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A Deep Dive into DORA's Threat-Led Penetration Testing Requirements

Welcome back to my blog series on DORA regulation !!!

In this blog, I will dive into the specific topic of Threat-Led Penetration Testing (TLPT).

Key Players in the TLPT Ecosystem:

Understanding the roles involved in TLPT is crucial. Here’s a quick rundown:

  1. Red Team: These are the attackers in the simulation, employing tactics, techniques, and procedures (TTPs) that real adversaries would use. They aim to uncover weaknesses in the organization's defenses.
  2. Blue Team: These defenders are responsible for detecting and responding to the simulated attacks. They bring business context and architectural familiarity to the exercise.
  3. White Team: This control group oversees the exercise, ensuring it stays on track and providing necessary hints to the Red Team to keep the simulation moving.
  4. Purple Team: This team collaborates with both Red and Blue teams to improve overall security posture by aligning detection and response strategies with real-world threats.

TLPT vs. Traditional Penetration Testing:

While both TLPT and traditional penetration testing are vital, they serve different purposes. Penetration tests evaluate the security of specific technologies (like websites or cloud infrastructure), whereas TLPT assesses the Blue Team's ability to detect and respond to simulated attacks.

The TLPT Process Under DORA:

The TLPT process is methodical and structured. Here’s a high-level overview:

  1. Initiation: Establishing the control team, defining scope, and setting flags (key objectives).
  2. Preparation: Procuring Threat Intelligence (TI) and Red Team (RT) providers, developing a risk management plan, and setting up the testing framework.
  3. Targeted Threat Intelligence: Producing a detailed TI report that informs the Red Team's attack strategies based on actual threat actors and their motivations, targets, and TTPs.
  4. Red Team Test: Executing the simulated attacks over a minimum 12-week period, with continuous monitoring and adjustment.
  5. Reporting and Closure: Compiling a comprehensive report, including timelines of events, specific TTPs used, and metrics on Blue Team performance. This phase also includes developing a remediation plan based on the findings.

Comparing TIBER and DORA TLPT:

The TLPT framework under DORA shares similarities with the TIBER-EU framework but with distinct differences:

  1. Scope: DORA TLPT is mandatory and regulated by EU authorities, while TIBER is voluntary and varies by country.
  2. Reporting: DORA requires results to be sent to regulators, whereas TIBER results are kept within the entity.
  3. Control: Under DORA, the TLPT authority decides the testing period, ensuring a more standardized approach across the EU.

Why TLPT Matters ?

TLPT provides financial institutions with a realistic assessment of their operational resilience. By simulating sophisticated attacks, institutions can identify and address their vulnerabilities, ultimately strengthening their defenses against actual threats. This proactive approach is crucial in a digital age where cyber threats are ever-evolving.

Looking Ahead,

As financial institutions continue to adapt to these regulatory changes, investing in TLPT will be crucial. This means not only preparing for these rigorous tests but also continuously improving detection and response capabilities. The goal is to ensure that when real threats arise, institutions are not just compliant but truly resilient.

Stay tuned for the next installment in the DORA series, where we will delve deeper into the practical steps financial institutions can take to prepare for TLPT and enhance their overall operational resilience.


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