Domain: Information
Question:
After a failed audit, you discover the fraud org has years of "temporary" access that never got rolled back. Fraud analysts, automation pipelines, service accounts, and vendor tools now have broad access across customer identity data, case-management systems, transaction monitoring, and even internal detection logic. Leadership wants least privilege without slowing fraud operations. Design a governance model that fixes privilege creep and still lets humans and automation work fast. Make sure your approach covers account lifecycle and access reviews (AC-2), least-privilege boundaries and role design (AC-6), and strong authentication expectations for users and non-human identities (IA-2). Then explain how you would keep access from drifting over time and catch abuse using configuration enforcement (CM-6) and logging requirements (AU-12).

Expected points in a correct answer:
States that CP-2 (Contingency Planning) must establish recovery objectives tied to fraud detection uptime
States that contingency plans must prioritize critical operations for restoration over non-critical ones
Recommends that contingency planning involve all related teams to ensure comprehensive coverage of affected systems and assigned responsibilities.
Recommends identifying and flagging critical assets
Recommends performing capacity planning to verify that telecom and environmental resources can support the demands of contingency operations.
States that AWS services such as EC2 instances and S3 buckets are natively replicated across multiple Availability Zones, simplifying backup implementation.
States that CP-9 requires protecting fraud models, customer risk datasets, alert telemetry, and detection pipelines with backups
States that organizations not leveraging AWS must ensure backups are implemented with explicitly defined recovery time objectives and recovery point objectives per CP-9.
States that backup solutions must maintain high availability to ensure they remain accessible when needed during a recovery event.
States that CP-10 (System Recovery) mandates that organizations define and test restoration procedures so fraud detection services can be rapidly reinstated without relying on unverified backups.
Recommends periodically re-testing and verifying restoration capabilities to confirm backup recoverability remains effective as systems and configurations evolve.
Recommends consulting applicable security or compliance frameworks when defining the cadence for CP-10 restoration testing to align with regulatory expectations.
States that a mature resilience strategy includes an up-to-date incident response procedure that is understood and known by all affected parties before an incident occurs.
States that the incident response procedure must define immediate actions, scoping, and individual responsibilities for responding to an incident.
States that IR-4 (Incident Handling) should guide coordinated response to ransomware events such as fraud-impact assessment, containment, and restoration prioritization
Recommends defining the appropriate level of isolation or containment scope for each identified critical asset as part of incident response planning.
Recommends ensuring networks are properly segmented and locked down before ransomware has an opportunity to move laterally within the environment.
Recommends removing unnecessary ports and access as a preventive measure to reduce the attack surface available for initial access by malicious actors.
Recommends deploying proper firewalls as a preventive control to restrict unauthorized network-level traffic from reaching internal systems.
States that SC-7 (Boundary Protection) reduces external attack paths by enforcing network segmentation and strictly regulating traffic between network segments.
States that SC-7 regulates inter-network traffic based on direction, port, data volume, protocol, and time as traffic-control parameters.
States that SI-3 (Malware Protection) mechanisms must detect and block malicious payloads before fraud infrastructure becomes compromised.
Recommends deploying endpoint detection and response software to halt runtime execution of malicious processes and isolate malicious files if malware reaches endpoint devices.
Recommends defining and documenting RTO and RPO thresholds individually for each fraud-critical system to reflect differing service criticality levels in recovery prioritization.
Recommends conducting tabletop exercises that simulate ransomware scenarios to validate IR-4 procedures and confirm all personnel understand their response roles before a real incident occurs.
Recommends implementing network micro-segmentation for fraud detection infrastructure to limit the blast radius of a ransomware compromise to isolated network zones in support of SC-7.
Recommends maintaining offline or air-gapped copies of critical backups to ensure ransomware cannot encrypt backup data that is reachable via the same network path as production systems.
Recommends establishing a stakeholder communication plan within the IR-4 procedure that defines how and when internal and external parties are notified during a ransomware incident.
Recommends maintaining an up-to-date asset inventory integrated with the contingency plan so recovery teams can locate and prioritize critical systems without delay during an incident.
States that CP-2 (Contingency Planning) must establish recovery objectives tied to transaction-monitoring latency
States that CP-2 (Contingency Planning) must establish recovery objectives tied to acceptable data-loss thresholds
States that contingency plans must include a defined timeline for restoring all operations.
Recommends preparing alternate sites and assets to support continuity of operations.
Recommends using immutable or segmented backups to prevent ransomware tampering per CP-9
States that an incident response plan should be in place as part of the overall resilience strategy.
States that backups should be created of critical systems and reviewed for effectiveness as part of the resilience strategy.