Strengthening Cybersecurity for a Wealth Management Firm

A mid-sized wealth management firm engaged a third-party auditor to perform an ISO 27001 gap analysis to assess its current information security posture and identify areas requiring improvement. The analysis aimed to ensure compliance with ISO 27001:2022, GDPR, PCI DSS, and PSD2, while also enhancing the organization’s resilience against cyber threats. This case study outlines the findings of the gap analysis and presents the high-level recommendations provided to the firm, along with the subsequent steps the organization took to develop a remediation plan.

Scope of gap analysis

The main goals of the gap analysis were to:

1.      1. Assess the current cybersecurity controls against the requirements of ISO 27001:2022.

2.      2. Identify non-compliance and vulnerabilities in data security, application security, network security, access control, and endpoint security.

3.      3. Evaluate alignment with regulatory requirements, such as GDPR, PCI DSS, and PSD2.

4.      4. Provide high-level recommendations to address identified gaps and enable the organization to develop an effective remediation plan.

Evaluation against ISO 27001 Requirements

Data Security (Annex A.5, A.10, A.18)

·        Data encryption mechanisms did not meet the required standard (AES-128 was used instead of AES-256).

·        Legacy systems supported TLS 1.0, increasing the risk of data exposure.

·        Data masking was insufficient in non-production environments, exposing sensitive PII during testing phases.

·        Financial records were retained beyond the regulatory retention period, breaching GDPR requirements.

Application Security (Annex A.14)

·        Weak password policies and no multi-factor authentication (MFA) exposed customer accounts to credential-based attacks.

·        Secure code reviews revealed vulnerabilities such as SQL injection and XSS in critical applications.

·        20% of third-party libraries used in applications were outdated and had known vulnerabilities.

Network Security (Annex A.13)

·        Firewalls were misconfigured, with unnecessary open ports exposing internal systems.

·        No network segmentation existed between public-facing applications and critical systems.

·        Legacy intrusion detection systems (IDS) could not monitor encrypted traffic effectively.

Access Control (Annex A.9)

·        Administrative accounts were shared across teams, leading to weak accountability.

·        Employees had excessive access rights beyond their job roles.

·        Third-party vendors had unmonitored and unrestricted access to sensitive systems.

Endpoint and Mobile Security (Annex A.12)

·        Endpoint detection and response (EDR) solutions were not deployed, and 25% of endpoints were running outdated operating systems.

·        The mobile application lacked code obfuscation, making it vulnerable to reverse engineering and API misuse.

High-Level Recommendations from the Gap Analysis

Data Security

·        Upgrade encryption standards to AES-256 for data at rest and enforce TLS 1.2 or higher for all data in transit.

·        Implement data masking techniques in non-production environments to secure sensitive PII.

·        Develop and enforce data retention policies aligned with GDPR and other regulations.

Application Security

·        Enforce strong password policies and deploy MFA for customer-facing accounts and internal systems.

·        Conduct regular secure code reviews and fix vulnerabilities such as SQL injection and XSS.

·        Establish a process for regular updates to third-party libraries to eliminate known vulnerabilities.

Network Security

·        Audit and reconfigure firewalls to close unnecessary open ports and follow least privilege principles.

·        Segment public-facing applications from critical systems to reduce attack surfaces.

·        Upgrade intrusion detection systems to modern tools capable of monitoring encrypted traffic.

Access Control

·        Replace shared accounts with individual credentials and enforce role-based access controls.

·        Deploy Privileged Access Management (PAM) tools to enforce least privilege and monitor administrative access.

·        Monitor and restrict third-party vendor access to sensitive systems.

Endpoint and Mobile Security

·        Deploy EDR solutions to monitor endpoints and detect malicious activity.

·        Establish an automated patch management process to ensure all systems remain up to date.

·        Implement code obfuscation techniques and secure API configurations to protect the mobile application.

Next Steps for Remediation

The organization’s internal information security team, in collaboration with external consultants, used the gap analysis report to develop a detailed remediation plan. This plan included:

5.      1. Prioritizing Risks: Addressing high-risk gaps, such as encryption weaknesses and access control issues, first.

6.      2. Phased Implementation: Dividing remediation activities into short-term, medium-term, and long-term actions to manage resources effectively.

7.      3. Alignment with ISO 27001: Mapping all remediation efforts to specific ISO 27001 clauses and controls to ensure compliance.

8.      4. Developing Governance Frameworks: Establishing policies and procedures for ongoing risk management, monitoring, and continuous improvement.

Outcome of the Gap Analysis

By acting on the recommendations from the gap analysis, the wealth management firm achieved the following improvements:

·        Enhanced Data Security: All sensitive data is now encrypted using AES-256, and data retention policies align with GDPR requirements.

·        Improved Application Security: Deployment of MFA and secure coding practices reduced vulnerabilities in customer-facing applications.

·        Stronger Network Defenses: Reconfigured firewalls and network segmentation reduced the risk of unauthorized access.

·        Streamlined Access Control: PAM tools and role-based access controls improved accountability and minimized the risk of privilege abuse.

·        Robust Endpoint Protection: Automated patch management and EDR solutions ensured endpoint security in a hybrid work environment.

·        Regulatory Compliance: The organization is now aligned with ISO 27001, GDPR, PCI DSS, and PSD2.

Disclaimer: The content of this article is for general informational purposes and educational purpose only. The case study and recommendations are hypothetical and intended to illustrate best practices in cybersecurity assessments. The views expressed in this article are my own and do not reflect the views of my employer or any affiliated organization. Readers are advised to seek professional advice tailored to their specific needs before implementing any recommendations.