SAMA CSF Compliance


What is the SAMA CSF?

The Saudi Arabian Monetary Authority (SAMA), the central bank of the Kingdom of Saudi Arabia, assumes the role of supervisory authority over various financial institutions within the Kingdom. A significant part of SAMA's responsibility is the establishment and maintenance of the Cyber Security Framework (CSF). This framework has been set up to enable the financial institutions regulated by SAMA, hereafter referred to as member organizations, to pinpoint and effectively address cyber security risks, while also providing direction for cyber security requirements for member organizations, their subsidiaries, employees, third parties, and customers. This serves as a robust line of defense against cyber security threats.

The core objectives of the SAMA CSF are threefold:

  • Facilitate a unified approach for addressing cyber security issues within the member organizations.
  • Ensure that member organizations attain an optimal level of maturity in their cyber security controls implementation.
  • Ensure that cyber security risks are effectively managed throughout the member organizations.

Beyond providing guidelines, the SAMA CSF actively evaluates the effectiveness of cyber security controls for member organizations and guides their cyber security requirements. This proactive initiative by SAMA fosters stakeholder confidence and ensures the security of the financial ecosystem in Saudi Arabia.

The SAMA CSF is aligned with the best practices and requirements of regulatory mandates such as the NIST, ISO, BASEL, and PCI DSS. It outlines cyber security controls pertinent to various information assets of the member organization, including but not limited to electronic and physical information, software applications, computer systems, and communication networks.

Who must comply with the SAMA CSF?

The SAMA CSF seeks to provide robust security measures to reinforce the overall financial network within Saudi Arabia. Understanding who must comply with this framework is of crucial importance. Entities that must comply include:

  • Banks functioning within Saudi Arabia's boundaries.
  • Insurance and/or reinsurance companies established and operational within Saudi Arabia.
  • Financing entities offering its services in Saudi Arabia.
  • Credit bureaus active in Saudi Arabia.
  • Financial market infrastructural entities (e.g., securities registries, stock exchanges, clearinghouses).

Notably, the banking sector is required to adhere to all areas, or domains, of this framework, covering various requirements such as application security, access control, infrastructure security, etc. Other organizations, depending on their function and risk exposure, may be required to comply with selected domains. The SAMA CSF exists to ensure these organizations are prepared against digital threats.

Consequences of SAMA CSF non-compliance

Failure to comply with the SAMA CSF can lead to serious consequences, such as:

  • Punitive measures: Should an organization not meet the standards set by SAMA, a range of remedial actions or penalties might be imposed. These could range from warnings to financial penalties proportionate to the level of non-compliance.
  • Corrective action plan: SAMA may require an entity to submit a plan of action to rectify the non-compliance.
  • Public censure: Non-compliance could result in a public statement against the organization, tarnishing its reputation.
  • License amendments: SAMA has the authority to amend, restrict, suspend, or even revoke the organization's license, effectively hampering its operations.
  • Legal recourse: In more severe cases, SAMA might seek legal action in relevant courts, potentially resulting in further penalties and legal complications.

Compliance with the SAMA CSF is not just obligatory—it is also in an organization's best interest to protect its financial stability, reputation, and business operations. This bolsters the broader cyber security landscape by setting a high standard for security, encouraging diligence, and deterring any potential for non-compliance.

SAMA CSF requirements for compliance

To be in compliance with the SAMA CSF, organizations must understand and implement several key requirements, divided into four broad categories:

1. Cyber security leadership and governance: This focuses on creating a robust foundation for cyber security within the organization.

  • Cyber security governance: The organization must define and implement a cyber security governance structure that is endorsed by the organization’s board. This structure guides the approach to cyber security, ensuring a comprehensive, top-down management of cyber security issues.
  • Cyber security strategy: A clear cyber security strategy should be established and aligned with the organizaton's security objectives. This ensures cyber security initiatives contribute effectively to the overall security posture of the organization.
  • Cyber security policy: A definitive cyber security policy must be defined, approved, and communicated across the organization. This policy documents the organization's commitment to cyber security and effectively communicates cyber security objectives to relevant stakeholders.
  • Cyber security roles and responsibilities: Responsibilities for implementing, maintaining, supporting, and promoting cyber security must be clearly defined. By doing so, all relevant stakeholders become aware of their responsibilities and can contribute to the overall cyber security controls.
  • Cyber security in project management: Cyber security requirements must be incorporated into project management and governance. This ensures all projects undertaken by the organization meet the necessary cyber security requirements, fostering a secure project environment.

2. Cyber security risk management and compliance: This area focuses on identifying, analyzing, responding to, monitoring, and reviewing cyber security risks.

  • Cyber security risk management: The organization must establish a defined, approved, and implemented cyber security risk management process, aligned with the enterprise risk management process. This ensures proper management of cyber security risks, safeguarding the confidentiality, integrity, and availability of the organization's information assets.
  • Regulatory compliance: An established process for identifying, communicating, and complying with other applicable regulations like PCI-DSS, the EMV technical standard, and the SWIFT Customer Security Controls Framework (CSCF) is required.
  • Compliance with international industry standards: The organization must comply with mandatory international industry standards. Compliance ensures adherence to best practices and reinforces the organization's commitment to maintaining the highest standards of cyber security.

3. Cyber security operations and technology: This involves ensuring the protection of the organization's information assets and processes.

  • Human resources: Cyber security requirements must be integrated into human resources processes. This ensures that cyber security responsibilities are embedded in employment terms and employees are adequately screened throughout their work lifecycle.
  • Asset management: An asset management process must be defined, approved, implemented, communicated, and monitored. This process will ensure an accurate, up-to-date, and unified asset register, thereby supporting organizational processes.
  • Cyber security architecture: The organization should define, adhere to, and review a cyber security architecture that outlines security requirements and design principles for developing cyber security capabilities. This ensures a strategic, consistent, cost-effective, and comprehensive cyber security framework.
  • Identity and access management: Access to information assets should be restricted according to business requirements, based on need-to-know principles. This ensures that only approved users with adequate privileges can access pertinent information assets.
  • Application security: Cyber security standards for application systems must be defined, approved, and implemented. Compliance with these standards should be monitored and their effectiveness measured and evaluated periodically to ensure robust application-level security.
  • Infrastructure security: Standards for cyber security within infrastructure components must be defined, approved, and implemented. These standards, along with their compliance and effectiveness, should be regularly monitored and evaluated to ensure a secure infrastructure.
  • Payment systems: A cyber security standard for payment systems must be defined, approved, implemented, and monitored. The effectiveness of this standard should be measured and evaluated periodically to ensure the confidentiality and integrity of transaction systems.

4. Third-party cyber security: When working with third parties, the same level of cyber security protection should be ensured.

  • Contract and vendor management: The organization should define, approve, implement, and monitor the required cyber security controls within the contract and vendor management processes.
  • Outsourcing: The organization should define, implement, and monitor the required cyber security controls within the outsourcing policy and process.

SAMA CSF roadmap

The roadmap to achieving SAMA CSF compliance involves the following stages:

  • Comprehend the framework: Understanding the SAMA CSF's objective is crucial for managing cyber security risks in the financial sector and implementing the framework. It is also the basis for the regular self-assessments that organizations are required to undergo. SAMA audits these assessments to ensure the level of compliance with the framework and the progression of cyber security maturity.
  • Identifying scope and implementation: The organization's chief information security officer should assess if compliance with the SAMA CSF is required. If so, they must determine, implement, and document all compulsorily required controls, including their scope and exclusions.
  • Self-assessment and audit: Organizations are required to perform self-assessments annually to gauge their compliance with the framework and maturity of cyber security. These assessments are then audited by SAMA for validation.
  • Continual compliance: Maintaining continual compliance with the framework is vital. This involves consistent reviews, audits, and updates, as well as ensuring employee cyber security awareness and training.

In essence, achieving compliance with the SAMA CSF requires a thorough understanding of the framework, strict adherence to the outlined requirements, and continuous self-assessment and improvement of cyber security controls.

SAMA CSF best practices: A checklist

  • Establish a cyber security committee with an independent senior manager at the helm, and create an independent cyber security function with its audits handled by the internal audit function.
  • Define and implement a robust cyber security strategy, reviewing and maintaining it periodically according to a pre-defined process.
  • Make it mandatory for employees to comply with the cyber security policy, standards, and procedures, and include cyber security responsibilities in employee agreements.
  • Provide employees with initial and ongoing cyber security awareness training.
  • Conduct regular cyber security risk assessments considering assets, threats, controls, and vulnerabilities, documenting all identified risks in a central register.
  • Create a structured process to identify, communicate, and comply with relevant regulations, and adhere to international industry standards like PCI-DSS, EMV, and the SWIFT CSCF.
  • Conduct regular reviews and audits on the organization's information assets, including annual reviews and penetration tests for customer-facing and internet-facing services.
  • Ensure physical security through measures like entry controls, monitoring, protection of data centers and data rooms, and safeguarding of information assets during the lifecycle.
  • Formulate and enforce an identity and access management policy, periodically evaluating its effectiveness through analytics or system logs.
  • Develop and implement standards for application and infrastructure security, change management, and secure disposal, regularly evaluating and monitoring the compliance and effectiveness of these standards.

SAMA CSF: Key subcategories to consider

SAMA CSF control Code definition Compliance recommendations
1.3.3 Asset Management The member organization should define, approve, implement, communicate, and monitor an asset management process, which supports an accurate, up-to-date, and unified asset register.
  • A comprehensive inventory of all information assets should be maintained.
  • Utilize software solutions, such as IT asset management tools, to automate the inventory process and track each asset's lifecycle.
1.3.5 Identity and Access Management The member organization should restrict access to its information assets in line with their business requirements based on the need-to-have or need-to-know principles.
  • Implement role-based access control (RBAC), assigning minimum necessary permissions, and limiting the duration of access to improve cyber security and minimize potential data breach impact.
  • Implement just-in-time (JIT) access control, granting necessary privileges only for a certain period when required.
1.3.6 Application Security The member organization should define, approve, and implement cyber security standards for application systems.
  • Cyber security standards should be established and implemented for all application systems.
  • Regular penetration testing should be conducted to identify any potential security flaws.
1.3.8 Infrastructure Security The member organization should define, approve, and implement cyber security standards for their infrastructure components.
  • Implement full-disk encryption for all storage devices to protect data at rest.
  • Implement network segmentation to limit the impact of a potential breach.
  • Use cloud access security brokers (CASBs) to enforce security policies on cloud-based infrastructure components.
  • Establish and implement cyber security standards specifically for payment systems.
1.3.12 Payment Systems The member organization should define, approve, implement, and monitor a cyber security standard for payment systems.
  • Integrate artificial intelligence (AI) and machine learning (ML) systems to detect and prevent payment fraud.
  • Conduct regular audits to monitor compliance and measure effectiveness.
  • Implement tokenization or encryption for sensitive payment data.
  • Implement a defined security event management process.
1.3.14 Cyber Security Event Management The member organization should define, approve, and implement a security event management process to analyze operational and security loggings.
1.3.16 Threat Management The member organization should define, approve, and implement a threat intelligence management process to identify, assess, and understand threats.
  • Employ multiple reliable sources for threat identification and assessment.
  • Integrate threat intelligence with other security controls like firewalls and IDS to block known threats automatically.
  • Implement a vulnerability management process for application and infrastructure.
  • Implement advanced threat detection systems like user and entity behavior analytics (UEBA) to detect abnormal behavior patterns.
1.3.17 Vulnerability Management The member organization should define, approve, and implement a vulnerability management process for the identification and mitigation of vulnerabilities.
  • Implement a patch management process to regularly apply necessary patches and updates.
  • Conduct red team exercises to simulate real-world attack scenarios and test the effectiveness of your vulnerability management process.

Comply with the SAMA CSF using EventLog Analyzer

ManageEngine’s EventLog Analyzer, an IT compliance and event log management solution, is well-equipped to support compliance with the SAMA CSF. EventLog Analyzer provides the required capabilities to identify, analyze, respond, monitor, and review cyber security risks, thereby strengthening the security posture of the organization in line with SAMA CSF regulations.

Under the SAMA CSF control, Cyber Security Incident Management (3.3.15), EventLog Analyzer effectively ensures timely identification and handling of cyber security incidents. It does so by providing comprehensive Network Device Logon Reports and Network Device Attack Reports, offering insights into the system's activities. This way, it can quickly identify anomalous or suspicious events, significantly reducing the potential business impact.

Moreover, for Threat Management (3.3.16), EventLog Analyzer leverages comprehensive threat intelligence feeds from trusted vendors such as Symantec, FireEye, Malwarebytes, and McAfee. These feeds provide the member organization with a thorough understanding of the emerging threat posture, essential for preventing potential breaches.

EventLog Analyzer also supports compliance with other key areas of the SAMA CSF, like Identity and Access Management (3.3.5) by providing detailed logon reports to ensure only authorized and sufficient access privileges are provided to approved users. For Application Security (3.3.6) and Change Management (3.3.7), it enables monitoring and management of changes in information assets and applications within the member organization.

Furthermore, it facilitates Infrastructure Security (3.3.8), Payment Systems (3.3.12), and Vulnerability Management (3.3.17) compliance through exhaustive logon, attack, and configuration reports. EventLog Analyzer also enables timely identification and effective mitigation of application and infrastructure vulnerabilities through integration with vulnerability assessment tools like Nessus, Nexpose, Qualys, Nmap, and OpenVAS.

Utilizing EventLog Analyzer can not only help achieve SAMA CSF compliance but also strengthen an organization's overall cyber security posture. It provides a streamlined, comprehensive, and user-friendly solution for managing cyber security risks and ensuring regulatory compliance.