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Compliance with NYDFS MFA regulations can be a daunting task, but it doesn't have to be overwhelming.
The NYDFS MFA regulation requires that financial institutions implement multi-factor authentication for all employees and third-party vendors with access to non-public information.
This means that financial institutions must ensure that all users, including employees and vendors, have access to the necessary MFA tools and technologies.
Implementing MFA requires a thorough risk assessment to identify vulnerabilities and develop a comprehensive security plan.
What Is the Regulation?
The NYDFS Cybersecurity Regulation is a set of legal obligations for certain companies operating in New York. It aims to counter the large-scale increase in cyberthreats to financial firms in the state.
The regulation requires firms to have a risk-assessed cybersecurity program to protect the confidentiality and integrity of their information systems. This includes implementing a cybersecurity policy covering data governance, access controls, and customer data privacy.
The regulation also requires firms to have a designated chief information security officer (CISO) and to limit user access privileges to nonpublic information. Effective controls, including multi-factor authentication (MFA), are also necessary to protect nonpublic information when the network is being accessed externally.
Here are some key features of the NYDFS Cybersecurity Regulation:
- Regulated entities must have a risk-assessed cybersecurity program.
- Companies must implement a cybersecurity policy covering data governance, access controls, and customer data privacy.
- Firms must have a designated chief information security officer (CISO).
- User access privileges to nonpublic information must be limited.
- Effective controls, including MFA, should protect nonpublic information.
- Notices of cybersecurity events must be made to the NYDFS superintendent within 72 hours.
Amended Regulation
The NYDFS Cybersecurity Regulation has undergone changes, specifically on November 1, 2023, when DFS announced amendments to Cybersecurity Regulation, 23 NYCRR Part 500.
These amendments were a response to concerns about the effectiveness of multi-factor authentication (MFA) implementations. The NYDFS released an industry letter in December 2021, highlighting the importance of MFA in preventing cyber incidents.
The NYDFS noted that too many cyber incidents occur due to improper or easily circumvented MFA implementations. This is why they emphasized the need for effective MFA implementation.
The NYDFS lists some of the most common issues that prevent effective MFA implementation, but these specific issues are not mentioned in the provided article section facts.
Regulation
The NYDFS Cybersecurity Regulation is a set of legal obligations for financial services companies operating in New York.
This regulation was developed by the New York Department of Financial Services (NYDFS) to curb the threats posed to information and financial systems by malicious actors and terrorist organizations.
The regulation came into effect on March 1, 2017, and has been fully in force since early 2019. It requires regulated entities to have a risk-assessed cybersecurity program to protect the confidentiality and integrity of their information systems.
Regulated entities must implement a cybersecurity policy covering data governance, access controls, and customer data privacy, among other features.
The regulation also calls for stricter procedures, including the requirement for a designated chief information security officer (CISO) and effective controls, including multi-factor authentication (MFA).
Here are some key features of the regulation:
- Regulated entities must have a risk-assessed cybersecurity program to protect the confidentiality and integrity of their information systems.
- Companies must implement a cybersecurity policy covering data governance, access controls, and customer data privacy, among other features.
- Firms must have a designated chief information security officer (CISO).
- Effective controls, including multi-factor authentication (MFA), should protect nonpublic information.
- Notices of cybersecurity events must be made to the NYDFS superintendent within 72 hours.
Non-compliance with the regulation has already resulted in multimillion dollar fines for businesses, highlighting the importance of adhering to these requirements.
Regulation Requirements
The NYDFS Cybersecurity Regulation requires financial services companies to have a risk-assessed cybersecurity program to protect the confidentiality and integrity of their information systems.
Regulated entities must implement a cybersecurity policy covering data governance, access controls, and customer data privacy. This policy should be comprehensive and cover all aspects of data protection.
Companies must have a designated chief information security officer (CISO) to oversee the implementation and maintenance of the cybersecurity program. The CISO is responsible for ensuring that the company's cybersecurity measures are adequate and effective.
The NYDFS Cybersecurity Regulation requires that user access privileges to nonpublic information be limited. This means that only authorized personnel should have access to sensitive data, and access should be granted on a need-to-know basis.
Effective controls, including multi-factor authentication (MFA), should protect nonpublic information. This measure becomes an obligation when the network is being accessed externally.
Here are some key requirements of the NYDFS Cybersecurity Regulation:
- Regulated entities must have a risk-assessed cybersecurity program.
- Companies must implement a cybersecurity policy covering data governance, access controls, and customer data privacy.
- Firms must have a designated chief information security officer (CISO).
- User access privileges to nonpublic information must be limited.
- Effective controls, including MFA, should protect nonpublic information.
- Notices of cybersecurity events must be made to the NYDFS superintendent within 72 hours.
Implement Multi-Factor Authentication
Implementing multi-factor authentication (MFA) is a crucial step in securing sensitive data. MFA adds a layer of security to prevent unauthorized users from tampering or stealing sensitive data.
As a covered entity, you're required to implement MFA in all information systems. This includes remote access to in-house information systems, third-party applications, and all privileged accounts.
MFA requires users to provide two or more authentication factors to gain access to a resource. This can include something you know (like a password), something you have (like a smart card), or something you are (like a fingerprint).
According to the NYCRR Part 500 regulation, MFA should be utilized for any individual accessing any information systems of a covered entity. Here are the specific requirements:
- Remote Access: MFA should be utilized for any remote access to the covered entity’s information systems.
- Third-Party Applications: MFA should be utilized for remote access to third-party applications, including but not limited to those that are cloud-based, from which nonpublic information is accessible.
- Privileged Accounts: MFA should be utilized for all privileged accounts other than service accounts that prohibit interactive login.
By implementing MFA, you can protect against compromised credentials and provide an additional layer of security for your sensitive data.
Security Measures
Implementing a robust security policy is crucial to protect sensitive information. MedData's $7 million settlement for exposing patient data to a public server is a harsh reminder of the importance of third-party service provider security.
To mitigate these risks, NYDFS requires entities to implement a third-party service provider security policy. This policy should include a risk assessment of third-party service providers, baseline security practices that third parties should meet, and due diligence processes to evaluate existing security practices.
The policy should also include periodic assessment of risks posed by third-party service providers and guidelines for due diligence, such as access control procedures, use of MFA, encryption implementation, and incident notification.
Implementing comprehensive Multi-Factor Authentication (MFA) is also a key requirement to protect against identity attacks. This is a direct response to the alarming rise in the use of compromised credentials for malicious access.
To address this issue, entities should adopt best practices in monitoring, detection, and response to cyber threats, and implement robust identity and access management to maintain a strong cybersecurity posture.
Third-Party Service Provider Security Policy
Developing a third-party service provider security policy is crucial to protect sensitive information. NYDFS requires entities to implement such a policy to safeguard information accessed by third parties.
A risk assessment of third-party service providers is essential to identify potential vulnerabilities. This should be done regularly to ensure the security posture of third parties is up to par.
A baseline security practice that third parties should meet is to implement multi-factor authentication (MFA). This is a requirement to prevent unauthorized access to nonpublic information.
Due diligence processes should be in place to evaluate the existing security practices of third parties. This includes guidelines for access control procedures, encryption implementation, and incident notification.
Here are the key components of a third-party service provider security policy:
- Risk assessment of third-party service providers
- Baseline security practices that third parties should meet
- Due diligence processes to evaluate the existing security practices of third parties
- Periodic assessment of risks posed by third-party service providers
- Guidelines for due diligence, such as access control procedures, use of MFA, encryption implementation, and incident notification
MedData's lawsuit in 2021, which resulted in a $7 million settlement, is a stark reminder of the importance of evaluating the risks of third-party service providers.
Identity Protection
Identity Protection is a critical component of any robust cybersecurity strategy. The alarming rise in the use of compromised credentials for malicious access has made identity protection a top priority.
Cybercriminals exploit weak or stolen credentials to gain unauthorized access to systems, highlighting the need for robust identity and access management. This is a direct response to the growing importance of identity protection.
Multi-Factor Authentication (MFA) is mandated by the amended Part 500 to protect against unauthorized access. MFA adds an extra layer of security to the login process, making it much harder for cybercriminals to gain access.
Best practices in monitoring, detection, and response to cyber threats are also required by the amended Part 500. This includes implementing measures to quickly identify and respond to potential security breaches.
The protection of privileged accounts is also a key requirement of the amended Part 500. This is because privileged accounts often have elevated access to sensitive systems and data, making them a prime target for cybercriminals.
Regulation Requirements
The NYDFS Cybersecurity Regulation requires regulated entities to have a risk-assessed cybersecurity program to protect the confidentiality and integrity of their information systems.
Regulated entities must implement a cybersecurity policy covering data governance, access controls, and customer data privacy, among other features.
A designated chief information security officer (CISO) is also required.
The regulation focuses on protecting nonpublic information, which includes all electronic information that is not publicly available, could be used to identify someone, or has been derived from a healthcare provider.
User access privileges to nonpublic information must be limited.
Effective controls, including multi-factor authentication (MFA), should protect nonpublic information, especially when the network is being accessed externally.
Notices of cybersecurity events must be made to the NYDFS superintendent within 72 hours.
Here are some of the key requirements of the NYDFS Cybersecurity Regulation:
The NYDFS also emphasizes the importance of multi-factor authentication, stating that it is an essential part of cybersecurity hygiene and should be implemented properly to prevent cyber incidents.
Challenges and Solutions
Implementing NYDFS MFA compliance can be a daunting task, especially when dealing with legacy systems that may not be compatible with modern security protocols.
Legacy systems can be a significant challenge, as they often require custom integrations and may not have the necessary APIs to support multi-factor authentication.
Resource constraints, such as limited budget and personnel, can also hinder a company's ability to implement NYDFS MFA requirements effectively. This can lead to a prolonged implementation process and increased costs in the long run.
Vendor limitations can also pose a challenge, as some vendors may not offer MFA solutions that meet the NYDFS requirements. This can force companies to seek out alternative vendors or invest in custom solutions.
Here are some of the key challenges in meeting NYDFS MFA requirements:
- Legacy Systems:
- Resource Constraints:
- Business Disruptions:
- Vendor Limitations:
These challenges can be overcome by carefully planning and executing an MFA implementation strategy that takes into account the specific needs and constraints of the organization.
Meeting Requirements Challenges
Meeting Requirements Challenges can be a daunting task, and it's essential to acknowledge the hurdles that companies face when trying to comply with NYDFS regulations.
Legacy systems can be a significant obstacle, as they may not be compatible with modern security measures.
Resource constraints, such as limited personnel and budget, can also hinder a company's ability to implement NYDFS MFA requirements.
Business disruptions can occur when implementing new security measures, potentially affecting day-to-day operations.
Vendor limitations can also pose a challenge, as some vendors may not offer MFA solutions that meet NYDFS requirements.
Here are the key challenges in meeting NYDFS MFA requirements:
- Legacy Systems
- Resource Constraints
- Business Disruptions
- Vendor Limitations
Weak Multi-Factor Authentication
Many types of MFA are already vulnerable to attacks, including SMS one-time passwords (OTPs) and push notifications.
According to the article, these types of MFA are easy to circumvent by attackers, making them a weak link in an organization's security posture.
The NYDFS Cybersecurity Regulation requires a risk-based assessment, which must consider the weaknesses of these types of MFA.
In fact, the regulation aims to provide an additional layer of security by requiring MFA for all privileged accounts, except for service accounts that prohibit interactive login.
This requirement is part of the regulation's effort to protect sensitive information and systems from cybercriminals.
Here are some examples of weak MFA methods:
- SMS one-time passwords (OTPs)
- Push notifications
These methods are not secure enough to protect against compromised credentials, as they can be easily exploited by attackers.
Frequently Asked Questions
What are the requirements for multi factor authentication?
To log in, multifactor authentication requires two or more steps, such as a code sent to your phone and a fingerprint scan. This additional step ensures only authorized users can access accounts.
Sources
- https://www.dfs.ny.gov/industry_guidance/cybersecurity
- https://sprinto.com/blog/nydfs-cybersecurity-regulation/
- https://rublon.com/blog/nydfs-23-nycrr-part-500-mfa-compliance/
- https://blog.hypr.com/the-nydfs-multi-factor-authentication-requirement
- https://www.datawiza.com/blog/industry/understanding-nydfs-23-nycrr-500-mfa-requirements-for-financial-services-compliance/
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