GRC Case Study: Tier-1 Bank Exceeds Digital Asset Compliance
About the Customer
The client is a major, publicly-listed commercial bank in Southeast Asia. The institution operates under a strict regulatory framework mandated by the region's central bank, requiring rigorous proof of compliance for all customer-facing financial technology.
| Category | Details |
|---|---|
| Industry | Banking & Financial Services |
| Challenge | Achieving and, more critically, quantifiably proving 100% compliance for a portfolio of flagship digital finance applications against a complex, 80+ point regulatory mandate. |
| Solutions Used | GRC Compliance Assessment, Penetration Testing, Secure SDLC Review, Mobile Application Security Assessment |
The Challenge: Quantifying Compliance as a Core Business Asset
Today, financial institutions understand that regulatory compliance is more than just an IT challenge; it directly impacts market valuation and is a cornerstone of shareholder confidence. For this client, the "cost of non-compliance"—including systemic fines, operational shutdown, and reputational damage—represented a significant material risk.
The bank's board required independent, quantitative validation of its two flagship digital assets (its core mobile banking app and its digital wallet app) against the Central Bank's "Minimum Compliance Standards for Payment-Related Mobile Applications." This framework dictates over 80 mandatory controls across more than 20 clauses, setting a high bar for technical and procedural governance.
The bank's challenge was threefold:
Validate Compliance: Quantify its adherence to 100% of the 80+ mandatory controls.
Identify Residual Risk: Discover "unknown-unknowns" or gaps between the controls that could be exploited.
Future-Proof the Asset: Move beyond baseline compliance to build a proactive security posture that anticipates the next generation of threats.
The AKATI Sekurity Solution: An Adversarial GRC Assessment
AKATI Sekurity was engaged to perform an exhaustive GRC (Governance, Risk, and Compliance) audit. This was not a passive documentation review. We treated the regulatory framework as an attack vector, running parallel technical assessments (penetration testing, code review) and procedural audits (interviews, documentation analysis) to stress-test the bank's compliance claims.
Our analysis mapped the bank's multi-layered defense stack (including SIEM, 24/7 SOC, network behavior analytics, WAFs, and secure coding practices) against every clause of the regulatory mandate.
Quantitative Compliance & Risk Posture Analysis
The audit concluded that the bank's digital application portfolio achieved full compliance across all 80+ mandatory controls—a "best-in-class" result. This score demonstrates a robust, mature GRC program.
Chart 1: Regulatory Compliance Status vs. Mandated Controls
Compliance Achievement
All 80+ mandatory controls validated as compliant across the entire regulatory framework
Table 1: Domain-Level Compliance Scorecard (Selected Domains)
Our analysis validated compliance across all 20+ clauses. The bank demonstrated exceptional maturity in foundational "cost-of-entry" domains, which are common failure points for less mature institutions.
| GRC Domain | Key Mandated Controls | Compliance Status | Analyst Assessment |
|---|---|---|---|
| Authentication & Device Registration |
|
Compliant | Robust. MFA is enforced using PINs, OTPs, and device identifiers. Account lockout procedures are in place and tested. |
| Data Protection & Cryptography |
|
Compliant | Excellent. Sensitive data is stored in secure OS enclaves (Keychain/Keystore) and encrypted. Strong, industry-standard algorithms are used. |
| Secure SDLC & Application Integrity |
|
Compliant | Mature. The CI/CD pipeline integrates static code analysis (SAST) and strong runtime protections (RASP) to prevent tampering and reverse engineering. |
| Session & Server-Side Security |
|
Compliant | Strong. Defense-in-depth is evident, with hardened servers, WAFs, and strict access controls via bastion hosts. |
| Governance & Operations |
|
Compliant | Mature. All governance-level controls are documented, reviewed annually, and integrated into the operational and BCP framework. |
Analyst Insight: Moving from Baseline Compliance to Proactive Defense
Achieving 100% compliance is not the end of the risk management journey; it is the foundation. The regulatory framework represents the baseline—the known, historical risks.
Our key value determination was identifying areas of residual risk and opportunities for proactive security investment that look beyond the current mandate. While the bank was fully compliant, we provided strategic recommendations to hedge against future, more sophisticated attack vectors.
Table 2: Analysis of Proactive Investment Opportunities (Beyond Baseline)
This analysis moves the bank's posture from "Compliant" (the baseline) to "Optimized" (the future state).
| Area of Analysis | Baseline Compliant Control | Proactive Analyst Recommendation |
|---|---|---|
| 1. User Behavior Monitoring |
Clause 6: Authentication Logs are monitored for invalid login attempts and anomalies. |
Shift to AI-Driven Baselines: Evolve from static alerts (e.g., "5 failed logins") to dynamic behavioral monitoring. Flag anomalies like logins from new geolocations, unusual transaction patterns, or access at odd hours, indicating potential Account Takeover (ATO).
|
| 2. Network Threat Detection |
Clause 19: Server-Side Infrastructure Servers are hardened and network traffic is monitored. |
Activate Proactive Network Hunting: Leverage existing network tools (e.g., Darktrace) more aggressively. Move beyond monitoring ingress/egress traffic and actively hunt for subtle lateral movement inside the perimeter, indicative of an Advanced Persistent Threat (APT).
|
| 3. SOC Operations |
Clause 20: Logs and Data Leakage Logs are centralized in a segregated SIEM and reviewed. |
Evolve SOC from Reactive to Proactive: Transition the 24/7 SOC's primary function from reactive L1/L2 alert triage (responding to noise) to proactive L3/L4 threat hunting (actively searching for hidden, undetected threats).
|
| 4. Customer-Side Security |
Clause 26: User Awareness Security awareness materials are provided to developers and users. |
Implement Dynamic, In-App Nudging: Enhance user-facing security by providing real-time, in-app security tips and warnings. This hardens the "human firewall" at the point of transaction, directly reducing fraud risk.
|
Conclusion
This engagement validates the client's robust GRC posture, providing the board with quantitative, independent proof of 100% compliance against the 80+ point Central Bank mandate.
More importantly, our analysis provides a data-driven investment thesis for the next phase of their cybersecurity strategy. By shifting focus from baseline compliance to mitigating residual risk through proactive threat hunting and AI-driven behavioral analytics, the bank is positioning its digital assets to defend not just against today's regulations, but against tomorrow's threats.
Key Terms Explained:
GRC (Governance, Risk, and Compliance): The integrated strategy for managing an organization's overall governance, enterprise risk management, and compliance with regulations.
Regulatory Framework: A set of mandatory guidelines, rules, and laws issued by a governing body (e.g., a Central Bank) that financial institutions must follow.
SIEM (Security Information and Event Management): A technology solution that collects, aggregates, and analyzes log data from across the enterprise to detect threats.
MFA (Multi-Factor Authentication): A security control requiring users to provide two or more verification factors (e.g., a password and an OTP) to gain access.
Secure SDLC (Software Development Life Cycle): The process of integrating security testing and best practices into every phase of software development, from design to deployment.
References:
Central Bank of Sri Lanka (CBSL) Guideline No. 01/2020: Minimum Compliance Standards for Payment-Related Mobile Applications
PCI-DSS (Payment Card Industry Data Security Standard)
NIST Special Publication 800-53: Security and Privacy Controls for Information Systems
About the Author: This article was written by AKATI Sekurity's GRC and Financial Services risk specialists. Our team helps organizations in highly regulated sectors—including banking, finance, and fintech—navigate complex regulatory frameworks, quantify risk, and build resilient security programs across ASEAN and North America.
Related Services: GRC Compliance Assessment | Penetration Testing | Mobile Application Security | 24/7 Managed Security (MSSP)
