The Acquisition of Island Banking Services has moved from the strategy development phase to the integration phase. In this phase, the M&A team will develop transition and implementation plans. Padgett-Beale’s Chief Information Security Officer (CISO) has recommended that a separate Cybersecurity Management Program be established for the Padgett-Beale Financial Services (PBI-FS) subsidiary to isolate as much risk as possible to the PBI-FS organization. This management program will require the establishment of policies, plans, and procedures which are customized to the financial service industry and the operating structure of PBI-FS.
The CISO has asked you to continue supporting the Merger & Acquisition team’s efforts. Your specific tasking is to assist in developing an implementation plan for the previously developed Cybersecurity strategy (Project #1). Since there have been additional developments in the M&A strategy overall, you should pay close attention to the Background Information provided later in this document.
Using your prior work (Project 1), develop a high-level plan for implementing a Cybersecurity Management Plan that will allow PBI-FS to begin operations in its new, on-island location. (The plan for the U.S. headquarters is being developed separately from your efforts.) This plan must take into account compliance requirements for U.S. banking laws, regulations, and standards. It must also include recommendations for required security controls, replacement of outdated hardware and software, and other measures necessary to reduce risk to an acceptable level. You must specifically address measures to reduce risks associated with both insider threats and external threats and threat actors.
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