The FCA has set out the below points that you should consider regarding your firm’s operational and cyber resilience following Russia’s invasion of Ukraine:
Although the National Cyber Security Centre (NCSC) is not aware of any current specific cyber threats to the UK following events in Ukraine, the NCSC has supported US President Biden’s call for increased cyber security vigilance among firms in response to Russia’s invasion of Ukraine.
We recommend firms follow their actionable guidance as a priority, to reduce your risk of cyber compromise.
Alongside the guidance listed above, the NCSC have issued guidance for various sizes of firms:
We also encourage firms to review the NCSC’s Cyber Essentials scheme.
You should consider your ability, and that of your third-party providers, to withstand a cyber attack. You should take all appropriate steps to shore up your controls, including raising staff awareness: that may, for example, include re-running staff ethical phishing campaigns. Consider if your staffing levels are appropriate to deal with an elevated cyber risk.
Important business services
You should consider the implications of the continuing unrest and UK/US/EU sanctions and how that might impact upon your firm and your third-party providers, and whether this could affect your ability to deliver your important business services.
Business continuity and incident management
You should ensure your business continuity and incident management arrangements are up to date, ensuring that you can continue to function and meet your regulatory obligations in the event of unforeseen disruption.
You should be ready to report material operational incidents to the FCA in a timely way.
During this period, it could be extremely valuable to the FCA and other UK authorities to be notified quickly of developing cyber incidents or outages, so that we can provide specialist expertise and work to minimise harm to consumers, markets and the wider UK financial sector.
See how to report an operational disruption.
You should be alert to the risk of false information being gathered or shared about the operations of a particular firm or the financial services sector, or about your staff. This could be, for example, information shared on social media.
If false information is circulated about your firm, you should have a prompt, clear response to try and prevent that information being acted upon.