Risk and Crisis Management Explored at Cyber Event

NEW YORK—Cyberattacks and data security need to be high priorities for all businesses, experts stressed at ALM’s cyberSecure 2017 event here, Dec. 4 and 5. In fact, not only is failing to prepare for an attack or breach risky, it’s foolish, Kathleen McGee, internet & technology bureau chief for the Office of the Attorney General of the State of New York said in Monday’s opening address. She added that not reporting a breach in a timely fashion has its own set of legal and reputational risks, referring to the SHIELD Act (the Stop Hacks and Improve Electronic Data Security Act), introduced to New York State legislature by Attorney General Eric Schneiderman in November.

“Under the SHIELD Act, companies would have a legal responsibility to adopt reasonable, administrative, physical and technical safeguards for sensitive data,” she said Monday, adding that the standards would apply to any business holding data of New Yorkers, whether or not they do business in the state.

McGee noted that even though a company may not have all the details in the first 72 hours following a breach, reporting it to the New York Department of Financial Services (NYDFS) or another regulator is crucial. It is a legal requirement as part of the NYDFS Cybersecurity Requirements for Financial Services Companies, and even if all the pertinent information about an attack is not yet available, divulging what is known will prevent further enforcement action from the state.

“For some companies, data is the only commodity,” she said. “But in the past 10 years, risk assessments have not evolved as quickly as data collection.”

That observation lent itself to a segue for the next session, “Integrating Periodic Risk Assessment to Avoid Becoming the Next Target of a High-Profile Cyberattack.” Panelists covered the importance of formal risk assessments, which will be legally required by regulators like the NYDFS and the General Data Protection Regulation (GDPR) in Europe and goes into effect in 2018.

Moderator Eric Hodge, director of consulting at CyberScout, said education charts the path to a positive assessment and suggested using non-traditional training methods to onboard clients and employees over the course of a year.

“There are a lot of ways to educate other than the traditional annual training session set in a typical conference room,” Hodge said. “You can try white hat phishing to trap people in a safe way. Share your stories every month and be honest about your own failures. There are ways beyond just checking a box.”

eHarmony Vice President and General Counsel Ronald Sarian said his company has learned from its past incidents to better prepare and to update its ERM framework. The dating and compatibility company’s site was breached in 2012, before he joined the group.

“You need to do a data impact assessment and ask: What are your family jewels?” noted Sarian, who has implemented ISO27001 as the ERM framework to secure eHarmony’s international and cyber presence. “We had so much in place already that I thought we should take a shot at it. It takes at least a year but so far it’s working for us.”

When considering ransomware, experts from healthcare, insurance and electronic payments companies spoke passionately during a dedicated session about how they mitigate risks. Christopher Frenz, director of infrastructure at the Interfaith Medical Center strongly advocated for network segmentation, which he uses at the center, in an effort to keep intrusions contained.

As previously reported, Advisen’s recent Information Security and Cyber Risk Management Survey indicated that, for the first time in the seven years of the survey, there has been a decline in how seriously C-Suite executives view cyberrisk. With that trend in mind, panelist Christopher Pierson, PhD, chief security officer & general counsel of ViewPost, a provider of electronic invoice and payment services to businesses, outlined his approach to eliciting a response from board members.

“You can’t tell the board that [paying] is not an option, unless it’s illegal,” Pierson said. “Educate the board and explain that it is an option to pay terrorists and criminal syndicates. You’ll see the looks on their faces and then you’ll get them [to want to take action].”

2017 Storms Break Records

The 2017 hurricane season is finally behind us, but it left its mark with two Category 5 hurricanes and one Category 4 striking within weeks of each other, causing an estimated $300 billion in damage. In fact, 2017 broke records, including the strongest storm—Irma—and the longest-lasting storm, which was Hurricane Harvey. Other natural disasters in 2017 also did their share of damage, including hailstorms and 1,496 tornadoes compared to an average of 1,202.

Then there were the wildfires, which burned more than 9 million acres of land.

Highlights of 2017 are summarized below by Interstate:

Santa’s Impact on Business and Finance

Just as Santa Claus brings gifts down chimneys, his name alone also carries the stigma of risks that transcend all industries. Indeed, thanks to the logistics of his job we better understand the risks of reindeer-led aviation. But perhaps more importantly, Kris Kringle’s presence has long influenced finance and business.

Mentioning him on Wall Street this year may trigger an underlying wealth management risk. The annual “Santa Claus Rally” marks an uptick in the stock market and a 1.4% average return of the S&P 500 index from the last five trading days of the year through the first two of January. This phenomenon can be attributable to people spending and investing a bit extra – possibly from holiday bonuses – leading to a generally happy mood on and off trading room floors.

Since 1950, the market has declined only 15 times during the Santa Claus Rally period. But due to the uncertainty surrounding the tax reform plan making its way through Congress, that 1-in-4.4 chance of downturn is on the minds of cynical investors. As reported recently by Investopedia, “Some bears think that, if Congress fails to make appreciable progress on tax reform before their holiday recess, Scrooge or Krampus will elbow Santa aside, and send the markets downward at year-end.”

And similar to the way Punxatawney Phil seeing his shadow on Groundhog Day can predict six more weeks of winter, Santa skipping stock exchanges’ chimneys may indicate a frosty new year. According to The Stock Trader’s Almanac, some of the more recent holiday seasons without a rally included the last two, as well as in late 2007 and early 2008 leading up to the financial crisis, and just before the dotcom bubble burst in the 1999-2000 holiday period.

Santa’s influence isn’t just relegated to stock speculation and short-term investments, however. Some executives and employees may emulate his work ethic without realizing it. All eyes turn to him in good times and especially during the bad. He’s trying to meet year-end quotas while keeping a workforce happy and focused. Plus, Santa has the burden of trans-meridian travel with frequent stops over a 24-hour period, which is sure to cause jet lag. Sound familiar?

While one all-nighter might not have major long-term effects, regular ones could lead to shift work disorder, which has been linked to chronic diseases and illnesses. Anyone known to “Santa Claus it” too frequently may accumulate a large “sleep debt” over time. According to the Sleep Foundation, “if you work at night, you’re also going against your biological clock, which is naturally cueing you to become less alert and encouraging you to sleep during the nighttime hours.”

This can lead to seasonal “presenteeism,” an issue Risk Management magazine recently explored, detailing pain management in the workforce. Presenteeism occurs when a worker inhabits a space at their job, but “is unable to focus and perform as expected” and can be an even greater drag on productivity than absenteeism. The condition is indiscriminate – it can affect interns and CEOs – and may cause someone to “miss out not only on the income, but also the sense of meaning, purposefulness and belonging that can be gained from a job. Initial distress may lead to chronic anxiety and even depression.”

Identify these risks now, so that the mention of Santa Claus doesn’t put a humbug in your eggnog this holiday season.

What Organizations Need to Know about Risk Culture Audits

Today’s risks require more proactive oversight by boards of directors on the issue of risk management. Transitioning to this approach is easier said than done, however. The trouble is that many organizations are weighed down by antiquated risk management frameworks that prevent them from being proactive. Even today, how financial services and other industries address risk is deeply ingrained in organizations’ character, requiring a broader change which extends beyond simply implementing new risk management frameworks.

Overcoming this hurdle is easier said than done. In fact, businesses across the capital markets are prime for a risk culture rewiring.

What’s in a risk culture audit?
A risk culture audit is a critical first step in reinventing risk management because it helps identify challenges in behavior and reorients how companies think about today’s increasingly complex risk landscape.

Here are the key focus areas in any risk culture audit:

Organization Vision and Values: Evaluating leadership and established communications by senior leaders relative to risk and compliance.

Risk Management: Evaluating the maturity of risk frameworks, defining clear roles and responsibilities, and implementing education and training programs designed to empower individuals to include risk management in their decision-making consistently across the organization.

People Management: Understanding how risk management is introduced early in the onboarding process on the front end and back end, as well as directly into incentive compensation programs.

Risk culture audit lessons learned
I recently led OCC (Options Clearing Corporation) through one of these trailblazing exercises, leading me to my new mantra of “identify, escalate and debate.”

Rather than promote a reactive risk culture in which specific risk incidents derail teams from business-as-usual, we’re adopting a risk-focused culture that enables our teams to escalate an event immediately, assess its impact quickly, and debate its resolution broadly.

While every financial institution has unique considerations in its risk management framework, OCC’s risk culture audit revealed some key hurdles that are commonplace across financial services firms.

The first challenge is developing a risk management framework that boards and management can easily implement for risk oversight. This framework can be difficult to pin down because it must be formal, objective, and metrics-driven—and ultimately must map back to a risk appetite and process that team leaders can follow.

The second challenge is developing an action plan to help team leaders manage the shift toward a proactive risk culture. To effect change, team leaders need to be able to demonstrate that the new approach reduces risk or manages new risks within the firm’s risk appetite. Oftentimes, this means replacing human judgment with transparent rules and objective criteria.

Finally, the third challenge is shifting employees toward adopting a risk-based mindset at the individual level. A successfully retooled risk culture ultimately comes down to the people. Doing this successfully requires firms to reinforce the new risk culture at every turn, such as linking positive risk culture behaviors to performance rewards. At OCC, we are working on this third piece of the puzzle by identifying “risk champions” across the business and training them on the techniques needed to evaluate risk.

At the end of the day, financial institutions’ risk cultures must support risk management models that ensure market confidence does not erode, that issues are addressed, and that business continues as planned. I have concluded the best way for organizations to do this is to use a risk culture audit to identify opportunities that will help them transition to a strong risk-oriented business model. This enables them to comprehensively evaluate and understand the risk posed to their business, put mitigating controls in place, and enable an environment where risk can be discussed openly across the firm.

If companies can re-orient their risk culture to be more forward-thinking, they will put themselves in the best possible position to address today’s ever-evolving and complex risk environment.