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Navigating the Complexities of Global Compliance

Mainframe Security: The Undiscovered and Rediscovered Country

In today's global cybersecurity landscape, organizations—particularly those with international reach—face the arduous challenge of navigating the intricate web of cybersecurity compliance regulations that vary between organizations. 

What constitutes a compliance requirement in Canada is distinctly different from the stipulations in the United States, the European Union and other nations. Each jurisdiction establishes its own set of rules and standards, reflecting its unique legal frameworks and priorities regarding data protection and security.

Why Should You Care?

For organizations operating across borders, the priority is to develop a strong and adaptable cybersecurity architecture that not only meets the diverse requirements of each region but also does so cost-effectively and efficiently. 

 

This effort is often driven by the board of directors, who carry an overarching responsibility for the organization's well-being and the security of the services it provides to its global user base. 

 

For example, consider an international bank managing deposits for individuals across six different countries. This institution is accountable for adhering to the specific regulations governing financial deposits in each of those six distinct legal environments, as well as potentially navigating the complexities of international financial regulations.

 

Given this environment, the cybersecurity architecture must be designed to address the specific regulatory demands of each operating country, to:

 

Avoid penalties

Avoid penalties

This is commonly the most vital, as these financial penalties directly impact the organization's profitability.

Safeguard reputations

Safeguard reputations

Compliance failures or security breaches can decrease investor confidence, negatively affecting stock options and the overall value of the organization. 

Protect consumers

Protect consumers

Rules are designed to influence organizations across various industries to adhere to specific security standards to safeguard user data and ensure the integrity of services.

Adding to the complexity of international regulations is the increasing surge in cyberattacks. These threats are becoming more complex and originating from nation-states, hacktivist groups and even internal users, who pose a significant and growing risk either intentionally or unintentionally. These attacks often share a common goal—to steal sensitive information for financial gain or to disrupt services due to malicious intent. 
 
This startling reality sets the tone for the critical need for proactive and strong cybersecurity compliance measures. Over time, the financial burden of cyberattacks is projected to escalate dramatically, potentially reaching a point where cyber insurance may not be able to cover the costs. By the end of 2025, global expenses related to cyberattacks are forecasted to exceed a staggering $1 trillion annually—a monumental increase from the $3.5 billion figure just over two decades prior.
Global expenses related to cyberattacks

$3.5 billion

Two decades prior

$1 trillion

2025

CASE STUDY

International Financial Institution Seeks a Unified System to Deal With Regulatory Requirements

An international financial institution was grappling with the complexities of managing external audit requirements across six different countries. Each country operated in multiple time zones with potentially disparate external security management practices, so they reached out to Vanguard. 

 

This institution faced the challenge of providing on-time, instantaneous, on-demand reporting that satisfied the challenging regulatory demands. The main requirement was to develop a unified system that could address these needs and establish measurable baselines for reporting results at the board level. 

 

The board, in turn, had a responsibility to collaborate effectively with external auditors and remain aware of their specific requirements. The power of modern regulations, as shown by frameworks like NIST, PCI-DSS, HIPAA, GDPR, DORA, NYC500 and SOX, now carries significant weight, with substantial penalties for non-compliance. These regulations have teeth! For example:

 

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GDPR sets a maximum fine of €20 million (about $23.8 million) or 4% of annual global turnover—whichever is greater—for infringements. However, not all GDPR infringements lead to data protection fines.
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Digital Operational Resilience Act (DORA) imposes significant penalties for non-compliance within the European financial sector. 
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The New York State Department of Financial Services (DFS) 23 NYCRR Part 500 mandates the appointment of a Chief Information Security Officer (CISO) and requires annual cybersecurity risk assessments and penetration testing.
To effectively navigate this complex regulatory landscape and avoid potentially severe penalties, the international financial institution successfully implemented a structured methodology by establishing specific baselines that aligned with the unique requirements of each country in which it operated, as well as adhering to relevant industry regulations. This involved a union of state or country-specific regulations with broader industry standards.

THE SOLUTION

Vanguard Compliance Manager and Vanguard Aggregation and Delivery

To facilitate this process, the financial institution leveraged tools like Vanguard Compliance Manager (VCM) as a central baseline tool. VCM enabled them to measure the effectiveness of custom security checks tailored to the specific regulatory and industry requirements of each country. This comprehensive approach involve developing and implementing a significant number of checks, encompassing various security domains and supporting a wide range of compliance objectives.

 

With a proven architecture from VCM in place to measure adherence against predetermined baseline requirements with custom baseline checks, the organization could then generate clear and actionable results for their external security managers and the broader enterprise. 

 

The difference between the established baseline and the actual results—instances where the system did not meet the defined requirements—is also known as a "gap." Each gap required remediation and thorough documentation. This introduced another significant requirement: how to efficiently gather the results for each of the defined compliance checks without relying on manual, time-consuming human intervention.

 

To address this challenge, Vanguard developed a technology known as Vanguard Aggregation and Delivery (VAD). This technology served as a central "highway" for the automated delivery of baseline requirements and the aggregation of results for processing. VAD enabled the organization to gain an in-depth and real-time view of its compliance posture across its global operations.

A Comprehensive Cybersecurity Approach

Ultimately, managing global cybersecurity requirements boils down to effectively navigating global compliance. This creates a need for a fundamentally different perspective on the organization's enterprise and network. By embracing a comprehensive approach that leverages strong tools like Vanguard Compliance Manager and Vanguard Aggregation and Delivery, organizations can effectively navigate the complexities of global cybersecurity compliance, mitigate risks and safeguard their operations and reputation in an increasingly interconnected and threat-filled world.

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