Compliance & Audit Services

FFIEC – SOX – GLBA Advisory

  • May 8, 2025
  • 0

Sherlocked Security – FFIEC / SOX / GLBA Advisory

Advisory and Readiness Services for Financial Institutions’ Compliance

1. Statement of Work (SOW)

Service Name: FFIEC / SOX / GLBA Advisory
Client Type: Financial Institutions, Banks, Credit Unions, Investment Firms, Insurers
Service Model: Advisory Services, Gap Analysis, Risk Assessment, Compliance Roadmap, Audit Preparation
Compliance Coverage: FFIEC Cybersecurity Assessment, SOX (Sarbanes-Oxley), GLBA (Gramm-Leach-Bliley Act), NIST Cybersecurity Framework, SOC 1 & 2

Assessment Types:

  • Financial and Operational Control Assessments
  • SOX 404 Compliance Audits
  • GLBA Privacy & Data Protection Review
  • FFIEC Cybersecurity Assessment
  • IT Risk Management and Internal Control Evaluation

2. Our Approach

[Regulatory Mapping] → [Compliance Gap & Control Maturity Assessment] → [Risk & Impact Evaluation] → [Advisory & Remediation Recommendations] → [Compliance Documentation Review] → [Audit Readiness Support] → [Post-Advisory Continuous Monitoring]

3. Methodology

[FFIEC/SOX/GLBA Regulatory Mapping] → [Internal Control and Risk Management Analysis] → [Compliance Gap & Control Maturity Assessment] → [SOX & GLBA Risk Evaluation] → [Recommendations & Remediation Roadmap] → [Audit Readiness & Documentation Support]

4. Deliverables to the Client

  1. FFIEC Cybersecurity Compliance Report
  2. SOX 404 Internal Control Assessment & Remediation Report
  3. GLBA Privacy & Security Controls Gap Analysis
  4. Risk Management & IT Governance Documentation
  5. Advisory Roadmap for Compliance Remediation
  6. SOX and GLBA Audit Readiness Documentation
  7. Compliance Monitoring & Continuous Improvement Plan
  8. Final Report and Executive Summary

5. What We Need from You (Client Requirements)

  • Access to your internal controls and IT governance documentation
  • Previous audit reports (e.g., SOX, FFIEC, GLBA)
  • Access to cybersecurity and risk management policies
  • Access to financial statements and control documentation for SOX
  • Information about critical data and privacy protection measures under GLBA
  • Documentation of current risk management practices and incident response plans
  • NDA and Scope Confirmation

6. Tools & Technology Stack

  • SOX & Compliance Tools: AuditBoard, Workiva, VComply
  • Cybersecurity Tools for FFIEC Assessment: Qualys, Tenable, Rapid7
  • Risk Management Tools: RSA Archer, RiskWatch, LogicManager
  • Data Privacy & Protection Tools for GLBA: TrustArc, OneTrust, BigID
  • Internal Control Testing: IDEAL, Protiviti’s SOX 404 Workpaper Tool
  • Documentation & Workflow Management: Confluence, SharePoint, Microsoft Word/Excel

7. Engagement Lifecycle

1. Kickoff & Scope Definition → 2. Regulatory Mapping to SOX, GLBA, FFIEC → 3. Gap & Maturity Assessment → 4. Risk & Compliance Evaluation → 5. Remediation Recommendations & Roadmap → 6. Audit Preparation & Documentation Support → 7. Continuous Monitoring & Post-Advisory Support

8. Why Sherlocked Security?

Feature Sherlocked Advantage
Regulatory Expertise In-depth knowledge of SOX, GLBA, and FFIEC requirements and controls.
Comprehensive Gap & Control Maturity Assessment Thorough evaluation of financial controls and cybersecurity policies.
Risk & Privacy Compliance Advisory Practical advice on risk management, privacy policies, and cybersecurity measures.
SOX & GLBA Audit Preparation Full support in preparing for SOX and GLBA audits, ensuring readiness.
Continuous Compliance Monitoring Ongoing support to track and manage regulatory compliance.

9. Real-World Case Studies

SOX 404 Compliance for a Financial Institution

Issue: A large financial institution faced difficulties meeting SOX 404 compliance standards for internal controls over financial reporting.
Impact: Non-compliance could result in SEC sanctions, loss of investor confidence, and internal control failures.
Solution: Sherlocked Security conducted a detailed SOX 404 audit readiness assessment, identified weaknesses in internal control frameworks, and developed a roadmap for remediation.
Outcome: The institution achieved SOX 404 compliance on time, with robust internal controls in place, avoiding penalties and ensuring continued investor confidence.

FFIEC Cybersecurity Assessment for a Regional Bank

Issue: A regional bank lacked a formal cybersecurity framework aligned with FFIEC’s guidelines, increasing exposure to cyber threats.
Impact: Potential exposure to data breaches, financial fraud, and regulatory penalties.
Solution: Sherlocked Security performed a comprehensive FFIEC Cybersecurity Assessment, helping the bank implement robust security measures, improve incident response plans, and establish ongoing monitoring practices.
Outcome: The bank successfully improved its cybersecurity posture, aligning with FFIEC standards and mitigating the risk of cyber threats.

10. SOP – Standard Operating Procedure

  1. Kickoff & Scope Definition

    • Define the engagement scope, focusing on specific FFIEC, SOX, or GLBA compliance requirements.
    • Identify key stakeholders and areas of compliance to focus on (e.g., internal controls, risk management, privacy protections).

  2. Regulatory Mapping & Compliance Assessment

    • Map existing security, financial, and privacy controls to SOX, FFIEC, and GLBA frameworks.
    • Perform a gap analysis to identify areas of non-compliance or underperformance.
    • Evaluate internal control structures for SOX 404 and assess cybersecurity policies for FFIEC.

  3. Risk Management & Privacy Evaluation

    • Evaluate existing risk management processes, including incident response plans, threat detection, and financial reporting.
    • Assess the protection of sensitive financial and personal data, ensuring compliance with GLBA.
    • Identify risks related to data privacy and cybersecurity across the organization.

  4. Remediation Planning & Advisory Roadmap

    • Develop a remediation roadmap to address identified compliance gaps.
    • Advise on process improvements to enhance internal controls, risk management, and privacy protection.
    • Assist in the design of new controls or the refinement of existing controls to meet regulatory standards.

  5. Audit Preparation & Documentation Support

    • Assist in preparing the necessary documentation for SOX, FFIEC, or GLBA audits.
    • Ensure internal control testing is robust and aligns with audit requirements.
    • Provide templates and guidance for compliance reports, policies, and risk assessments.

  6. Continuous Monitoring & Compliance Tracking

    • Establish mechanisms for continuous monitoring of compliance status.
    • Provide ongoing advisory support to address emerging risks and changes in regulatory requirements.
    • Help track and ensure continuous adherence to regulatory standards and frameworks.

11. FFIEC / SOX / GLBA Advisory Checklist

1. Regulatory Mapping & Compliance Assessment

  • Map internal controls to SOX 404 requirements (e.g., financial reporting, internal controls).
  • Align cybersecurity policies with FFIEC’s Cybersecurity Assessment Tool (CAT).
  • Review privacy controls and ensure compliance with GLBA requirements (e.g., information security program, privacy notices).

2. Internal Control Assessment (SOX 404)

  • Evaluate controls over financial reporting (e.g., segregation of duties, authorization processes).
  • Test effectiveness of control activities and financial transaction approvals.
  • Assess accuracy of financial statements and reporting procedures.

3. Cybersecurity Controls for FFIEC

  • Assess the bank’s cybersecurity risk management framework.
  • Review network security, access controls, and vulnerability management practices.
  • Evaluate incident response capabilities and alignment with FFIEC guidelines.

4. Privacy & Data Protection for GLBA

  • Ensure the bank has a written information security program in place.
  • Review data collection, storage, and sharing practices for compliance with GLBA.
  • Implement policies to safeguard nonpublic personal information (NPI).

5. Risk Management & Monitoring

  • Evaluate overall enterprise risk management practices and tools.
  • Review incident response plans, including breach detection and reporting.
  • Monitor for ongoing regulatory changes and adapt controls accordingly.

6. Documentation & Audit Readiness

  • Ensure proper documentation of internal controls and risk assessments.
  • Develop detailed action plans (POA&Ms) to address gaps in compliance.
  • Prepare supporting materials for audits, including compliance reports and risk management frameworks.

7. Continuous Compliance Monitoring

  • Implement continuous risk and compliance monitoring tools.
  • Develop tracking systems for ongoing adherence to SOX, GLBA, and FFIEC standards.
  • Provide ongoing support for internal control and privacy policy updates.
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