ISO 37301
International certifiable standard for compliance management systems
23 NYCRR 500
NY regulation for financial services cybersecurity.
Quick Verdict
ISO 37301 offers certifiable CMS for global compliance culture; 23 NYCRR 500 mandates cybersecurity for NY finance. Firms adopt ISO for broad risk management, NYCRR to avoid fines and meet regulatory demands.
ISO 37301
ISO 37301:2021 Compliance management systems – Requirements
Key Features
- Certifiable requirements replacing guidance-only ISO 19600
- High-Level Structure enables integration with other ISO standards
- Risk-based compliance obligation identification and planning
- Leadership commitment fosters compliance culture and resources
- Mandatory whistleblowing channels with anti-retaliation protections
23 NYCRR 500
23 NYCRR Part 500 Cybersecurity Regulation
Key Features
- Annual CISO/CEO dual compliance certification
- 72-hour cybersecurity incident notification
- Phishing-resistant MFA for high-risk access
- Third-party service provider security policy
- Risk-based annual penetration testing
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
ISO 37301 Details
What It Is
ISO 37301:2021 is a certifiable international standard specifying requirements with guidance for establishing, implementing, maintaining, and improving Compliance Management Systems (CMS). It applies to organizations of all sizes and sectors, using a risk-based approach via the Plan-Do-Check-Act (PDCA) cycle and High-Level Structure (HLS) for integration.
Key Components
- Core clauses: context, leadership, planning, support, operation, performance evaluation, improvement.
- Emphasizes leadership commitment, compliance culture, risk assessment, whistleblowing protections, internal audits, and continual improvement.
- Built on HLS; supports companion standards like ISO 37302 for measurement.
- Certification model via accredited bodies (e.g., ANAB) with three-year cycles.
Why Organizations Use It
- Drives risk reduction, regulatory compliance, and stakeholder trust.
- Provides third-party assurance for investors, partners; enhances reputation.
- Mitigates fines, litigation; supports ESG/SDGs (e.g., 8,16).
- Competitive edge through demonstrated integrity and efficiency.
Implementation Overview
- Phased: secure leadership buy-in, map obligations, build register, train, audit.
- Scalable for SMEs to enterprises; integrates with IMS.
- Certification optional but via accredited auditors; ongoing surveillance required.
23 NYCRR 500 Details
What It Is
23 NYCRR Part 500 is the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, a state-level mandate effective March 2017 with 2023 amendments. It establishes prescriptive, risk-based cybersecurity requirements for financial services entities to protect nonpublic information (NPI) and information systems. The approach emphasizes governance, evidence-based outcomes, and rapid incident response.
Key Components
- 14 core requirements including cybersecurity program, CISO governance, MFA, encryption, asset inventory, TPSP oversight, penetration testing, and 72-hour incident notification.
- Built on risk assessments using frameworks like NIST CSF; annual dual CISO/CEO certification with 5-year record retention.
- Class A companies face enhanced audits and controls; limited exemptions for small entities.
Why Organizations Use It
- Mandatory for NY-licensed financial entities (banks, insurers, etc.) to avoid multimillion-dollar fines (e.g., Robinhood $30M).
- Enhances resilience, reduces incident risk, builds stakeholder trust, and aligns with enterprise risk management.
Implementation Overview
- Phased roadmap: gap analysis, asset inventory, MFA rollout, TPSP contracts, testing; up to 24 months.
- Applies to NY financial services firms; no external certification but DFS examinations and annual filings required. (178 words)
Key Differences
| Aspect | ISO 37301 | 23 NYCRR 500 |
|---|---|---|
| Scope | Compliance obligations, risks, culture across all areas | Cybersecurity protections for NPI and systems |
| Industry | All sectors, global applicability | NY financial services entities only |
| Nature | Voluntary certifiable management standard | Mandatory regulation with enforcement |
| Testing | Internal audits, management reviews annually | Annual pen testing, vulnerability scans |
| Penalties | Loss of certification, no fines | Multi-million dollar fines, consent orders |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about ISO 37301 and 23 NYCRR 500
ISO 37301 FAQ
23 NYCRR 500 FAQ
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