Regulatory landscape
Now that we have seen the typical issues that can occur for red and blue teams, we will have a look at the regulatory landscape.
Even though regulators are often late in terms of adoption, we are seeing numerous initiatives that tackle some of the issues discussed in this chapter, and tend to drive organizations toward the purple teaming approach. In general, the financial industry's regulators are often leading the way. Here, we will briefly explore some of the regulatory frameworks that have been proposed and applied in recent years.
The G7 (previously the G8) has a special group working on cybercrime and has created several cyber policies for its member countries. The G-7 Fundamental Elements for Threat-led Penetration Testing (G7FE-TLPT) was created in 2016 to help organizations incorporate real-world scenarios into their risk management controls with penetration testing exercises.
The Bank of England has developed, for the CBEST members, the CBEST Intelligence-Led Testing. This was developed in 2016 to help organizations evaluate their cyber resilience by mimicking the actions of real threat actors.
In 2016, the Honk Kong Monetary Authority (HKMA) published its Cybersecurity Fortification Initiative, composed of three pillars. The first one, the Cyber Resilience Assessment Framework (C-RAF), describes several types of cyber assessment with one in particular, which is called Intelligence-led Cyber Attack Simulation Testing (iCAST). The framework extends the scope of traditional penetration testing engagements by including detection and response evaluation from a technological perspective, but also from a human and procedural perspective.
In 2018, the European Central Bank released the TIBER-EU framework, which describes how to implement the European framework for threat intelligence-based ethical red teaming. Similar to the CBEST framework from the Bank of England, it helps organizations to mimic attackers to evaluate the cyber resilience of people, process, and technology security controls.
The same year, the Global Financial Markets Association (GFMA) published A Framework for the Regulatory use of Penetration Testing in the Financial Services Industry. It highlights the need for a more collaborative approach with regard to penetration testing, and it promotes the integration of threat intelligence within the planning phase of the assessment. This framework is mainly intended for regulators, as they are increasingly requiring financial services to perform mandatory penetration tests.
Also in 2018, the Association of Banks in Singapore (ABS) published its guidelines, Red Team: Adversarial Attack Simulation Exercises. The paper helps organizations to develop, plan, and execute adversarial attack simulation exercises (referred to as AASE in the paper). This guideline also helps to differentiate cyber range, penetration testing, automated attack simulation, and advanced adversary attack simulation assessments.
Last but not least, the Saudi Arabian Monetary Authority (SAMA) developed the FEER framework – that is, the Financial Entities Ethical Red-Teaming framework.
All the mentioned frameworks are trying to solve issues around penetration testing. Specifically, all of them integrate some form of threat intelligence into penetration testing exercises in order to perform a more realistic assessment with regard to the current threats to organizations. In addition, they all highlight the need for debriefing discussions between all stakeholders at the end of the security assessment to maximize the post-mortem activities (lessons learned).
Finally, even though this last point is not relevant to everyone, the regulators act as a participant in the exercise, which allows them to benefit from real-world experience that will help them to understand their industry's threat landscape. Let's hope they will make good use of that experience and intelligence across their industry to provide applicable and prioritized actions and recommendations for organizations.
