Blog: Security and Compliance

By: (CSXF)

Whether you work from home full-time, go to the office a couple of days a week, or work full-time in the office, each of us has adjusted our routines to deal with this new lifestyle. With these adjusted routines, it is imperative that we check in on our security routines to ensure the safety of our information and customer information.  Some of the tactics we have relied upon in the past can still be helpful to us today, even if our routines look different.

So, what does it mean to "check-in" on our security routines? Consider these questions:

  • What kind of habits make up a security routine?
  • How can I monitor these habits and controls for myself and my employees as we encounter different types of risk every day?
  • Is there guidance I can turn to for extra tips?

5 Ways to Improve Your Security Routine

Change Passwords Frequently

Many organizations have implemented policies that force passwords to be changed on some sort of frequency to prevent fraudulent logins. Even if an account you use doesn't have this type of policy in place, consider updating passwords for your frequently used accounts to ensure further security.

Don't Share Passwords 

If you're an administrator, manager, or officer of some sort for your organization, you may have elevated administrative privileges for certain accounts. None of your passwords should ever be shared with anyone else, including those within your organization. This can lead to unauthorized access, misuse, alteration, and destruction of data.

Implement Multi-Factor Authentication

This is especially helpful for employees working from home who must access your organization's network over a VPN. Home networks are not always as secure as the network of your organization, and your employees should have to verify their identity before accessing the company network from a different location.

Schedule Regular Exercises / Tests

Testing your organization's response to downtime, closures, or inability to access information can be critical for those situations that occur in real life. Are your employees prepared for how to continue critical operations if there's a network outage, or if they cannot report to their normal job site? Documenting these procedures in a business continuity plan is a start, but executing those procedures helps you identify gaps and areas that need improvement.

Schedule Annual Security Awareness Training

Improperly trained employees pose a large security risk to your institution. Even employees with low-level access to secure information should be trained to understand the importance of keeping information secure, and how to easily detect and report problems. Everyone at your institution plays a role in keeping customer and internal information secure, and creating an environment where risks can be taught, discussed, and used for educational purposes is vital. At least once a year, enroll all employees in security awareness training. As part of the security awareness training, conduct simulated phishing tests. If certain employees continuously fail your simulated phishing tests, take that as an indication that additional security awareness training is needed.

What are my next steps?

As you check in on your security routine, remember that you can always refer to guidance for additional tools and verification. Checking in on your security routine not only benefits your own knowledge and skills, but it benefits the overall well-being and security of your information, so your organization can continue to thrive and provide exceptional service.






Many organizations are adopting Microsoft 365 (formerly Office 365) and businesses nationwide are seeing the benefits of improved productivity through its email and collaboration solution. Organizations of all sizes can benefit from a seamless user experience between mobile and on-premise environments.

While Microsoft 365 offers great flexibility, it mostly focuses on infrastructure management rather than data management. Meaning: You are responsible for your data.

Some businesses who have migrated their workloads to Microsoft 365 do not realize that the same reasons they had for backing up and protecting that data on-premises applies even in the cloud.

If you are still considering Microsoft 365 for office productivity and collaboration, this article may be for you: Microsoft 365: Is it the right choice for your business?

Without proper backup and recovery, your data is at risk, because Microsoft isn't providing complete protection. It's important to create a backup and recovery strategy to ensure you avoid permanently losing your critical data.

It's important to understand the difference in responsibilities of Microsoft and Microsoft 365 user organizations. Microsoft hosts the infrastructure, but you are responsible for your data.

What is Microsoft's Responsibility?

Cloud Infrastructure Uptime — Microsoft focuses on the infrastructure management rather than data management. By focusing on infrastructure, Microsoft ensures its cloud service is online and operational. Guaranteed uptime is based on your agreement level and outlined in the availability SLA (Service Level Agreement).

Basic Data Replication — Microsoft provides basic data replication with datacenter-to-datacenter geo redundancy, and limited retention for short-time data recovery.

Data Processing Compliance — Compliance and controls for data processing are limited to the processor, not the data itself. Microsoft ensures data privacy, regulatory controls, and industry certifications for compliance are in place and maintained for the infrastructure of its cloud service.

Physical Infrastructure Security — Security functions for Microsoft 365 are limited to physical infrastructure, not data. It includes app-level security, logical security, and access controls for users and administrators.

What is the Customer's Responsibility?

Business Data in Microsoft 365 — The customer is the owner of the data that resides in the Microsoft 365 data centers. As the owner, the customer controls the data and who can access the data. All responsibility of the data is on the user to ensure data security, privacy, and retention.

Enterprise-grade Backup and Long-Term Data Retention — Implementing an enterprise-grade backup solution for Microsoft 365 can give businesses confidence to recover from security breaches, compliance exposure, and data loss. With enterprise-grade backup, a copy of the data is stored outside the environment. In the event of an incident, it provides granular and point-in-time recovery options.

Data Owner Compliance — As the data owner, the customer has the ultimate responsibility of data for internal legal and compliance teams. The customer answers to the demands from corporate and industry regulations.

Security Functions to Protect Data — Protection of data is the responsibility of the user, not Microsoft. Security controls must be implemented to protect the data from internal threats, such as accidental deletion, insider threat, and disgruntled employees, and external threats, such as malware, ransomware, and rogue applications.

What happens when Microsoft 365 is used without backup?

Microsoft only provides basic and limited retention. If you don't implement a backup strategy outside of Microsoft's native capabilities, you are opening up your business for unnecessary risk. Lack of a Microsoft 365 backup plan is a risky data strategy.

Without proper backup and recovery, your organization can expose itself to the following risks:

  • Data loss from accidental deletions
  • Ransomware attacks and security breaches
  • Insufficient retention time for regulatory compliance policies
  • Lack of data control due to potential SaaS lock-in

Organizations investing in productivity and collaboration tools should also consider their backup and retention needs as a factor in efficiency and productivity. Considering a third-party backup solution is critical for data loss avoidance.

What is the best strategy for Microsoft 365 backup?

Your data is your business. By taking a data-driven approach to your backup strategy, you recognize the critical importance of your data for your business stability.

Make Microsoft 365 Backup a Key Priority

Backup for cloud services (SaaS), such as Microsoft 365, is imperative for security and data control. Full oversight and control of data is a boardroom priority. Without backup, organizations do not have an exit strategy or freedom from SaaS lock-in because they are not in complete control of their data. Backup should be part of the conversation when buying SaaS and not an afterthought.

Consider Enterprise-grade Data Protection

When investing in backup solutions, consider integration between the Microsoft 365 environment and your existing data protection environment. Evaluate automation, security, and integration between systems when comparing enterprise-grade data protection and recovery features. Integrating SaaS into enterprise data protection can help unify data management.

What to look for in a Microsoft 365 backup solution

1) Freedom to use existing on-premise capacity for Microsoft 365 backup, or the ability to leverage another cloud for cloud backup.
2) Basic features provided, such as incremental backups, granular recovery, automation, and policy-based retention capabilities.
3) A solution capable of managing and protecting hybrid deployments and the ability to ease the full adoption of SaaS.
4) Integration between Microsoft 365 and the customer's existing data protection environment.
5) Advanced security features such as access control, SaaS usage metrics, and multifactor authentication for additional security.
6) Ability to scale up or down as business and data demand changes and as SaaS is rolled out more widely within the company.

Investing in productivity tools and the corresponding backup is an exciting adventure. When you are ready for a guide, we are here to help. We can advise on and implement a solution that fits your business needs. Contact us today to schedule a consultation.


Microsoft has been emphasizing Office 365 (now Microsoft 365) subscription services since the public introduction in 2011. As a result, the popularity of these services has grown to over 155 million active users as of October 2018, and is gaining new users at over 3 million seats per month. With this growth, on-going marketing, and the increasing acceptance of public cloud services, many businesses and financial institutions are starting to look at Microsoft 365.

In this article, we will highlight several pros and cons of Office 365 you should consider to determine if it's right for your business.

Microsoft 365 (formerly Office 365) encompasses several different products and services, but in this article, we will address these services in two primary areas: user applications and back-end services.

Microsoft 365 User Applications

Most Microsoft 365 subscription plans include Office applications like Word and Excel running on Windows, macOS, and portable devices running iOS and Android. Applications are also available through a web browser but most customers are interested in Microsoft 365 applications as a possible replacement for traditional Office licensing.

What are the primary differences between Microsoft 365 and traditional on-premise Office applications?
  • Microsoft 365 is an annual subscription per user or seat. Each user is entitled to run the Microsoft 365 applications on up to 5 devices for the term of the subscription. As long as you continue to pay the annual subscription, you are covered for the Office applications included in your plan.
  • Office applications through Microsoft 365 are designed to be downloaded from the O365 portal. There is no license key to determine if you have a valid license. After installation the applications routinely "check in" to the M365 (formerly O365) portal to ensure there is an active account. Because of this check-in process IT administrations must use a specific procedure for mass deployment of M365 applications. Additionally, installation on multi-user servers like Remote Desktop Services and Citrix requires a new approach.
  • Microsoft 365 applications are designed to install features and security updates directly from Microsoft when they are released. Legacy patch management solutions like Windows Server Update Services (WSUS) and 3rd party solutions will not work with M365. This can create a challenge for regulated customers who are required to report on patch status. Scanning tools used by auditors to determine patch levels will need the ability to recognize the differences between M365 and traditional Office applications. The M365 update process could also create an issue for Office-integrated applications if a hotfix is released that affects the compatibility of those applications, as there will be no option to block that update from being installed.
  • Microsoft 365 applications utilize a feature called Click to Run. This feature, which was originally introduced with Office 2016, provides a streaming method for installing features and patches for Microsoft 365 and Office 2019 applications. Our experience is that Click to Run can use a significant amount of bandwidth if you are installing Office applications or large updates on multiple systems simultaneously.
Is licensing through Microsoft 365 less expensive than traditional licensing?

For most customers the biggest question is: "Is licensing through Microsoft 365 less expensive than traditional licensing?" The answer is "It depends!" Microsoft 365 licensing could be financially attractive if:

  • Your business always updates to the latest release of Office.
  • You want the flexibility of per user licensing.
  • You want to take advantage of the licensing of up to 5 devices for multiple systems, mobile devices, home use, etc.
  • You need a simplified update process that works anywhere the PC has Internet connectivity.
  • You need to use the browser-based applications for a specific function or employee role.
  • You plan to implement one of the Office 365 back-end services.

Microsoft 365 Back-End Services

Microsoft provides several cloud server applications through Microsoft 365 including Exchange Online (email), Skype for Business (voice and messaging collaboration), SharePoint (file collaboration), and OneDrive (file storage and sharing). These back-end services can be implemented individually, or as part of a bundle with or without the Office applications depending on the plan. However, Exchange Online vs. Exchange on-premise is receiving the most attention from our customers.

What should I look for when performing due diligence?

The security and compliance of back-end Microsoft 365 services is not significantly different than any other cloud-based application or service. The areas to research include:

  • External audit attestation – SSAE 18 or similar
  • Data location residency – production and failover scenarios
  • Data privacy policies - including encryption in transit and at rest
  • Contracts and licensing agreements
  • Intellectual property rights
  • Service Level Agreements – service availability, capacity monitoring, response time, and monetary remediation
  • Disaster recovery and data backup
  • Termination of service
  • Technical support – support hours, support ticket process, response time, location of support personnel
A few more things to consider...

As a public cloud service, Microsoft 365 has several challenges that need specific attention:

  • The business plans listed on the primary pricing pages may include applications or services that you don't need. All of the various features can be confusing and it's easy to pick the plan that is close enough without realizing exactly what's included and paying for services you will never use.
  • Most of the back-end M365 services can integrate with an on-premise Active Directory environment to simplify the management of user accounts and passwords. This provides a "single sign-on" experience for the user with one username and password for both local and M365 logins. Microsoft has several options for this integration but there are significant security implications for each option that should be reviewed very carefully.
  • Microsoft has published several technical architecture documents on how to have the best experience with Microsoft 365. The recommendations are especially important for larger deployments of 100+ employees, or customers with multiple physical locations. One of the notable recommendations is to have an Internet connection at each location with a next-generation firewall (NGFW) that can optimize Internet traffic for M365 applications. Redundant Internet connections are also strongly recommended to ensure consistent connectivity.
  • The default capabilities for email filtering, encryption, and compliance journaling in Exchange Online may not provide the same level of functionality as other add-on products you may be currently using. Many vendors now provide M365-integrated versions of these solutions, but there will be additional costs that should be included in the total.
  • Microsoft OneDrive is enabled by default on most Microsoft 365 plans. Similar to other public file sharing solutions like Dropbox, Box, and Google Drive, the use of OneDrive should be evaluated very carefully to ensure that customer confidential data is not at risk.
  • Several other vendors provide Microsoft 365 add-on products that provide additional functionality which may be useful for some businesses. Netwrix Auditor for Microsoft 365 can provide logging and reporting for security events in your M365 environment. Veeam Backup for Microsoft 365 can create an independent backup of your data to ensure it will always be available. Cloud Access Security Brokers (CASB) such as Fortinet FortiCASB and Cisco Cloudlock can provide an additional layer of security between your users and cloud services such as M365.

Discover why the default retention policies of Microsoft 365 can leave your business at risk.

It is certainly a challenge to research and evaluate cloud solutions like Microsoft 365. Financial institutions and other regulated businesses with high-security requirements have to take a thorough look at the pros and cons of any cloud solution to determine if it's the best fit for them.

CoNetrix Aspire has been providing private cloud solutions for businesses and financial institutions since 2007. Many of the potential security and compliance issues with the public cloud are more easily addressed in a private cloud environment when the solution can be customized for each business.

The combination of Office application licensing with back-end services like Exchange Online can be a good solution for some businesses. The key is to understand all of the issues related to Microsoft 365 so you can make an informed decision.

Contact CoNetrix Technology at if you want more information about the differences between Aspire private cloud hosting and Microsoft 365.


By: (CISA, CISSP, Security+)

Well, maybe it used to be the question, but it is no longer a question to be asked. Scanning your network is an essential part of your security protocol to ensure that customer information is secured. So, since I need to scan my systems for vulnerabilities, where do I start?

Determine the Best Product to Scan Your System

There are many good products on the market to test for system vulnerabilities. The best method is to review different products and decide which product will take care of your needs. Not only does the product need to give you information on what vulnerabilities exist on your network, but it also needs to provide you with reporting that is easy for you to read and understand. A report is only good if you can take the information and make decisions on how to remediate the findings that it observes.

Rely on Network Vendors to Conduct Your Scanning

You may be thinking, I do not have the expertise to conduct these scans and read the reports, so what do I do now? This is where you will have to rely on a network vendor or third-party to conduct your scanning. You also need to ensure you have a contract and have conducted your due diligence with this vendor because they will need an administrative account on your network to perform an administrative vulnerability scan. User accounts can be used to scan the systems but will not give you a full representation of all your vulnerabilities. The goal is to mitigate as many vulnerabilities as possible, and a good administrative scan will help you reach this goal.

Remediate Vulnerabilities on the Network

Now that I have all this information, what do I do? REMEDIATE and DOCUMENT. Yes, those two words you always love to hear that strike fear in the hearts of man. Most, if not all, scanning software will rate the criticality of each vulnerability that is found on the network. Always start with the most critical and work your way down the list. Findings will require a knowledge of the systems you are running and an understanding of how to remediate the vulnerability. If you do not have the expertise to take care of these issues, a network vendor will need to be used at this point. Some findings require changes in Active Directory, registry settings or Group Policy. When changing these settings, making the wrong move can cause tremendous damage to your network. If one of these settings need to be changed, it is always a good practice to change the setting for one computer and test the change to ensure it does not cause issues with existing applications.

Sometimes settings cannot be changed due to the harm it causes in the system. If this is the case, document, document, document. Documentation needs to be completed that reveals the issue when you will resolve the issue, how the issue was resolved, and then verify that the issue was resolved.

Verification of the resolution is a critical part of the process. If a change is made in Active Directory, how do I know that the change has happened? If there is a change in Group Policy, how do I know if it has propagated to all the systems with the vulnerability? There are multiple ways to verify different vulnerabilities have been remediated, but the best way is to rerun a scan against the system.

Continue to Scan Your System

So how often do I need to run this scan? The frequency of the scan will be determined by your risk assessment and the size and complexity of your system. Sound familiar? Sounds like a statement that may come from your regulator or through guidance, doesn't it? If my system is not that complex, I would not have to scan frequently, but if it is complex, open to the outside world, and includes multiple users, I would need to scan more frequently.

Keep Up to Date with New Vulnerabilities

New vulnerabilities are being developed all the time, and a system that is scanned and is secure one day may be the target of a new vulnerability the next day. When you are between scans, be sure and keep yourself aware of any new vulnerabilities that may arise, especially those vulnerabilities that target your systems. Keep up to date by receiving emails from publications, vendors and regulators, and attending webinars and seminars that deal with information technology. Sound like a full-time job? It is!

So, to scan or not to scan can never be the question again.


Finding the right cybersecurity provider is not easy. While some services are like utilities where the options are very similar, the cybersecurity company that you choose is not just a matter of personal preference; you need a reliable provider because the potential risks to your business are much greater. As you consider your options, here are a few things you should consider to determine if a cybersecurity provider will protect your business.


Full Coverage – When it comes to cybersecurity, many products have a specific specialty and only work for a certain kind of device. A good cybersecurity provider should be able to install and support a solution - like Security Information and Event Monitoring (SIEM) - that will aggregate multiple solutions to cover your entire network at a reasonable cost.

Complete Protection – Similar to products that only cover certain devices, there are solutions that only protect from attacks that come from the Internet and the cloud but are limited in detecting internal attacks. Be cautious of this and make sure you find a provider that will support solutions to detect and stop not only external threats but attacks from multiple sources. A layered approach to cybersecurity utilizing Intrusion Prevention Systems, Endpoint Protection, Email Filtering, Web Filtering, and Multi-Factor Authentication with comprehensive monitoring and reporting is ideal to provide complete protection.


A product like a SIEM will make meeting reporting and compliance requirements much easier. Most products generate reports or alerts from one type of device, which can be a headache when you are looking for a potential problem across your network, but a good SIEM solution can centralize your alerts and remove a lot of false positives. Ideally, your cybersecurity provider can provide guidance on the type of reports and alerts that are needed to satisfy your regulators.


Expertise – Along with the product, cybersecurity providers should offer additional services in the form of expert analysis and guidance. This is a crucial aspect to consider. You might not have a lot of experience on the complexities of cybersecurity, but when a problem or question comes up, will you know what do to? How much pressure can you handle during a security incident? A good cybersecurity company will have a team of experts that understands your network and can customize a solution to meet your needs.

Monitoring and Notifications – A good cybersecurity company can provide 24x7 monitoring and notifications at a reasonable cost. In the past, having staff to monitor security full-time was only an option for the largest companies. Now there are many cybersecurity providers with Security Operations Center (SOC) services to ensure that when any unusual behavior takes place you will be notified. A good cybersecurity provider should provide a written service level agreement (SLA) on their response times.


In order to have the most complete and reliable cybersecurity coverage, you need a cybersecurity provider that will offer you all the product and service positives that we've discussed here. Our company, CoNetrix Technology, checks all the boxes. If you need a good cybersecurity company, contact us today!


"You need a pen test. This is a vulnerability assessment. Have you considered Red Team testing?"

You might have been told this by a regulatory examiner, your IT vendor, a senior partner, a Board member, or read it in an article. It's a common statement in the penetration testing space these days and with good reason. The scope and methodology of penetration tests is not standardized or regulated, so each provider can create their pen test service as they see fit. This puts more responsibility on you, the customer, to determine if they are meeting your needs.

In this article:

We covered these topics in our webinar Choosing Pen Tests & Real-Life Horror Stories. In this webinar we discussed:

  • The different types of penetration tests available
  • The pros and cons of different penetration tests
  • How to choose the best penetration test for your organization
  • Stories of real-world exploits
  • How to make the most of your penetration testing budget

What is Penetration Testing?

Many terms are used to describe penetration testing…

Red Team, Physical Intrusion, Gray Box Testing, Phishing, Reconnaissance, Privilege Escalation, Precision Strike, War Dialing, Black Box Testing, Social Engineering, Capture the Flag, Web Application Testing, Purple Team, White Box Testing, Blue Team, Pivoting, Internal Testing, External Testing

They overlap, they conflict, they can be misleading.

What is Penetration Testing?

So, what is pen testing?

Whether it's physical, logical, or human, pen testing shows you how an attacker would look at your organization. They look for holes and possibilities to disrupt the way you work.

Penetration testers look for holes and vulnerabilities that could disrupt the way you work.

According to the FFIEC IT Exam Handbook for financial institutions, there are many types of penetration tests . . . and management should determine the level and types of tests employed to ensure effective and comprehensive coverage.* The regulators are giving you the responsibility for figuring out what level and type of pen test you need.

So, what terms mean something, and what is terminology fluff? What should you look for when determining the pen test you need and what vendor to use?

Choosing and understanding penetration test vendors and knowing the terminology is important. Our aim in this article is to help remove some of the mystery around pen testing and help you feel confident in determine the best solution for your company.

What type of Pen Test do you need?

What is the type or level of penetration testing that you need?
Let's go back to the regulation:
"A penetration test subjects a system to real-world attacks selected and conducted by the testers." - FFIEC IT Exam Handbook, Information Security Booklet, Sep 2016 (emphasis added)

Essentially you are choosing what you want tested, you are not telling them how you want them to test it. That should be up to the penetration tester. The reason is, the penetration tester should have the expertise to know what the attackers are doing, and they are going to choose the real-world attacks that the attackers would choose. They have done the research, gone through the certifications and the training to know what types of methods to use. So it's important to know you're not telling them how to do the test, you're telling them what you want tested.

You figure out WHAT you need tested and the penetration tester will figure out HOW to test it.

Here is a simple definition of penetration testing that doesn't use any of the fancy marketing terms. Let's start here.

At its core, penetration testing should show you how an attacker would see you and describe specific attacks they would choose to use against you. That means you don't need to tell the pen testers HOW to do the testing. You just need to tell them WHAT to test and ensure their METHODOLOGY meets your needs and keeps you safe.

So, how do you determine WHAT you need?

Start with a Risk Assessment

When done correctly, a risk assessment will inform you of what you need to do for security testing.

Let's use an example to illustrate. Here is a simple risk assessment.

Simple Risk Assessment

  • What attacks do we hear about from IT, in the news, etc.?
    • Phishing!
    • Ransomware
    • Website attacks
  • What assets do those attacks target for us?
    • Employees
    • Corporate email and perimeter defenses
    • Web servers
  • What testing do we need?
    • Email social engineering for ALL employees
    • Internet perimeter testing for ALL of our public IP addresses

In this sample risk assessment, we are showing that as a company that offers services via the Internet our top concern is cybersecurity; but more specifically, we are concerned with phishing, ransomware, and website attacks.

So how do those threats apply to us? Phishing relies on our employees to click a link or open an attachment, so testing our people is important. Ransomware is typically introduced from the outside, so our corporate email defenses and perimeter defenses, such as firewalls, are important. Website attacks target our webservers directly, so those are also important targets.

Translate your Risk Assessment

After you perform a risk assessment, you will need to translate the results to answer the questions "What" to test and "Why" test it. The penetration test company will figure out "How" to test it.

For our sample risk assessment illustrated above, here is what we would choose:

  1. What to test? — Internet exposed systems
    Why test it? — These are our most exposed systems. They are what our attackers are going to hit first.
  2. What to test? — Employee responses to social engineering, because our employees are the ones who will protect us from phishing attacks.
    Why test it? — Phishing attacks are frequent and successful. They are hurting other people and happen all the time.

TIP: Test against common attacks. Attackers stick with what works. We're tempted to say "It's so common, let's look for the next big thing instead." Attackers will stick with what works as long as it works. So if you're hearing about things in the news, like ransomware and you're worried about it, then that is a valid threat to test against. It will continue to happen until it's no longer profitable for the attacker.

Test against common attacks. Attackers stick with what works as long as it works.

Whether your risk assessment is a formal or informal process is not as important as the results. You need to identify the areas where you are exposed, where your most critical assets are, and where attacks are most likely to occur. These decisions come from knowing your organization and knowing what types of attacks are common. We see these attacks in the news and other places all the time.

Determine the testing you need

Going back to our simple risk assessment example, we can take the assets we identified in the first step and translate them into the type of testing we need. In this case, we decided on email social engineering for all employees and Internet perimeter testing for all of our public IP addresses.

Be specific!

It is important to be very specific when communicating to your penetration testing company what type of testing you want performed. In a minute, we will look at what could happen if we don't communicate clearly.

Choosing a Pen Test Provider

Now that we know what we want to test, we need to define the scope of the testing. Do we want to test just our web servers or our entire Internet exposure? Do we want to test a specific group of employees or are we specifically concerned about a certain department that performs risky tasks – maybe they initiate wire transfers for our company.

In this example, we will define the scope as:

  • All public IP addresses
  • All employees

TIP: Include ALL external IP addresses, active and inactive. You never know when an inactive IP address might become active. Mistakes and misconfigurations happen and attackers are looking for them.

This scope can be modified over time. Maybe we want to test all employees the first time and then focus on a risky department the next time.

What can happen if you don't communicate clearly?

Check out what happened when pen testing services were requested by Iowa State Court Officials. As reported in this news article, the scope of testing was defined as "test the security of the court's electronic records . . . through various means." Not specific enough! It only defined an asset, not what the organization was worried about or what they wanted tested. The result: two pen testers were arrested in Adel, Iowa for attempting to physically break into the court house. The State's response: "[we] did not intend, or anticipate, those efforts to include the forced entry into a building."

In other words, if we want our employees tested against phishing and our Internet perimeter tested against a remote attacker, we don't want the pen testers to do this to our front door:

Unrelated to the Iowa incident, this gentlemen is well-known for his pen testing of physical controls, but would you want this sort of testing when you are concerned about ransomware coming in through phishing emails?

Set the Rules of Engagement

The final step in our pen test selection process is to set the boundaries for our pen testers to follow. Remember that we get to choose WHAT they target, but they get to choose the attacks that would be most effective – what the real attacker might choose. By settings boundaries on those attacks or rules of engagement, we can ensure the pen test won't go too far and cause harm.

In this step you will agree on:

  • What the pen testers WILL attempt
  • What the pen testers WON'T attempt

"The test mimics a threat source's search for and exploitation of vulnerabilities to demonstrate a potential for loss." - FFIEC IT Exam Handbook, Information Security Booklet, Sep 2016 (emphasis added)

Going back to our regulatory reference, these boundaries are stated as "demonstrating the potential for loss." Notice it doesn't say "demonstrating the loss," but rather the potential for loss. This is an important word to highlight because it identifies the need for pen test boundaries. We want our pen test firm to show us how an attack could happen and how it could negatively impact our organization, but we don't want them to go so far as to actually cause loss or have a significant negative impact.

Here's an example set of the rules of engagement that CoNetrix will use. Because we typically test live, operational systems, we put certain rules into place to make sure the testing stays within bounds.

Rules of Engagement
  • Do no harm. It's not a good penetration test if the penetration test company leaves you more vulnerable than you were when you started. What would that look like? If they went into a system and they installed malware and left that malware sitting there and didn't tell you they installed it. That malware may be opening a door to the internet that you didn't have before. If the pen testers create new exposure, then it would leave you worse off than when you started.
  • No significant customer impact. You don't want customers calling in saying: "I can't get into my internet banking account," "I can't log in to this website," "the website is down." The penetration test company needs to be very aware of who your customers are and how they use your systems. They need to make sure that everything they do does not impact the customer. Some tests can't be performed unless there is some customer impact. How would a penetration company handle that? The way it should go is: 1) Identify the vulnerability and the potential exploit for that vulnerability. 2) Contact the customer and let them know about it. If they would like us to perform the exploit, inform them it may cause some downtime and it might affect their customers. 3) Coordinate with the customer on when to perform the exploit testing. Maybe we do it after hours. Or it may be they are great with just knowing the vulnerability exists and don't need the exploit performed due to the possible negative impact.
  • No unplanned operational impact. A penetration test company may discover that your system or website is extremely vulnerable to a certain kind of denial of service attack. If exploited, it could be taken down for hours on end. That's great to know, but the penetration test company should not exploit that vulnerability without coordinating with you first. That would cause unplanned operational impact and now your IT department is scrambling and your customers or your internal staff are upset because they can't do their job or access your services.
  • Limited system recovery time/money. This is an important one and not always obvious. If you're not careful, a penetration tester that is not very good at what they're doing could say "well, we could do this and they would just have to restore from backup". That's easy for the penetration tester to say, but they aren't the ones who have to do the work to restore from backup. A lot of times restoring from backup can be a complicated process and can take a while. It might cost a lot of time and money, and that may not be obvious to a penetration tester. Just having a dedicated person to go recover a system can be a big impact to other projects and tasks you have going on. If an exploit is going to take significant effort or money to recover from, then that needs to be out of bounds, unless you have coordinated about it ahead of time.
  • Attempted exploits need to provide value. Penetration testing can be flashy and glamorous. It shows up in movies, TV shows, YouTube, etc. Make sure that the exploits that are being performed are providing value. Flashy and glamorous is fine for the movie screen, but real world pen testing must provide value to your company by helping improve your security posture.
  • If an exploit might break the rules, report the vulnerability. A penetration test company may say they found this vulnerability, but if exploiting it is going to break the rules, then it would be better to just report the vulnerability and say what needs to be fixed. It's better to do that than to cause your customers and staff a lot of grief. The vulnerability can be talked about and remediated without causing problems.

These are the rules of engagement we practice here at CoNetrix when performing penetration tests.

Evaluate a Pen Test Provider

So let's wrap up how to choose a pen test provider with some ways you can evaluate pen testers and then we'll move on to the fun stuff – the exploits!

  1. Know what you need tested and clearly communicate that in the project scoping and quoting process. We talked about identifying what you need tested. Make sure the pen test company's expertise matches with what you need tested. As we saw earlier, some pen testers excel in physical security testing. Others excel at Internet-based testing. Some are industry-specific such as SCADA pen testers. Make sure you find out what their strengths are.
  2. Make sure their report is understandable and well-organized. Many pen testers are great at successfully demonstrating attacks. After all, that's the fun part – the part that gets put into the movies. Buy many don't put as much effort in communicating what they did and how you can improve your defenses. Make sure the format of the report and the way information is communicated in the report is going to help you improve your security. Is it actionable for you and your IT/security staff?
  3. Check out their certifications on top of experience. Certifications are a great way of making sure a pen test company has the knowledge and skills necessary. Some examples include Certified Ethical Hacker (CEH), Offensive Security Certified Professional (OSCP), and any certification that shows they have knowledge of the area you need tested.
  4. Make sure the penetration test company will help you understand the report. We believe security testing is most useful when it is a partnership, not a stand-alone service. Ask how the pen test company will help you understand what the issue is and what you can do about it. Do they review their results with you? Do they provide remediation recommendations? Or do they drop a bunch of results on you and wish you good luck.

Phases of Pen Testing

So now let's talk about the fun side of pen testing—exploitation. It's good to know that exploitation is part of the process. Many times it is because of this process that a penetration test report may look like a vulnerability assessment. Every pen test process follows a similar process—identify how the target is exposed—identify vulnerabilities that could be attacked—exploit those vulnerabilities—report both the vulnerabilities and any successful exploits.
But what if no exploits were possible—at least not within the rules of engagement? In that case, the report would only identify vulnerabilities and could look a lot like a vulnerability assessment. But through your pen test selection process, you made sure the firm would exploit vulnerabilities when safe and possible and their documented methodology should reflect that approach.
Phases of Pen TestingOne of the best things you can do when evaluating a pen test company is ask them for examples of what they have done. See how they did it and whether you're comfortable with the things they are capable of doing.

One of the best ways to evaluate a pen test company is to ask for some examples of their successful exploits.

*FFIEC IT Exam Handbook, Information Security Booklet, Sep 2016
**This blog post is for information purposes only. Evaluate your risks before acting on any ideas presented in this article.


On Wednesday, November 14th, the Federal Financial Examination Council (FFIEC) released an updated version of the Business Continuity Management Booklet. One of the changes is related to business continuity and disaster recover exercises and tests. In the new booklet, the FFIEC redefines the testing methods and introduces more delineation between a BCP exercise and a BCP test.

What is a BCP Exercise?

According to the new booklet, "an exercise is a task or activity involving people and processes that is designed to validate one or more aspects of the BCP or related procedures" (p. 37). Each exercise can look different depending on the scope, goals, and objectives of the test. Some exercises can be discussion only (i.e. tabletop discussion) while others could be comprehensive (i.e. full-scale exercise).

What is a BCP Test?

The new booklet defines a test as a "type of exercise intended to verify the quality, performance, or reliability of system resilience in an operational environment" (p. 37). Tests typically focus on a system or set of systems. An example of a test might be verifying back on a server is functions or verifying recovery time objectives (RTOs) are acceptable for a system. The big difference according to the booklet is, "exercises address people, processes, and systems whereas tests address specific aspects of a system" (p. 38).

How are the testing methods different in the new booklet?

Examples of testing methods from the older 2015 Business Continuity Planning Booklet included (p. 18):

  • Tabletop Exercise Structured Walk-Through Test. "[The tabletop exercise structured walk-through tests] primary objective is to ensure that critical personnel from all areas are familiar with the BCP and that the plan accurately reflects the financial institution's ability to recover from a disaster."
  • Walk-Through Drill/Simulation Test. "A walk-through drill/simulation test is somewhat more involved than a tabletop exercise/structured walk-through test because the participants choose a specific event scenario and apply the BCP to it."
  • Functional Drill/Parallel Test. "Functional drill/parallel testing is the first type of test that involves the actual mobilization of personnel to other sites in an attempt to establish communications and perform actual recovery processing as set forth in the BCP."
  • Full-Interruption/Full-Scale Test. "In a full-scale test, a real-life emergency is simulated as closely as possible."

The new testing methods introduced in the 2019 Business Continuity Management Booklet map closely to its predecessor; however, they are renamed and have slight differentiators (pp. 42-44).

  • Full-Scale Exercise. "A full-scale exercise simulates full use of available resources (personnel and systems) prompting a full recovery of business processes."
  • Limited-Scale Exercise. "A limited-scale exercise is a simulation involving applicable resources (personnel and systems) to recover targeted business processes."
  • Tabletop Exercise. "A tabletop exercise (sometimes referred to as a walk-through) is a discussion during which personnel review their BCP-defined roles and discuss their responses during an adverse event simulation."
  • Tests. "Management uses tests to verify the quantifiable performance and reliability of system resilience."

What does this mean for me?

The new FFIEC guidance highlights the "people and processes" aspects of your organization's BCP. This is a shift in focus from the 2015 BCP booklet in which testing guidance more heavily emphasized testing IT systems and system components. This change can be seen in the definitions of the testing methods. Personnel are specifically included in all four of the "exercise" definitions whereas the definition of "tests" is only concerned with validating system resilience.

What hasn't changed is BCP exercises and tests are used to validate one or more aspects of an enterprise-wide BCP. Financial institutions should incorporate a variety of exercises and tests into their overall BCP test program in order to ensure the institution can restore operations and recover from business interruptions. While the test program will be different based on each institution's size and complexity, strong test plans include strategies to evaluate all aspects of the institution's BCP, including people and processes as well as IT systems.


For more information about the updated booklet, visit:



It was announced on August 16th that 22 Texas cities were attacked and infected with ransomware, rendering many of their municipal IT systems unavailable to conduct daily business. The mayor of one of these cities has said the ransom request was $2.5 million to unlock their files. The Texas Department of Information Resources believes this was a coordinated attack by a single threat actor. Source:

We will likely get more details about how these networks were infected, but this incident should be a reminder to continually evaluate your cyber security risks and follow best practices to ensure your business or financial institution is protected. 

Below are a few comments and recommendations to consider as you examine your cyber security posture.

You don't have to be a big business to be a target

We've seen an increasing number of cyber attacks and ransomware infections directed toward small businesses where the bad actors see them as "low hanging fruit" with limited cyber security defenses. The cities listed in the recent news articles about this event are relatively small - less than 10,000 residents.

Most of these attacks rely on email phishing to gain access

A good email filtering solution is a good start, but on-going employee training and testing is critical to help them recognize potentially malicious emails. There are several tools availalble like the Tandem Phishing solution ( to help design and implement a phishing plan.

Traditional Anti-Virus solutions are not good enough

Many small businesses are still relying on traditional signature-based AV solutions. These products are not sufficient to protect against the latest malware. New products such as CylancePROTECT are more effective for stopping attacks by using machine learning instead of a bulky signature database.

Monitor your network

Our IT environments are under constant attack from bad actors around the world. This is an unfortunate fact of life today. An effective monitoring solution like CoNetrix Network Threat Protection is one of the security layers that every business should implement to help identify these attacks, and help them react quickly to prevent or limit potential damage. 

Incident Response is important

While we apply controls to protect against incidents, it is important to have a plan in the event of an incident occurs. If you have a documented Incident Response plan, great! Now take that IR plan to the next level by regularly conducting table top exercises and penetration testing to validate and improve it.

Backups should be a last resort

Ideally, if several security layers are in place then restoring from a backup won't be needed. However to ensure your backup is safe from being encrypted by ransomware it should be "air gapped" from the primary network. This means the backup data should be offline or not directly accessible for the malware to encrypt. Historically this has been done using removable media like tapes, but today it is much more efficient and cost-effective to use a cloud backup service. Many of these services (like CoNetrix AspireRecovery) provide a cloud backup with an option for disaster recovery services. 

No enterprise has to be a victim to ransomware. With proper planning and intentional practice, you CAN protect your network. While there is an investment associated with implementing appropriate controls and practices, the return on investment is well worth it if you protect against just one attack, not to mention the peace of mind you gain.

Contact CoNetrix Sales if you would like more information about protecting your network.


The world of cybersecurity has had some fundamental shifts in the past several years that have made the vast majority of companies unprepared for today's threats. The extensive use of malware, for example, has dramatically reduced the value of traditional security solutions, such as firewalls, IDS/IPS, and anti-virus software. These solutions that used to adequately prevent attacks are now very limited in their risk mitigation value. Many organizations have not updated their cybersecurity technology and solutions to stop today's threats. It's like monitoring your front door for a break in while someone comes in through the back window.

Even companies that have taken cybersecurity seriously have not always been led the right way by cybersecurity vendors. In the past, an organization who was serious about cybersecurity was told that they needed 24x7x365 monitoring - paying for really smart cybersecurity professionals to watch the alerts and events as they happen in real-time so they could respond at a moment's notice to malicious events.

But legacy technologies have relied mostly on human review, not machine intelligence. A common metric for a traditional Managed Security Service Providers (MSSP's) is to have a security engineer for every 30 devices under management. In the U.S., the average cybersecurity professional makes $116,000/year. This means the cost to monitor a single device is $322/month, forcing traditional MSSP's to charge between $500 and $1500/device/month to be profitable. Does this sound like your MSSP?

At those rates most customers can only afford for a few devices to be monitored; usually the firewall, IDS/IPS, and possibly a Windows domain controller. When asked why they don't need to monitor more devices, these MSSP's would state "As long as you are monitoring the choke points, you are safe."

Using the home security system analogy, imagine being told that monitoring the front and back doors are enough and then having your child kidnapped through a bedroom window. No choke point only security system would detect that, allowing the worst-case scenario to happen without your system even tripping. Home security systems relied upon a few choke points because it was very expensive to run wires to the whole home (especially after it was already built). However today many home security systems use wireless technology which has made it possible to place multiple sensors throughout the house without the use of wires. This makes the cost of securing the entire home from multiple threats much less expensive.

Thankfully, IT cybersecurity has evolved as well. Automated correlation and analytics from a properly deployed, configured, and tuned Security Information and Event Management (SIEM) solution has the ability to increase the ratio of devices per cybersecurity professional exponentially. Today, SIEM technology can quickly and efficiently find the "needle in a haystack" with far less human interaction. This dramatically reduces the number of cybersecurity professionals needed for a traditional Security Operation Center (SOC) which means a lower cost per device for customers. With a lower cost to monitor each device, we can now monitor more devices. Rather than just monitoring choke points, we can monitor all of the windows, doors, and rooms; which is really what was needed from the beginning.

When all of the critical devices are being monitored and correlated, you can now stitch together pieces of information across different systems and areas of the network to give you a much more accurate picture of what is happening. In other words, the more devices that you monitor, the more accurate the monitoring becomes and, therefore, the better economies of scale can be achieved.

So, what should a customer monitor? It's still a good idea to monitor the firewall and IDS, but we need to go beyond that and focus on today's threats. Routers, servers (especially Active Directory servers), wireless access points, and endpoint security solutions should all be monitored. With current SIEM technology, you can monitor all of these systems for about the same price as you used to be able to monitor just the firewall and IDS/IPS.

Monitoring only choke points and smaller areas of a network will not protect your organization from today's threats. Cybersecurity monitoring is more important than ever, but real risk mitigation comes with a holistic approach to monitoring all of the possible security events from every possible device. Stop only monitoring your front door for a break-in and assuming that your business is safe... because your back window is open.

Contact Technology Sales at 806-698-9600 or email if you want to improve your Cybersecurity Monitoring and Response solution AND lower the annual cost.


This article was updated on August 28, 2019. See below for the updates.

What is the FSSCC Cybersecurity Profile?

The FSSCC Cybersecurity Profile was published on October 25, 2018 by the Financial Services Sector Coordinating Council (FSSCC). The FSSCC is a private entity comprised of 70 members from financial services organizations. Their cybersecurity profile has multiple tiers, which allow users to answer a scalable set of questions. This scaling is designed to provide an expedited assessment of the user's organization's cybersecurity preparedness.

In addition to the tool's claims of efficiency, the tool's development is largely credited to organizations familiar to the financial services industry. The Press Release includes names such as the American Bankers Association, Bank Policy Institute, the Institute of International Bankers, and more.

Beyond this, the FSSCC has made multiple appeals to the Cybersecurity Profile's usefulness in regulatory examinations, going so far as to claim, "The numerous and substantial benefits [of using the FSSCC Cybersecurity Profile] to the financial services sector are: […] Supports tailored supervision, examinations, and collaboration among state, federal, and international supervisors," per the FSSCC Overview and Users Guide.

What is the FFIEC Cybersecurity Assessment Tool?

The FFIEC Cybersecurity Assessment Tool (CAT) was initially published on June 30, 2015, and updated May 31, 2017. The CAT was designed by the Federal Financial Institutions Examination Council (FFIEC), a formal interagency body, comprised of members from the FRB, FDIC, NCUA, OCC, CFPB, and SLC. The CAT is standardized, which allows users to answer a specific set of questions, designed to provide a thorough assessment of their organization's cybersecurity preparedness.

The FFIEC CAT includes 494 cybersecurity maturity statements, which has resulted in some complaints. However, it is not only designed to provide a detailed assessment of a financial institution's current state of cybersecurity preparedness, it also enables targeted and long-term planning for growth and improvement.

With regard to examinations:

• The FDIC continues to heavily rely on the InTREx Work Program. While InTREx does state financial institutions are not required to use the FFIEC CAT to assess cybersecurity preparedness, the program also states FDIC examiners will reference the CAT's Appendix A when performing examinations.

• The NCUA is currently implementing the Automated Cybersecurity Examination Tool (ACET). The ACET is based on the FFIEC CAT, with a document request list to help credit unions understand, gather, and organize the documents needed for the examination. Read our blog on FAQs about the ACET

• In their Spring 2018 Semiannual Risk Perspective, the OCC announced they had "implemented the Federal Financial Institutions Examination Council (FFIEC) Cybersecurity Assessment Tool (CAT) into its examination process." In addition, an OCC representative at the 2019 CoNetrix KEYS Conference Examiner Panel indicated the OCC is piloting their own segmented version of the FFIEC CAT, to be fully completed on a three-year cycle.

August 2019 Update: In July 2019, the OCC replied to a comment from the FSSCC in the Federal Register. The FSSCC asked the agencies to "make a clear statement that other methodologies, such as NIST Cybersecurity Framework and the FSSCC Cybersecurity Profile, are acceptable inputs into the examination process." The OCC replied that financial institutions "may choose to use the [FFIEC CAT], the NIST Cybersecurity Framework, or any other risk assessment process or tool to assess cybersecurity risk."

• The FRB's supervisory letter about the tool, SR 15-9, indicated the CAT's planned use in examinations, and the FRB was a contributor in the May 2017 update of the tool, per their 2017 Annual Report. Additionally, a list of Information Technology Guidance was published, including the FFIEC CAT as a "Policy Letter."

Will the FSSCC Cybersecurity Profile Replace the FFIEC Cybersecurity Assessment Tool?

While the FSSCC Cybersecurity profile has fewer questions, and the FSSCC has expressed interest in seeing the tool used during regulatory examinations, the federal banking agencies have not yet expressed the same interest.

In addition, while completing the FFIEC CAT is not required, four years into the CAT's implementation, examiners are now familiar with the tool and the agencies continue to supplement and reference the CAT in their own examination programs. In light of this, using the CAT to assess cybersecurity preparedness could help expedite the examination process, as the tool may be used during an exam.

At this point in time, it is not clear what the future holds for the FSSCC Cybersecurity Profile. Due to the thorough nature and widespread adoption of the FFIEC CAT, it is difficult to imagine the CAT will be replaced by any tool in the foreseeable future.

August 2019 Update: In August 2019, the FFIEC published a press release encouraging a standardized approach to assessing cybersecurity preparedness. While the press release lists the FFIEC CAT, NIST Cybersecurity Profile, Center for Internet Security Controls, and FSSCC Cybersecurity Profile as references to "support institutions in their self-assessment activities," the press release reiterates that "the FFIEC does not endorse any particular tool" and the "tools are not examination programs."

Does CoNetrix have anything that can help with assessing cybersecurity preparedness?

Yes. The Tandem Cybersecurity module took the FFIEC CAT PDF content and streamlined it into an easy-to-use web-based application. With email reminders, charts and graphs, presentation documents, optional peer comparison, and tools for the NCUA's ACET, you can put the FFIEC CAT to work for you. Get started for free with Tandem Cybersecurity.