I have colleagues across the US and International financial systems... Per a colleague the SWIFT system is critical and some users do not even have cyber controls in
place and even with patches in place malware can still bypass processes.
Industry best practices and standards along with vigilance maintenance thereof are essential; I am not sure if DHS is a replacement for the industry with its attempts...
Thomas Ward, LSE MSc. Transitional Economics
AML/CFT&FCPA, PMP, PPP(P3)/PBI/PFIs, & Systems
International Business Driver & Mentor - Sr. Advisor & Strategic Financial Economist International Development -- Agriculture, Global Banking & Capital Markets, Extraction Industries