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.