Standards Comparison

    MAS TRM

    Mandatory
    2021

    Singapore guidelines for financial technology risk management

    VS

    CIS Controls

    Voluntary
    2021

    Prioritized cybersecurity framework reducing common attack risks

    Quick Verdict

    MAS TRM provides supervisory guidance for Singapore FIs' technology risk governance and cyber resilience, while CIS Controls offer prioritized global cybersecurity safeguards. FIs adopt MAS TRM for regulatory compliance; all orgs use CIS for practical hygiene and risk reduction.

    Technology Risk Management

    MAS TRM

    Technology Risk Management Guidelines January 2021

    Cost
    €€€€
    Complexity
    Medium
    Implementation Time
    12-18 months
    Cybersecurity

    CIS Controls

    CIS Critical Security Controls v8.1

    Cost
    €€€
    Complexity
    Medium
    Implementation Time
    12-18 months

    Key Features

    • 18 prioritized controls with 153 actionable safeguards
    • Implementation Groups IG1-IG3 for maturity scaling
    • Technology-agnostic, hybrid/cloud-focused best practices
    • Detailed mappings to NIST, PCI DSS, HIPAA frameworks
    • CIS Benchmarks and tools for automated assessment

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    MAS TRM Details

    What It Is

    MAS Technology Risk Management (TRM) Guidelines (January 2021) are supervisory guidance issued by the Monetary Authority of Singapore for financial institutions. They provide a principles-based framework for governing technology and cyber risks, emphasizing proportional implementation based on risk profile, service complexity, and technology used to ensure CIA triad (confidentiality, integrity, availability).

    Key Components

    • 15 main sections covering governance, risk frameworks, secure development, IT operations, resilience, access controls, cryptography, data security, cyber operations, assessments, online services, and audit.
    • Synthesized 12 core principles like board accountability, asset classification, third-party oversight, security-by-design.
    • Defence-in-depth approach with continuous monitoring and independent assurance; no fixed control count but minimums like annual staff training and pen testing.

    Why Organizations Use It

    Financial institutions adopt MAS TRM for regulatory supervision, avoiding fines/enforcement (e.g., S$27M AML penalties). It enhances resilience, customer trust, and enables secure digital transformation amid cyber threats.

    Implementation Overview

    Risk-based rollout starts with board-approved appetite, asset inventories, control mapping. Applies to all MAS-supervised FIs proportionally; involves governance setup, testing regimes, third-party diligence. No formal certification but MAS examines observance via inspections.

    CIS Controls Details

    What It Is

    CIS Critical Security Controls (CIS Controls) v8.1 is a community-driven, prescriptive cybersecurity framework of prioritized best practices to reduce cyber risks. It focuses on actionable safeguards across hybrid and cloud environments, using a risk-based, implementation-group approach for scalability.

    Key Components

    • 18 Controls with 153 Safeguards, organized into Implementation Groups (IG1–IG3) for maturity levels.
    • Core principles: asset inventory, vulnerability management, logging, incident response.
    • No formal certification; self-assessed compliance via tools like CIS RAM.

    Why Organizations Use It

    • Mitigates 85% of common attacks, accelerates regulatory compliance (NIST, PCI DSS, HIPAA).
    • Delivers ROI via reduced breach probability, operational efficiency, insurance discounts.
    • Builds stakeholder trust, supports contractual requirements, competitive differentiation.

    Implementation Overview

    • Phased roadmap: governance, discovery, foundational controls, expansion, assurance.
    • Key activities: asset inventories, automated scanning, training, metrics tracking.
    • Applicable to all sizes/industries; IG1 for SMBs, IG3 for enterprises.

    Key Differences

    Scope

    MAS TRM
    Technology risk governance, cyber resilience, third-party in financial sector
    CIS Controls
    18 prioritized cybersecurity safeguards across all assets and environments

    Industry

    MAS TRM
    Singapore financial institutions (FIs), proportional by risk/complexity
    CIS Controls
    All industries worldwide, scaled by Implementation Groups IG1-IG3

    Nature

    MAS TRM
    Supervisory guidance, non-binding but considered in MAS supervision
    CIS Controls
    Voluntary best practices framework, community-driven consensus safeguards

    Testing

    MAS TRM
    Annual pen testing for internet-facing systems, DR tests, cyber exercises
    CIS Controls
    Continuous vulnerability scans, pen testing per IG, asset inventories

    Penalties

    MAS TRM
    Supervisory actions, fines, license conditions via MAS enforcement
    CIS Controls
    No direct penalties, reputational/insurance impacts from non-adoption

    Frequently Asked Questions

    Common questions about MAS TRM and CIS Controls

    MAS TRM FAQ

    CIS Controls FAQ

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