Threats have moved from stealing card numbers and online banking information to more lucrative attacks on networks, increasing risk to not only to ATM machines, but also to electronic payment networks.
Case in point, the attack at Bangladesh’s central bank that controlled access to the SWIFT messaging system was one of the biggest digital heists on record. And more recently, a hacking spree affected European ATMs remotely accessing NCR machines in more than a dozen countries, forcing them to spit out cash.
Risk is nothing new to the banking industry. The risk of loss from failed internal processes, controls, people, systems or external events has attracted a lot of attention over the years. This is mainly because operational risk incorporates many of the major issues facing the sector today, including systems, cybersecurity, infrastructure, organizational issues, regulatory compliance and data breaches. We’ve recently seen billions of dollars in fines being issued to banks all over the world for poor compliance and oversight of practices.
In a recent interview, Federal Reserve Governor Daniel Tarullo said, “banks only respond when there is a particular problem. They need to change. They really need to be much more proactive.” Operational risk remains a constant give-and-take between run-the-business initiatives and change-the-business initiatives, all while maintaining compliance to avoid being hit over the head with more fees.
Global legislatures are putting further pressure on banks to digitize. Most recently, the U.K.’s Competition and Markets Authority (CMA) ruling and SWIFT’s enforcement that banks must comply puts the onus on institutions to get their systems updated or risk getting fined. In addition, the Basel Banking Committee recently signalled an overhaul of the way banks should calculate their operational risk, requiring them to use a standardized approach laid out by regulators incentivizing them to improve IT risk management.
However, despite tightening regulations, there are still major technological challenges that legislators fail to address. Technology risk is obviously a big part of operational risk; yet, this is less understood by regulatory entities. And, when you get down to system risks, the most poorly understood is certainly the software layer. Today, software risk is one of the major sources of profit loss and security exposure for banks. Software is also the backbone to any payment system. If you have bad software, you’re going to incur a lot of risk.
The latest Financial Services CRASH Report from CAST reveals the Financial Services sector is delivering software ‘at the highest risk’ of failure. The study, which analyzed 241 million lines of code across 430 applications submitted by over 53 global financial institutions, exposed the overall quality of banks’ mission critical functions is poor. Institutions are operating business critical systems filled with dangerous flaws.
Shareholders and regulators have been so focused on operational considerations that they have largely failed to understand and ascertain whether the IT infrastructure and software quality of banking systems are actually capable of supporting the pace of financial innovation. There needs to be a much higher degree of technical excellence and software engineering to underpin our financial system.
A global, standardized approach, such as those provided by the Consortium of IT Software Quality (CISQ) should be the first line of defence for banks to assess the level of software risk they must report. Using CISQ, banks are able to report compliance using a standards-based method. In addition, CISQ measures more vulnerabilities and weaknesses than other compliance frameworks, such as those focused on PCI compliance.
Both legacy and new banks will need to ensure checks and balances, including system-level software analysis. For legacy financial institutions focused on ‘keeping the lights on,’ modernization efforts can be quite costly and time-intensive. Newly established banks, which can come up and running very quickly using modern technologies and API-driven development over the cloud, will still need to prove that applications are robust, secure and scalable. Of course, they don’t carry the cost and complexity of legacy systems. However, as they are delivering more discrete services, the same regulatory and operational hurdles will apply.
As part of their business operating model, new banks are adopting an approach where they buy specific services rather than build everything themselves – hence, in parallel, the rise of offerings by ‘fintech’ and ‘regtech’ providers. Big banks, who are effectively software and technology companies, need to run a robust infrastructure. Largely owned in house, the complexity is now accounting for significant operating budget and restricting change. The new ‘challenger’ approach is one where organizations don’t own their own technology. This presents new obstacles for IT sourcing and managing vendor quality while keeping systems cohesive. Whichever approach is taken, both big and small banks need to know their software is safe and secure. CISQ standards can help with this as well.
Successful institutions have to delicately balance regulatory requirements with their technical capacities, while pursuing the maximum set of capabilities. By analyzing their software using the most advanced standards at the system-level, banks will better measure and manage operational risks for their complex technology infrastructures. Those who can master this process will be the ultimate winners. This is the real challenge for today’s banks.