The following article originally appeared in HFMWeek's Cyber Compliance Focus.
It’s not enough to have strong security policies. And it’s not enough to have robust technologies in place to ward off cyber threats. In truth, it’s not even enough to have both of these.
An effective cybersecurity program, rather, can only be achieved through a consistent and comprehensive strategy that touches layers across the entirety of the organization – from perimeter security and access control to policy enforcement and employee training. Without each of these building blocks, the effectiveness of a cyber risk management program is crippled at best.
And today’s standards for cybersecurity are increasing rapidly.
Traditionally, hedge funds and private equity firms have allocated significant capital budgets to build out their own sophisticated Communication (Comm.) Rooms, which can take months to provision and bring online. With servers to buy and install, software to license and configure, and voice/networks to deploy – not to mention recruiting, hiring, and managing expensive and hard-to-find IT talent – it’s no wonder cloud solutions have emerged as the dominant choice for computing infrastructures at investment firms large and small.
Not surprisingly, many investment management firms – including those with well-established in-house infrastructures – are making the move to the cloud for a number of compelling reasons, most notably these five:
Timing. Understanding when the right time to move to the cloud might be is a smart first step. There are three typical inflection points: when you’re adding new applications, moving or opening a new office, or in need of an IT refresh. But even if you’re not under any of those circumstances, there are a lot of motivating factors (keep reading).
Cost Containment. You may not always be able to reduce the cost of IT in the long-run with the cloud (depends on your firm’s size and scope), but you will have a predictable budget to work with, which means you can contain costs and create greater predictability and smoother, linear cash flows. As an added bonus, you can better allocate funds to other strategic projects and areas more directly relevant to the business mission. Even within the IT discipline, instead of spending time on mundane, daily operation of commodity IT resources, the firm can focus on proprietary application development, application integration, cyber security protections or other strategic initiatives.
When it comes to cybersecurity, the list of haves and have nots is constantly evolving due to the changing regulatory and threat landscape. In case you missed it, we hosted a webinar this week on Cybersecurity Basics for Asset Managers, during which we uncovered various elements within three primary cybersecurity layers: from Tier 0 (Basic Protection) to Tier 1 (Industry Standard) to Tier 2 (Advanced Protection).
How does your firm stack up when it comes to your cybersecurity practices? Watch the replay below and find out where you fit in.
Tier 0: We call this level Tier 0 in part because, well, there’s zero chance your firm will have long-term success in thwarting cyber risks if you don’t employ these basic security measures.
Hedge fund outsourcing is not a new trend, as buy-side firms have long dispersed the responsibility of many functions to third-party service providers more adept and accomplished at said functions. Technology, for example, is an area where many firms choose to leverage outsourced providers to manage complete or partial infrastructures, support projects or supplement on-site IT staffs. The benefits to outsourcing are numerous, but the true measure of a successful service provider relationship comes when an investment firm’s level of risk in using that provider is low.
Risks are everywhere, particularly in today’s cyber-focused environment. But the risk a hedge fund undertakes when outsourcing a function of its business to a third-party is enormous. Not only is the firm relinquishing control to an outside company, it also takes on the added burden of managing that company, in addition to its own.
It’s one thing to put faith in your service providers to do their jobs effectively. It’s another to ignore your own firm’s responsibility to manage that third party as a means of protecting your own firm. Successfully managing risk associated with third-party service provider relationships is a full-time job, especially for financial services firms working with dozens of various parties. Here are a few tips to help your firm properly manage third-party service provider risk:
As you probably recall, our 2016 Private Equity CTO Survey – which we released at the end of November – highlights key IT priorities and investment areas driving private equity firms in 2017. And while we shared some high-level findings at the outset, we’d like to take the opportunity to dig a little deeper into some of the survey results over the next two weeks. Since the survey itself covered four primary areas, our next four Hedge IT articles will examine each of these areas independently and highlight some of the most interesting and thought-provoking findings.
To kick us off, let’s start by taking a look at some critical business priorities for private equity firms in 2017.
Drivers for Private Equity IT Investments
We all know and appreciate how technology can impact our day-to-day operations. For private equity firms, advances in technology have enabled their businesses to become more efficient and drive growth across the entire organization.
When asked to identify the top drivers impacting IT spend in the next 12 months, survey respondents highlighted the need for increased protection against growing cybersecurity threats, a desire to improve the investor/client experience, and the goal of improving efficiencies by refreshing outdated or legacy technology.
2017 is already shaping up to be an interesting year. With a new presidential administration taking office and the hedge fund industry coming off the heels of a challenging year, there’s a lot to keep an eye on. We recently hosted a panel with law firm Morgan Lewis to discuss these and many other topics as part of our “2017 Outlook for Hedge Funds: Risk, Regulation and Technology” event.
Read on for some of our panel’s key takeaways.
2017 Regulatory Outlook
While little is known about how a Trump presidency will operate, there could be potential tax savings for managers depending on how the administration chooses to regulate Wall Street.
Firms should expect to see reforms with the Dodd-Frank Act and the Volcker Rule, which could add more competition into the marketplace if limits on bank investments are adjusted.
SEC Focus Areas
Top six areas of focus for the Securities & Exchange Commission will likely be: (1) expenses and fees, (2) trade allocation, (3) material non-public personal information, (4) valuation processes, (5) operating partners and due diligence, and (6) security, privacy, insider trading and business continuity.
Cybersecurity is not necessarily part of every SEC examination, however, the bar will continue to be raised in terms of preparations firms will need to employ.
In 2016, the SEC provided additional guidance on business continuity and transition plan requirements, highlighting the need for hedge fund and financial firms to maintain their fiduciary responsibility to their clients and investors.
Due to changes in the cyber security landscape, traditional firewalls on the port level are no longer effective at managing traffic. Malicious traffic has the capacity to enter any open port, which provides great risk to firm security. Next-generation firewalls work further than port-based firewalls by adding application inspection and intrusion prevention. Next generation firewalls have the ability to scan traffic as it enters and leaves the network, therefore stopping potential threats.
Eze Castle Integration is increasingly implementing Palo Alto next-gen firewalls for our hedge fund and alternative investment firm clients. Palo Alto is not only a next generation firewall but it is also the market leader based upon ratings, support, pricing and overall performance. A Palo Alto firewall has the ability to detect what traffic is doing and immediately stop threats from spreading by distributing protection.
Unknown traffic is analyzed by Palo Alto Wildfire, where new threats are identified and protections are simultaneously developed. Upon the discovery of an unknown threat, the threat is not only blocked but updates are sent to all global subscribers within five minutes to be able to stop them from spreading. Due to this feature each threat and its variants are blocked without having to go through the analysis process again. Through Wildfire information is also fed through a filter which allows for automatic blocking of any correlated threats.
Older port-based models do not detect what traffic is doing, therefore allowing threats to port hop until they find an open port in which they can enter. Viruses are not port specific and can therefore utilize any port. Without analyzing what traffic is doing threats can easily bypass a port-based model.
The current threat landscape is such that security threats are more likely to arise from within your network as opposed to external sources. Internal users opening malicious emails or becoming victims of phishing schemes are now preferred methods for attackers. The next generation capabilities of the Palo Alto firewalls allow for deep application level inspection to detect and thwart these threats from opening backdoors to your network.
Additional Advantages of Next Generation Firewalls
All-in-one functionality: Next-generation firewalls bundle traditional firewall functionality with intrusion prevention, antivirus and protocol filtering.
With October being cybersecurity awareness month it is an important time to ensure your firm and employees are aware of and using best practices, and security policies and procedures. Risk mitigation is needed to protect both the firm and its employees from savvy hackers and attacks. Data breaches continue to wreak havoc on businesses, and the cost is continuously rising. According to the Ponemon Institute, the total average cost of a data breach is now $4 million, up from $3.8 million in 2015. Hackers have everything to gain while your firm bears reputational and operational harm.
While companywide policies should reflect long-range expectations and corporate best practices, they should also include tactical recommendations that employees can follow to ensure they are complying with the company’s overall risk strategy. To get started here are just a few pieces of advice we offer our investment firm clients and remember to not only inform employees on what to do, but also what not to do.
Private equity firms have been slow to embrace outsourcing, but managing data and technology is more complex than ever. With increasing regulatory requirements and a growing urge to focus on core competencies, PE firms are shifting their views of the back office. In case you missed our recent webinar on 'The Transformation of Private Equity Operations', speakers from Citco Fund Services and Eze Castle Integration examined the changing tide for private equity operations and how CFOs, CTOs and fund managers alike can control operating costs, maximize efficiency and better perfect operational workflows.
Drivers for change.
The number one reason for managers to make the switch to an outsourced solution is the desire for managers to get back to their roots. The idea of back office transformation is really founded in that managers have found themselves spending much more time doing everything but raising money and investing money.
Beneath this layer, back office transformation is also driven by regulation, investor transparency, the lifecycle of a private equity firm, and global reach. Slow adoption, fast results. The private equity sector has been slow on the uptake when it comes to outsourcing, and we contribute this lag due to lack of education on the process and benefits of outsourcing. In the past three to five years, adoption in the PE space has increased because it is cost effective, secure and feature rich. Private equity firms that have made the switch wonder why others are not doing the same. The idea of leveraging an experienced managed service provider is one that private equity firms have really embraced because there is no burden for firms to hire and attract talent, which can be challenging and expensive.
The new Apple iOS version 10, that was released today, delivers some cool new features but before jumping in we recommend you review the following upgrade steps.
Here’s why. As with any major update, there can be risks associated with early adoption until issues are uncovered and Apple has the time to debug and fix them. Eze Castle Integration has learned of some significant potential issues including risk of data loss due to incompatibilities with mobile device management (MDM) applications.
So here’s a critical to-do list before starting the iOS 10 upgrade.
FIRST - BACKUP
Backup your device. Always take a backup before updating your device.
1. The best way to do this is via WiFi at night when the device is also plugged into a power source (computer or electrical outlet). iCloud will back up your device on its own if configured correctly and provided you have enough storage. To ensure this is occurring, launch the Settings App -> iCloud -> Backup and see what it says next to “Last Backup:”. If it only states a time, then it means it backed up today and no further action is needed. If it says a date, you can back up the device by clicking “Back Up Now”. (Note: WiFi is required to back up this way). If this fails, you can back up to iTunes (see next bullet) or clients can call ECI’s Help Desk for assistance.
2. Alternatively, you can backup using iTunes. Plug the device into a computer, launch iTunes, right-click on your device and click “Back Up.”
Manually backup passwords. Ensure you know your iCloud passwords, iTunes Store password, email passwords and any other critical passwords. Write them down and test them. Then safely and securely discard that information. As a best practice, there are secure password storage applications available through the App Store.
Copy anything you can’t live without. Backup anything (i.e. photos) that you cannot live without. Do so in a way that you can verify the backup easily. One option is enabling iCloud Photo Library so you can access copies of your photos on all your other iOS devices.