential
data or provide critical services.D1.G.Ov.E.2:
Management is responsible for ensuring compliance
with legal and regulatory requirements related to
cybersecurity.
D2.IS.Int.2: Information sharing agreements are used as
needed or required to facilitate sharing threat
information with other financial sector institutions or third
parties.

Appendix A: Framework Core
NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

ID.AM-1: Physical devices and systems within the
organization are inventoried (p. 20)

D1.G.IT.B.1: An inventory of organizational assets (e.g.,
hardware, software, data, and systems hosted externally)
is maintained.

ID.AM-2: Software platforms and applications within
the organization are inventoried (p. 20)

D1.G.IT.B.1: An inventory of organizational assets (e.g.,
hardware, software, data, and systems hosted externally)
is maintained.

ID.AM-3: The organizational communication and data
flow is mapped (p. 20)

D4.C.Co.B.4: Data flow diagrams are in place and
document information flow to external parties.
D4.C.Co.Int.1: A validated asset inventory is used to
create comprehensive diagrams depicting data
repositories, data flow, infrastructure, and connectivity.

ID.AM-4: External information systems are mapped
and catalogued (p. 20)

D4.RM.Dd.B.2: A list of third-party service providers is
maintained.
D4.C.Co.B.3: A network diagram and identifies all
external connections.

ID.AM-5: Resources are prioritized based on the
classification / criticality / business value of hardware,
devices, data, and software (p. 20)

June 2015

D1.G.IT.B.4: Institution assets (e.g., hardware, systems,
data, and applications) are prioritized for protection based
on the data classification and business value.

DRAFT

7

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

ID.AM-6: Workforce roles and responsibilities for
business functions, including cybersecurity, are
established. (p. 20)

D1.R.St.B.1: Information security roles and
responsibilities have been identified.

ID.BE-1: The organization’s role in the supply
chain is identified and communicated (p. 21)

D1.G.SP.A.3: The cybersecurity strategy identifies and
communicates the institution’s role as a component of
critical infrastructure in the financial services industry.

ID.BE-2: The organization’s place in critical
infrastructure and their industry ecosystem is identified
and communicated (p. 21)

D1.G.SP.Inn.1: The cybersecurity strategy identifies and
communicates its role as it relates to other critical
infrastructures.

ID.BE-3: Priorities for organizational mission,
objectives, and activities are established (p. 21)

D1.G.SP.E.2: The institution has a formal cybersecurity
program that is based on technology and security industry
standards or benchmarks.

D1.TC.Cu.B.1: Management holds employees
accountable for complying with the information security
program.

D1.G.Ov.Int.5: The board or an appropriate board
committee ensures management’s annual cybersecurity
self-assessment evaluates the institution’s ability to meet
its cyber risk management standards.
D1.G.SP.Int.3: The cybersecurity strategy is incorporated
into, or conceptually fits within, the institution’s enterprisewide risk management strategy.
ID.BE-4: Dependencies and critical functions for
delivery of critical services are established (p. 21)

D4.C.Co.B.1: The critical business processes that are
dependent on external connectivity have been identified.
D1.G.IT.E.2: Organizational assets (e.g., hardware,
systems, data, and applications) are prioritized for
protection based on the data classification and business
value.

ID.BE-5: Resilience requirements to support delivery
of critical services are established (p. 21)

D5.IR.Pl.B.5: A formal backup and recovery plan exists
for all critical business lines.
D5.IR.Pl.E.3: Alternative processes have been
established to continue critical activity within a reasonable
time period.

ID.GV-1: Organizational information security policy is
established (p. 21)

D1.G.Ov.SP.B.4: The institution has board-approved
policies commensurate with its risk and complexity that
address information security.

ID.GV-2: Information security roles & responsibility are
coordinated and aligned with internal roles and
external partners. (p. 21)

D1.G.Ov.SP.B.7: All elements of the information security
program are coordinated enterprise-wide.
D4.RM.Co.B.2: Contracts acknowledge that the third party
is responsible for the security of the institution’s
confidential data that it possesses, stores, processes, or
transmits.
D4.RM.Co.B.5: Contracts establish responsibilities for
responding to security incidents.

ID.GV-3: Legal and regulatory requirements regarding
cybersecurity, including privacy and civil liberties
obligations, are understood and managed (p. 21)

June 2015

D1.G.Ov.E.2: Management is responsible for ensuring
compliance with legal and regulatory requirements related
to cybersecurity.

DRAFT

8

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

ID.GV-4: Governance and risk management
processes address cybersecurity risks (p. 22)

D1.G.Ov.B.1: Designated members of management are
held accountable by the board or an appropriate board
committee for implementing and managing the information
security and business continuity programs.
D1.G.Ov.B.3: Management provides a written report on
the overall status of the information security and business
continuity programs to the board or an appropriate
committee of the board at least annually.
D1.G.Ov.E.1: At least annually, the board or an
appropriate board committee reviews and approves the
institution’s cybersecurity program.
D1.G.SP.E.1: The institution augmented its information
security strategy to incorporate cybersecurity and
resilience.
D1.G.Ov.Int.1: The institution has a cyber risk appetite
statement approved by the board or an appropriate board
committee.

ID.RA-1: Asset vulnerabilities are identified and
documented (p. 22)

D2.TI.Ti.B.2: Threat information is used to monitor threats
and vulnerabilities.
D3.DC.Th.B.1: Independent testing (including penetration
testing and vulnerability scanning) is conducted according
to the risk assessment for the external-facing systems and
the internal network.
D1.RM.RA.E.2: The focus of the risk assessment has
expanded beyond customer information to address all
information assets.
D3.DC.Th.E.5: Vulnerability scanning is conducted and
analyzed before deployment/redeployment of new/existing
devices.
D3.DC.Th.A.1: Weekly vulnerability scanning is rotated
amongst environments to scan all environments
throughout the year.

ID.RA-2: Threat and vulnerability information is
received from information sharing forums and sources.
(p. 22)

D2.TI.Ti.B.1: The institution belongs or subscribes to a
threat and vulnerability information sharing source(s) that
provides information on threats (e.g., FS-ISAC, USCERT).

ID.RA-3: Threats to organizational assets are
identified and documented (p. 22)

D3.DC.An.B.1: The institution is able to detect anomalous
activities through monitoring across the environment.
D2.MA.Ma.E.1: A process is implemented to monitor
threat intelligence to discover emerging threats.
D2.MA.Ma.E.4: Monitoring systems operate continuously
with adequate support for efficient incident handling.
D2.MA.Ma.Int.2: A profile is created for each threat that
identifies the likely intent, capability, and target of the
threat.

June 2015

DRAFT

9

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

ID.RA-4: Potential impacts are analyzed (p. 22)

D5.RE.Re.B.1: Appropriate steps are taken to contain ad
control an incident to prevent further unauthorized access
to or use of customer information.
D5.ER.Er.Ev.1: Criteria have been established for
escalating cyber incidents or vulnerabilities to the board
and senior management based on the potential impact
and criticality of the risk.

ID.RA-5: Threats, vulnerabilities, likelihoods, and
impacts are used to determine risk. (p. 22)

D1.RM.RA.B.1: A risk assessment focused on
safeguarding customer information identifies reasonable
and foreseeable internal and external threats, the
likelihood and potential damage of threats, and the
sufficiency of policies, procedures and customer
information systems.
D1.RM.RA.E.1: The focus of the risk assessment has
expanded beyond customer information to address all
information assets.
D1.RM.RA.E.1: Risk assessments are used to identify the
cybersecurity risks stemming from new products, services,
or relationships.

ID.RA-6: Risk responses are identified and prioritized.
(p. 22)

D5.IR.Pl.B.1: The institution has documented how it will
react and respond to cyber incidents.
D5.DR.Re.E.1: The incident response plan is designed to
prioritize incidents, enabling a rapid response for
significant cybersecurity incidents or vulnerabilities.
D5.IR.Pl.E.1: The remediation plan and process outlines
the mitigating actions, resources, and time parameters.

ID.RM-1: Risk management processes are managed
and agreed to by organizational stakeholders. (p. 23)

D1.G.Ov.B.1: Designated members of management are
held accountable by the board or an appropriate board
committee for implementing and managing the information
security and business continuity programs.

ID.RM-2: Organizational risk tolerance is determined
and clearly expressed (p. 23)

D1.G.Ov.Int.3: The institution has a cyber risk appetite
approved by the board or an appropriate board committee.

ID.RM-3: The organization’s determination of risk
tolerance is informed by their role in critical
infrastructure and sector specific risk analysis (p. 23)
PR.AC-1: Identities and credentials are managed for
authorized devices and users (p. 23)

D1.G.SP.A.4: The risk appetite is informed by the
institution’s role in critical infrastructure.
D3.PC.Im.B.7: Access to make changes to systems
configurations (including virtual machines and
hypervisors) is controlled and monitored.
D3.PC.Am.B.6: Identification and authentication is
required and managed for access to systems,
applications, and hardware.

PR.AC-2: Physical access to assets is managed and
protected (p. 23)

D3.PC.Am.B.11: Physical security controls are used to
prevent unauthorized access to information systems, and
telecommunication systems.
D3.PC.Am.B.17: Administrative, physical, or technical
controls are in place to prevent users without
administrative responsibilities from installing unauthorized
software.

June 2015

DRAFT

10

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

PR.AC-3: Remote access is managed (p. 23)

D3.PC.Am.B.16: Remote access to critical systems by
employees, contractors, and third parties uses encrypted
connections and multifactor authentication.
D3.PC.De.E.7: The institution wipes data remotely on
mobile devices when a device is missing or stolen. (*N/A if
mobile devices are not used.)
D3.PC.Im.Int.2: Security controls are used for remote
access to all administrative consoles, including restricted
virtual systems.

PR.AC-4: Access permissions are managed,
incorporating the principles of least privilege and
separation of duties (p. 24)

D3.PC.Am.B.1: Employee access is granted to systems
and confidential data based on job responsibilities, the
principles of least privilege.
D3.PC.Am.B.2: Employee access to systems and
confidential data provides for separation of duties.
D3.PC.Am.B.5: Changes to physical and logical user
access, including those that result from voluntary and
involuntary terminations, are submitted to and approved
by appropriate personnel.

PR.AC-5: Network integrity is protected, incorporating
network segregation where appropriate. (p. 24)

D3.DC.Im.B.1: Network perimeter defense tools (e.g.,
border router and firewall) are used.
D3.DC.Im.Int.1: The enterprise network is segmented in
multiple, separate trust/security zones with defense-indepth strategies (e.g., logical network segmentation, hard
backups, air-gapping) to mitigate attacks.

PR.AT-1: All users are informed and trained (p. 24)

D1.TC.Cu.B.2: Annual information security training
includes incident response, current cyber threats (e.g.,
phishing, spear phishing, social engineering, and mobile
security), and emerging issues.

PR.AT-2: Privileged users understand roles &
responsibilities (p. 24)

D1.TC.Tr.E.3: Employees with privileged account
permissions receive additional cybersecurity training
commensurate with their levels of responsibility.

PR.AT-3: Third-party stakeholders (suppliers,
customers, partners) understand roles &
responsibilities (p. 24)

D1.TC.Tr.B.4: Customer awareness materials are readily
available (e.g., DHS’ Cybersecurity Awareness Month
materials).
D1.TC.Tr.Int.2: Cybersecurity awareness information is
provided to retail customers and commercial clients at
least annually.

PR.AT-4: Senior executives understand roles &
responsibilities (p. 24)

D1.TC.Tr.E.2: Management is provided cybersecurity
training relevant to their job responsibilities.

PR.AT-5: Physical and information security personnel
understand roles & responsibilities (p. 25)

D1.TC.Tr.E.3: Employees with privileged account
permissions receive additional cybersecurity training
commensurate with their levels of responsibility.
D1.R.St.E.3: Staff with cybersecurity responsibilities have
the requisite qualifications to perform the necessary tasks
of the position.

June 2015

DRAFT

11

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework
PR.DS-1: Data-at-rest is protected (p. 25)

FFIEC Cybersecurity Assessment Tool
D1.G.IT.B.13: Confidential data is identified on the
institution's network.
D3.PC.Am.B.15: Mobile devices (e.g., laptops, tablets,
and removable media) are encrypted if used to store
confidential data. (*N/A if mobile devices are not used).
D4.RM.Co.B.1: Formal contracts that address relevant
security and privacy requirements are in place for all third
parties that process, store, or transmit confidential data or
provide critical services.
D3.PC.Am.A.1: Encryption of select data at rest is
determined by the institution’s data classification and risk
assessment.

PR.DS-2: Data-in-transit is protected (p. 25)

D3.PC.Am.B.14: Confidential data is encrypted when
transmitted across public or untrusted networks (e.g.,
Internet).
D3.PC.Am.E.5: Controls are in place to prevent
unauthorized access to cryptographic keys.
D3.PC.Am.Int.7: Confidential data is encrypted in transit
across private connections (e.g., frame relay and T1) and
within the institution’s trusted zones.

PR.DS-3: Assets are formally managed throughout
removal, transfers, and disposition (p. 25)

D1.G.IT.E.3: The institution proactively manages system
end-of-life (e.g., replacement) to limit security risks.
D1.G.IT.E.2: The institution has a documented asset lifecycle process that considers whether assets to be
acquired have appropriate security safeguards.

PR.DS-4: Adequate capacity to ensure availability is
maintained (p. 25)

D5.IR.Pl.B.5: A formal backup and recovery plan exists
for all critical business lines.
D5.IR.Pl.B.6: The institution plans to use business
continuity, disaster recovery, and data back-up programs
to recover operations following an incident.
D5.IR.Pl.E.3: Alternative processes have been
established to continue critical activity within a reasonable
time period.
D3.PC.Im.E.4: A risk-based solution is in place at the
institution or Internet hosting provider to mitigate disruptive
cyber attacks (e.g., DDoS attacks).

PR.DS-5: Protections against data leaks are
implemented (p. 26)

D3.PC.Am.B.16: Remote access to critical systems by
employees, contractors, and third parties uses encrypted
connections and multifactor authentication.
D3.PC.Am.Int.1: The institution has implemented tools to
prevent unauthorized access to or exfiltration of
confidential data.
D3.PC.De.Int.1: Data loss prevention controls or devices
are implemented for inbound and outbound
communications (e.g., e-mail, FTP, Telnet, prevention of
large file transfers).
D3.DC.Ev.Int.1: Controls or tools (e.g., data loss
prevention) are in place to detect potential unauthorized or
unintentional transmissions of confidential data.

June 2015

DRAFT

12

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

PR.DS-6: Integrity checking mechanisms are used to
verify software, firmware, and information integrity (p.
26)

D3.PC.Se.Int.3: Software code executables and scripts
are digitally signed to confirm the software author and
guarantee that the code has not been altered or corrupted.
D3.PC.De.Int.2: Mobile device management includes
integrity scanning (e.g., jailbreak/rooted detection). (*N/A if
mobile devices are not used.)

PR.DS-7: The development and testing
environment(s) are separate from the production
environment (p. 26)

D3.PC.Am.B.10: Production and non-production
environments are segregated to prevent unauthorized
access or changes to information assets. (*N/A if no
production environment exists at the institution or the institution’s
third party.)

PR.IP-1: A baseline configuration of information
technology/industrial control systems is created and
maintained (p. 26)

D3.PC.Im.B.5: Systems configurations (for servers,
desktops, routers, etc.) follow industry standards and are
enforced.

PR.IP-2: A System Development Life Cycle to manage
systems is implemented (p. 26)

D3.PC.Se.B.1: Developers working for the institution
follow secure program coding practices, as part of a
system development life cycle (SDLC), that meet industry
standards.
D3.PC.Se.E.1: Security testing occurs at all post-design
phases of the SDLC for all applications, including mobile
applications. (*N/A if there is no software development.)

PR.IP-3: Configuration change control processes are
in place (p. 27)

D1.G.IT.B.4: A change management process is in place to
request and approve changes to systems configurations,
hardware, software, applications, and security tools.

PR.IP-4: Backups of information are conducted,
maintained, and tested periodically (p. 27)

D5.IR.Pl.B.6: A formal backup and recovery plan exists
for all critical business lines.
D5.IR.Te.E.3: Information backups are tested periodically
to verify they are accessible and readable.

PR.IP-5: Policy and regulations regarding the physical
operating environment for organizational assets are
met (p. 27)

D3.PC.Am.B.11: Physical security controls are used to
prevent unauthorized access to information systems,
wireless access points, and telecommunication systems.

PR.IP-6: Data is destroyed according to policy (p. 27)

D1.G.IT.B.19: Data is disposed of or destroyed according
to documented requirements and within expected
timeframes.

PR.IP-7: Protection processes are continuously
improved (p. 27)

D1.RM.RMP.E.2: Management reviews and uses the
results of to improve existing policies, procedures, and
controls.
D1.G.Ov.A.2: Management has a formal process to
continuously improve cybersecurity oversight.

PR.IP-8: Effectiveness of protection technologies is
shared with appropriate parties (p. 28)

D2.IS.Is.B.1: Information security threat are gathered and
shared with applicable internal employees.
D.2.IS.Is.E.2: A representative from the institution
participates in law enforcement or information sharing
organization meetings.

PR.IP-9: Response plans (Incident Response and
Business Continuity) and recovery plans (Incident
Recovery and Disaster Recovery) are in place and
managed (p. 28)

June 2015

D5.IR.Pl.B.1: The institution has documented how it will
react and respond to cyber incidents.

DRAFT

13

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

PR.IP-10: Response and recovery plans are tested (p.
28)

D5.IR.Te.B.1: Scenarios are used to improve incident
detection and response.
D5.IR.Te.B.3: Systems, applications, and data recovery is
tested at least annually.

PR.IP-11: Cybersecurity is included in human
resources practices (e.g., deprovisioning, personnel
screening) (p.28)

D1.R.St.E.4: Employment candidates, contractors, and
third parties are subject to background verification
proportional to the confidentiality of the data accessed,
business requirements, and acceptable risk.

PR.IP-12: A vulnerability management plan is
developed and implemented. (p. 28)

D3.CC.Re.Ev.2: Formal processes are in place to resolve
weaknesses identified during penetration testing.

PR.MA-1: Maintenance and repair of organizational
assets is performed and logged in a timely manner,
with approved and controlled tools (p. 28)

D3.CC.Re.Int.5: The maintenance and repair of
institutional assets is performed by authorized individuals
with approved and controlled tools.
D3.CC.Re.Int.6: The maintenance and repair of
institutional assets are logged in a timely manner.

PR.MA-2: Remote maintenance of organizational
assets is approved, logged, and performed in a
manner that prevents unauthorized access (p. 28)

D3.PC.Im.B.7: Access to make changes to systems
configurations (including virtual machines and
hypervisors) is controlled and monitored.

PR.PT-1: Audit/log records are determined,
documented, implemented, and reviewed in
accordance with policy (p. 29)

D1.G.SP.B.3: The institution has policies commensurate
with its risk and complexity that address the concepts of
threat information sharing.
D2.MA.Ma.B.1: Audit log records and other security event
logs are reviewed and retained in a secure manner.
D2.MA.Ma.B.2: Computer event logs are used for
investigations once an event has occurred.

PR.PT-2: Removable media is protected and its use
restricted according to a specified policy (p. 29)

D1.G.SP.B.4: The institution has policies commensurate
with its risk and complexity that address information
security.
D3.PC.De.B.1: Controls are in place to restrict the use of
removable media to authorized personnel.
D3.PC.Im.E.3: Technical controls prevent unauthorized
devices, including rogue wireless access devices and
removable media from connecting to the internal
network(s).

PR.PT-3: Access to systems and assets is controlled,
incorporating the principle of least functionality (p. 29)

D3.PC.Am.B.7: Access controls include password
complexity and limits to password attempts and reuse.
D3.PC.Am.B.4: User access reviews are performed
periodically for all systems and applications based on the
risk to the application or system.
D3.PC.Am.B.3: Elevated privileges (e.g., administrator
privileges) are limited and tightly controlled (e.g., assigned
to individuals, not shared, and require stronger password
controls).
D4.RM.Om.Int.1: Third-party employee access to the
institution's confidential data is tracked actively based on
the principles of least privilege.

June 2015

DRAFT

14

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

PR.PT-4: Communications networks are secured (p.
29)

D3.PC.Im.B.1: Network perimeter defense tools (e.g.,
border router and firewall) are used.
D3.PC.Am.B.11: Physical security controls are used to
prevent unauthorized access to information systems, and
telecommunication systems.
D3.PC.Im.Int.1: The enterprise network is segmented in
multiple, separate trust/security zones with defense-indepth strategies (e.g., logical network segmentation, hard
backups, air-gapping) to mitigate attacks.

DE.AE-1: A baseline of network operations and
expected data flows for users and systems is
established and managed (p. 30)

D3.DC.Ev.B.1: A normal network activity baseline is
established.

DE.AE-2: Detected events are analyzed to understand
attack targets and methods (p. 30)

D5.IR.Pl.Int.4: Lessons learned from real-life cyber risk
incidents and attacks on the institution and other
organizations are used to improve the institution’s risk
mitigation capabilities and response plan.

DE.AE-3: Event data are aggregated and correlated
from multiple sources and sensors (p. 30)

D3.DC.Ev.E.1: A process is in place to correlate event
information from multiple sources (e.g., network,
application, or firewall).

DE.AE-4: Impact of event is determined (p. 30)

D5.IR.Te.E.1: Recovery scenarios include plans to
recover from data destruction, and impacts to data
integrity, data loss, and system and data availability.

D4.C.Co.B.4: Data flow diagrams are in place and
document information flow to external parties.

D5.ER.Is.E.1: Criteria have been established for
escalating cyber incidents or vulnerabilities to the board
and senior management based on the potential impact
and criticality of the risk.
D1.RM.RMP.A.4: A process is in place to analyze the
financial impact cyber incidents have on the institution’s
capital.
DE.AE-5: Incident alert thresholds are established (p.
30)

D5.DR.De.B.1: Alert parameters are set for detecting
information security incidents that prompt mitigating
actions.
D3.DC.An.E.4: Thresholds have been established to
determine activity within audit logs that would warrant
management response.
D3.DC.An.Int.3: Tools actively monitor security logs for
anomalous behavior and alert within established
parameters.

DE.CM-1: The network is monitored to detect potential
cybersecurity events (p. 30)

D3.DC.An.B.1: Customer transactions generating
anomalous activity alerts are monitored and reviewed.
D3.DC.An.B.3: Logs of physical and/or logical access are
reviewed following events.

DE.CM-2: The physical environment is monitored to
detect potential cybersecurity events (p. 30)

D3.PC.Am.E.4: Physical access to high risk or
confidential systems is restricted, logged, and
unauthorized access is blocked.
D3.Dc.Ev.B.5: The physical environment is monitored to
detect potential unauthorized access.

June 2015

DRAFT

15

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

DE.CM-3: Personnel activity is monitored to detect
potential cybersecurity events (p. 31)

D3.DC.An.A.3: A system is in place to monitor and
analyze employee behavior (network use patterns, work
hours, and known devices) to alert on anomalous
activities.

DE.CM-4: Malicious code is detected (p. 31)

D3.DC.Th.B.2: Anti-virus and anti-malware tools are used
to detect attacks.

DE.CM-5: Unauthorized mobile code is detected (p.
31)

D3.DC.Th.E.5: Anti-virus and anti-malware tools deployed
on end-point devices (e.g., workstations, laptops, and
mobile devices).

DE.CM-6: External service provider activity is
monitored to detect potential cybersecurity events (p.
31)

D4.RM.Om.Int.1: Third-party employee access to the
institution's confidential data is tracked actively based on
the principles of least privilege.

DE.CM-7: Monitoring for unauthorized personnel,
connections, devices and software is performed (p. 31)

D3.DC.Ev.B.3: Processes are in place to monitor for the
presence of unauthorized users devices, connections, and
software.

DE.CM-8: Vulnerability scans are performed (p. 31)

D3.DC.Th.E.5: Vulnerability scanning is conducted and
analyzed before deployment/redeployment of new/existing
devices.

DE.DP-1: Roles and responsibilities for detection are
well defined to ensure accountability (p. 31)

D3.DC.Ev.B.4: Responsibilities for monitoring and
reporting suspicious systems activity have been assigned.

DE.DP-2: Detection activities comply with all
applicable requirements (p. 32)

D1.G.Ov.E.2: Management is responsible for ensuring
compliance with legal and regulatory requirements related
to cybersecurity.

DE.DP-3: Detection processes are tested (p. 32)

D3.DC.Ev.A.2: Event detection processes are proven
reliable.

DE.DP-4: Event detection information is
communicated to appropriate parties (p. 32)

D3.DC.Ev.B.2: Mechanisms (e.g., anti-virus alerts, log
event alerts) are in place to alert management to potential
attacks.
D5.ER.Is.B.1: A process exists to contact personnel that
are responsible for analyzing and responding to an
incident.
D5.ER.Is.E.1: Criteria have been established for
escalating cyber incidents or vulnerabilities to the board
and senior management based on the potential impact
and criticality of the risk.

DE.DP-5: Detection processes are continuously
improved (p. 32)

D5.IR.Pl.Int.3: Lessons learned from real-life cyber
incidents and attacks on the institution and other
institutions are used to improve the institution’s risk
mitigation capabilities and response plan.

RS.PL-1: Response plan is executed during or after
an event (p. 33)

D5.IR.Pl.B.1: The institution has documented how it will
react and respond to cyber incidents.

RS.CO-1: Personnel know their roles and order of
operations when a response is needed (p. 33)

D5.IR.Pl.B.3: Roles and responsibilities for incident
response team members are defined.

June 2015

DRAFT

16

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

RS.CO-2: Events are reported consistent with
established criteria (p. 33)

D5.IR.Pl.B.2: Communication channels exist to provide
employees a means for reporting information security
events in a timely manner.
D5.DR.Re.B.4: Incidents are classified, logged and
tracked.
D5.DR.Re.E.6: Records are generated to support incident
investigation and mitigation.
D5.DR.De.Int.3: Incidents are detected in real time
through automated processes that include instant alerts to
appropriate personnel who can respond.

RS.CO-3: Information is shared consistent with
established criteria (p. 33)

D5.ER.Is.B.2: Procedures exist to notify customers,
regulators, and law enforcement as required or necessary
when the institution becomes aware of an incident
involving the unauthorized access to or use of sensitive
customer information.

RS.CO-4: Coordination with stakeholders occurs
consistent with response plans (p. 33)

D5.ER.Is.B.1: A process exists to contact personnel that
are responsible for analyzing and responding to an
incident.
D5.IR.Pl.Int.1: A strategy is in place to coordinate and
communicate with internal and external stakeholders
during or following a cyber attack.

RS.CO-5: Voluntary information sharing occurs with
external stakeholders to achieve broader cybersecurity
situational awareness (p. 33)

D2.IS.Is.B.3: Information about threats is shared with law
enforcement and regulators when required or prompted.

RS.AN-1: Notifications from the detection system are
investigated (p. 33)

D5.DR.De.B.3: Tools and processes are in place to
detect, alert, and trigger the incident response program.

D2.IS.Is.E.2: A representative from the institution
participates in law enforcement or information sharing
institution meetings.

D5.DR.De.Int.3: Incidents are detected in real time
through automated processes that include instant alerts to
appropriate personnel who can respond.
RS.AN-2: The impact of the incident is understood (p.
34)

D1.RM.RMP.A.4: A process is in place to analyze the
financial impact cyber incidents have on the institution’s
capital.
D5.IR.Te.E.1: Recovery scenarios include plans to
recover from data destruction, impacts to data integrity,
data loss, impacts to system and data availability.
D5.ER.Is.E.1: Criteria have been established for
escalating cyber incidents or vulnerabilities to the board
and senior management based on the potential impact
and criticality of the risk.

RS.AN-3: Forensics are performed (p. 34)

D3.CC.Re.Int.3: Security investigations, forensic analysis,
and remediation are performed by qualified staff or third
parties.
D3.CC.Re.Int.4: Generally accepted and appropriate
forensic procedures, including chain of custody, are
utilized to gather and present evidence to support
potential legal action

June 2015

DRAFT

17

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

RS.AN-4: Incidents are categorized consistent with
response plans (p. 34)

D5.DR.Re.B.4: Incidents are classified, logged and
tracked.
D5.DR.Re.E.1: The incident response plan is designed to
prioritize incidents, enabling a rapid response for
significant cybersecurity incidents or vulnerabilities.

RS.MI-1: Incidents are contained (p. 34)

D.5.DR.Re.B.1: Appropriate steps are taken to contain
and controls an incident to prevent further unauthorized
access to or use of customer information.
D5.DR.Re.E.4: Procedures include containment strategies
and notifying potentially-impacted third parties.
D5.DR.Re.E.2: A process is in place to help contain the
incidents and restore operations with minimal service
disruption.
D5.DR.Re.E.3: Containment and mitigation strategies are
developed for multiple incident types (e.g., DDoS,
malware).

RS.MI-2: Incidents are mitigated (p. 34)

D5.DR.De.B.1: Alert parameters are set for detecting
information security incidents that prompt mitigating
actions.
D5.DR.Re.E.3: Containment and mitigation strategies are
developed for multiple incident types (e.g., DDoS,
malware).
D3.PC.Im.E.4: A risk-based solution is in place at the
institution or Internet hosting provider to mitigate disruptive
cyber attacks (e.g., DDoS attacks).

RS.MI-3: Newly identified vulnerabilities are
documented as accepted risks (p. 34)

D1.RM.RA.E.1: Risk assessments are used to identify the
cybersecurity risks stemming from new products, services,
or relationships.

RS.IM-1: Response plans incorporate lessons learned
(p. 34)

D5.IR.Pl.Int.4: Lessons learned from real-life cyber-risk
incidents and attacks on the institution or other institutions
are used to improve the institution’s risk mitigations
capabilities and response plan.

RS.IM-2: Response strategies are updated (p. 34)

D5.IR.Pl.Int.4: Lessons learned from real-life cyber-risk
incidents and attacks on the institution or other institutions
are used to improve the institution’s risk mitigations
capabilities and response plan.
D5.IR.Te.Int.5: The results of cyber event exercises are
used to improve the incident response plan and
automated triggers.

RC.RP-1: Recovery plan is executed during or after an
event (p. 34)

D5.IR.Pl.B.6: The institution plans to use business
continuity, disaster recovery, and data back-up programs
to recover operations following an incident.

RC.IM-1: Recovery plans incorporate lessons learned
(p. 35)

D5.IR.Pl.Int.4: Lessons learned from real-life cyber-risk
incidents and attacks on the institution or other institutions
are used to improve institution’s risk mitigations
capabilities and response plan.

June 2015

DRAFT

18

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

NIST Cybersecurity Framework

FFIEC Cybersecurity Assessment Tool

RC.IM-2: Recovery strategies are updated (p. 35)

D5.IR.Pl.Int.4: Lessons learned from real-life cyber-risk
incidents and attacks on the institution or other institutions
are used to improve institution’s risk mitigations
capabilities and response plan.
D5.IR.Te.Int.5: The results of cyber event exercises are
used to improve the incident response plan and
automated triggers.

RC.CO-1: Public Relations are managed (p. 35)

D5.ER.Is.Int.3: An external communication plan is used
for notifying media regarding incidents when applicable.

RC.CO-2: Reputation after an event is repaired (p. 35)

D5.IR.Pl.Int.1: A strategy is in place to coordinate and
communicate with internal and external stakeholders
during or following a cyber attack.

RC.CO-3: Recovery activities are communicated to
internal stakeholders and executive and management
teams (p. 35)

D5.ER.Is.B.1: A process exists to contact personnel that
are responsible for analyzing and responding to an
incident.
D5.IR.Pl.Int.1: A strategy is in place to coordinate and
communicate with internal and external stakeholders
during or following a cyber attack.

June 2015

DRAFT

19

FFIEC Cybersecurity Assessment Tool

Mapping to NIST Cybersecurity Framework

Explanation of Cybersecurity Assessment Tool References
To reference the Cybersecurity Assessment Tool declarative statements, each has a unique
identifier that is comprised of the Domain, Assessment Factor, Component, Maturity Level, and
statement number. Each portion is separated by a period.
The following table provides the codes used in the above references for the Cybersecurity
Assessment Tool. For example, “D1.G.Ov.B.1” refers to Domain: 1, Assessment Factor:
Governance, Component: Oversight, Maturity Level: Baseline, and statement 1.
Domain
Domain 1: Cyber Risk
Management &
Oversight (D1)

Assessment Factor
Governance (G)

Component
Oversight (Ov)
Strategy/Policies (SP)
IT Asset Management (IT)

Risk Management (RM)

Risk Management Program (RMP)

Maturity Level
Baseline (B)
Evolving (E)
Intermediate (Int)
Advanced (A)
Innovative (Inn)

Risk Assessment (RA)
Audit (Au)
Resources (R)

Staffing (St)

Training and Culture (TC)

Training (Tr)
Culture (Cu)

Domain 2: Threat
Intelligence and
Collaboration (D2)

Domain 3: Cybersecurity
Controls (D3)

Threat Intelligence (TI)

Threat Intelligence and Information
(Ti)

Monitoring and Analyzing
(MA)

Monitoring and Analyzing (Ma)

Information Sharing (IS)

Informational Sharing (Is)

Preventative Controls (PC)

Infrastructure Management (Im)
Access and Data Management
(Am)
Device/End-Point Security (De)
Secure Coding (Se)

Detective Controls (DC)

Threat and Vulnerability Detection
(Th)
Anomalous Activity (An)
Event Detection (Ev)

Corrective Controls (CC)

Patch Management (Pa)
Remediation (Re)

Domain 4: External
Dependency
Management (D4)

Connections (C)

Connections (Co)

Relationship Management
(RM)

Due Diligence (Dd)
Contracts (Co)
Ongoing Monitoring (Om)

Domain 5: Cyber Incident
Management and
Resilience (D5)

June 2015

Incident Resilience Planning
and Strategy (IR)

Planning (Pl)

Detection, Response and
Mitigation (DR)

Detection (De)

Escalation and Reporting
(ER)

Escalation and Reporting (Re)

Testing (Te)
Response and Mitigation (Re)

DRAFT

20


File Typeapplication/pdf
AuthorKopchik, Jeff
File Modified2015-06-16
File Created2015-06-16

© 2024 OMB.report | Privacy Policy