Implementation monitoring of the PFMI: Level 3 assessment on Financial Market Infrastructures' Cyber Resilience
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This CPMI-IOSCO report reviews the state of cyber resilience (as of February 2021) at a sample of 37 financial market infrastructures (FMIs) from 29 jurisdictions. The report finds a reasonably high adoption of the June 2016 CPMI-IOSCO Guidance on cyber resilience for financial market infrastructures by FMIs. However, it identifies one serious issue of concern relating to a small number of FMIs not fully meeting expectations regarding the development of cyber response and recovery plans to meet the two-hour recovery time objective (2hRTO).
The report also highlights four additional issues of concern among some of the assessed FMIs that relate to: (i) shortcomings in established response and recovery plans to meet the 2hRTO under extreme cyber-attack scenarios; (ii) a lack of cyber resilience testing after a significant system change; (iii) a lack of comprehensive scenario-based testing; and (iv) inadequate involvement of relevant stakeholders in testing of their responses.
Collectively, these findings highlight clear challenges for FMIs' cyber resilience that should be addressed with the highest priority.
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