According to FFIEC:

Financial institutions should have an effective process to administer access rights. The process should include:

FFIEC also notes:

In addition, FFIEC offers guidelines for security monitoring.

Financial institutions should gain assurance of the adequacy of their risk mitigation strategy and implementation by:

Vormetric’s Data Security Platform provides state of the art user access control.

• Separation of privileged access users and sensitive user data. With the Vormetric Data Security Platform, administrators can create a strong separation of duties between privileged administrators and data owners. The Vormetric Data Security Platform encrypts files, while leaving their metadata in the clear. In this way, IT administrators—including hypervisor, cloud, storage, and server administrators—can perform their system administration tasks, without being able to gain privileged access to the sensitive data residing on the systems they manage.
• Separation of administrative duties. Strong separation-of-duties policies can be enforced to ensure one administrator does not have complete control over data security activities, encryption keys, or administration. In addition, the Vormetric Data Security Manager supports two-factor authentication for administrative access.
• Granular privileged access controls. Thales eSecurity’s solution can enforce very granular, least-privileged user access management policies, enabling protection of data from misuse by privileged users and APT attacks. Granular privileged user access management policies can be applied by user, process, file type, time of day, and other parameters. Enforcement options are very granular; they can be used to control not only permission to access clear-text data, but what file-system commands are available to a user.

Thales eSecurity protects the data itself through Vormetric Transparent Encryption with integrated Key Management for data at rest, Application Encryption, Tokenization with Dynamic Masking and more. These techniques make the data meaningless and worthless without the tools to decrypt it.

Thales eSecurity enables the credit union to monitor and identify extraordinary data access. Vormetric Security Intelligence provides detailed management logs that specify which processes and users have accessed protected data. The detailed management logs specify when users and processes accessed data, under which policies, and if access requests were allowed or denied. The management logs will even expose when a privileged user submits a command like 'switch users' in order to attempt to imitate, and potentially exploit, the credentials of another user.

Sharing these logs with a security information and event management (SIEM) platform helps uncover anomalous patterns in processes and user access, which can prompt further investigation. For example, an administrator or process may suddenly access much larger volumes of data than normal, or attempt to do an unauthorized download of files. These events could point to an APT attack or malicious insider activities.