The World Federation of Exchanges (“WFE”), the global industry group for exchanges and CCPs, has today responded to the ECB’s consultation on Cyber Resilience Oversight Expectations (CROE) for Financial Market Infrastructures (FMIs).
1. Governance
The WFE and its members share the views of the ECB on the importance of having effective arrangements in place to establish, implement and review their approach to managing cyber risk. The WFE believes that FMIs should be able to work on their own cyber resilience strategies, in a flexible way, recognising the different scales, business focuses and cultures within each institution.
The role of the board and senior management in the area of cyber resilience has increased, with Chief Information Security Officers (CISOs) now routinely briefing their Boards on recent developments and of the level of preparedness. The WFE’s view differs to the ECB’s on the topics of formal Cyber Code of Conduct, however, and suggests that cyber should instead be included in the overall FMI’s Code of Conduct.
2. Identification
The industry agrees that identification is a key component of…
