While the text of the article lays out the directives, what truly brings these requirements to life is how organizations interpret and implement them.
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Unpacking Article 9: Core Components
Section 1: Detecting Anomalous Activities
- Mandates mechanisms to promptly detect anomalies, including ICT network issues and ICT-related incidents.
- Stresses the identification of “potential material single points of failure.”
Section 2: Multiple Layers of Control
- Requires detection mechanisms to have multiple layers of control.
- Specifies the need for defining alert thresholds and criteria for triggering ICT-related incident detection and response.
- Requires automatic alert mechanisms for relevant staff.
Section 3: Resource Allocation
- Emphasizes the need to allocate sufficient resources for monitoring user activity and detecting anomalies and incidents.
- Considers the size, business, and risk profiles of the financial entity when determining what “sufficient resources” means.
Section 4: Trade Report Accuracy
- Applies to certain financial entities as defined in Article 2(1) point (l).
- Requires systems that can effectively scrutinize trade reports for completeness and identify omissions or errors.
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Article 9 centers on creating robust and vigilant detection systems. It covers both the technological and human resources aspects, emphasizing a multi-layered approach to improve security posture.