Future-Proofing Cybersecurity: Shifting from FFIEC CAT to NIST CSF 2.0

In August 2024, the Federal Financial Institutions Examination Council (FFIEC) announced its decision to sunset the Cybersecurity Assessment Tool (CAT) on August 31, 2025. Here’s how cybersecurity leaders in financial institutions can prepare for the FFIEC CAT sunset, including guidance on transitioning to the National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF) 2.0. 

Introduced in 2015, the CAT was designed to help financial institutions identify and assess their cybersecurity risks and preparedness. However, as the cybersecurity landscape has evolved, NIST CSF 2.0 has become the preferred alternative. 

Understanding NIST CSF 2.0 

Released in February 2024, NIST CSF 2.0 is a flexible and comprehensive framework designed to manage cybersecurity risks across industries, including the financial sector. 

Key Components of NIST CSF 2.0 

1. CSF Core: Organized into six primary functions: 
   • Govern: Establishing cybersecurity governance 
   • Identify: Understanding risks to systems and data 
   • Protect: Implementing safeguards 
   • Detect: Identifying cybersecurity events 
   • Respond: Taking action against threats 
   • Recover: Restoring capabilities after an incident 
2. Implementation Tiers: Ranging from Tier 1 (Partial) to Tier 4 (Adaptive), these levels help organizations assess their cybersecurity maturity. 
3. Profiles: Organizations create a Current Profile and a Target Profile to track cybersecurity improvements. 

Comparing FFIEC CAT and NIST CSF 2.0 

Mapping FFIEC CAT to NIST CSF 2.0 

To facilitate the transition, organizations can leverage existing mappings between FFIEC CAT and NIST CSF. The FFIEC provides a detailed mapping in Appendix B of the CAT documentation, aligning CAT components with NIST CSF categories.  

Steps to Transition from FFIEC CAT to NIST CSF 2.0 

Transitioning from FFIEC CAT to the NIST CSF 2.0 involves a structured approach: 

1. Conduct a Gap Analysis – Identify differences between current cybersecurity practices and NIST CSF 2.0. 
2. Map Existing Assessments to NIST CSF 2.0 – Use available mappings to align FFIEC CAT components with NIST CSF categories. 
3. Develop an Implementation Roadmap – Outline steps, timelines, and responsibilities for integrating NIST CSF 2.0. 
4. Engage Stakeholders – Communicate the benefits of NIST CSF 2.0 to executives and staff. 
5. Train Personnel – Provide training on NIST CSF 2.0 principles. 
6. Monitor and Review Progress – Establish metrics for continuous improvement. 

Leveraging Additional Resources 

Incorporating supplementary resources can enhance cybersecurity posture and ensure comprehensive risk management. Notably: 

• Cybersecurity Performance Goals (CPGs) from the Cybersecurity and Infrastructure Security Agency (CISA) 
• Cyber Risk Institute (CRI) Profile  

Benefits of Integrating CPGs and the CRI Profile 

• Enhanced Risk Management: Structured approaches tailored to the financial sector 
• Regulatory Alignment: Meeting regulatory expectations by aligning practices with recognized standards 
• Resource Optimization: Prioritized actions for significant risk reduction 

Benefits of Adopting NIST CSF 2.0 

Transitioning to NIST CSF 2.0 offers financial institutions several advantages: 

• Enhanced Governance Integration: Embeds cybersecurity into organizational governance and risk management processes 
• Improved Supply Chain Risk Management: Ensures adequate cybersecurity measures across the entire ecosystem 
• Flexibility and Scalability: Tailors cybersecurity programs to unique risk profiles and regulatory requirements 
• Regulatory Alignment: Supports strong cybersecurity controls and risk management processes as the FFIEC CAT sunsets 

By understanding the benefits of NIST CSF 2.0 and aligning with regulatory expectations, financial institutions can strengthen their cybersecurity posture and ensure compliance in an evolving threat landscape. 

How Sikich Can Assist in Transitioning to NIST CSF 2.0 

Sikich offers tailored services to support your transition to NIST CSF 2.0. Our expertise includes: 

• Conducting comprehensive gap analyses 
• Developing strategic implementation roadmaps 
• Providing staff training on NIST CSF 2.0 principles 

By partnering with Sikich, your organization can align its cybersecurity program with current industry standards and regulatory expectations. 

Contact Sikich today to begin your transition to NIST CSF 2.0 and secure your organization’s future.