Financial Cybersecurity Compliance: Frameworks and Threat Modeling
The Role of Threat Modeling in Financial Compliance
Global regulations require financial institutions to proactively manage cyber risk, implement layered defenses, and demonstrate control effectiveness. Threat modeling is critical in meeting these expectations, often as a defined requirement within the development lifecycle.
ThreatModeler supports financial services organizations by aligning threat modeling practices with 180+ compliance standards. Our platform automates risk assessments, validates security controls, and generates audit-ready reports that scale across applications and cloud infrastructure.
Below, you’ll find summaries of major financial regulations—including where threat modeling is explicitly required or strongly recommended, how it supports secure-by-design mandates, and how ThreatModeler helps meet these requirements efficiently and at scale.
Geography: North America
NIST SP 800-53 Rev. 5 (2020) – United States
Description: Security and privacy controls for U.S. federal information systems and organizations.
Specifics: Includes specific requirements for threat modeling during system development and risk assessment.
Threat Modeling Alignment: Threat modeling is explicitly required in the development lifecycle. It helps identify potential attack vectors, threat agents, and security control requirements early in the engineering process.
As specified in the guidelines:
“Require the developer of the system, system component, or system service to perform threat modeling and vulnerability analyses during development and the subsequent testing and evaluation of the system, component, or service.” (SA-11(2))
“Examples of system security engineering principles include: developing layered protections; establishing sound security architectures; designing for least privilege and least functionality; performing threat modeling to identify use cases, threat agents, attack vectors and patterns, design patterns, and compensating controls needed to mitigate risk.” (SA-8)
FFIEC Cybersecurity Assessment Tool (2015) – United States
Description: Framework to help financial institutions evaluate their cybersecurity preparedness.
Specifics: Provides a structured assessment tool that supports incorporating threat modeling in mature programs.
Threat Modeling Alignment: Threat modeling is referenced as part of mature threat and vulnerability management processes.
As specified in the guidelines:
“Management has a formal process for identifying and prioritizing threats and vulnerabilities that includes the use of threat modeling.”
GLBA Safeguards Rule (Revised 2021) – United States
Description: U.S. regulation mandating safeguards for consumer financial information.
Specifics: Emphasizes risk-based security planning, testing, and monitoring of controls.
Threat Modeling Alignment: While threat modeling is not mentioned directly, the mandate to continuously monitor and evaluate the effectiveness of safeguards aligns with threat modeling principles.
As specified in the standard:
“Regularly test or otherwise monitor the effectiveness of the safeguards’ key controls, systems, and procedures.”
OSFI Guideline B-13 (Effective 2024) – Canada
Description: Guidelines for technology and cyber risk management by federally regulated financial institutions in Canada.
Specifics: Promotes risk-based planning and recommends specific tools like threat modeling.
Threat Modeling Alignment: Explicitly recommends using threat modeling as part of ongoing cyber defense measures.
As specified in the guidelines:
“FRFIs should develop and maintain threat intelligence capabilities to identify threats, understand attack vectors, identify vulnerabilities, and assess risks. They should safeguard classified data, engage in threat modeling and hunting, and consistently monitor and report on the organization’s cyber risk profile.”
Mexico Fintech Law (2018) – Mexico
Description: Regulation for secure and inclusive financial tech innovation.
Specifics: Requires institutions to manage and mitigate cybersecurity risks.
Threat Modeling Alignment: Although threat modeling is not named, the requirement to identify, measure, and mitigate risks reflects threat modeling processes.
As specified in the standard:
“Institutions must establish mechanisms to identify, measure, manage, and mitigate the risks to which they are exposed.”
Geography: United Kingdom
FCA SYSC Handbook – SYSC 13 (2023) – United Kingdom
Description: Rules for UK-regulated firms’ systems and controls.
Specifics: Requires management of IT system risks and operational resilience.
Threat Modeling Alignment: Requires firms to identify, manage, and mitigate threats to their IT and information systems, foundational to threat modeling.
As specified in the standard:
“A firm must take reasonable care to establish and maintain such systems and controls as are appropriate to its business… including effective ICT systems that manage vulnerabilities and detect threats.”
Geography: EMEA
DORA – Digital Operational Resilience Act (EU Regulation 2022/2554) – European Union
Description: EU regulation for improving the operational resilience of financial entities against ICT-related disruptions.
Specifics: Requires regular advanced testing informed by threat intelligence.
Threat Modeling Alignment: DORA supports threat modeling by requiring advanced testing based on threat scenarios and intelligence to identify vulnerabilities and systemic weaknesses.
As specified in the regulation:
“Financial entities shall undertake advanced testing of ICT tools, systems and processes based on threat intelligence and scenarios, which simulate real-life threat scenarios…”
EBA Guidelines on ICT Risk (EBA/GL/2019/04) – European Union
Description: Guidelines by the European Banking Authority for managing ICT and security risk in financial institutions.
Specifics: Promotes proactive detection and response to ICT-related threats.
Threat Modeling Alignment: These guidelines indirectly support threat modeling by strongly emphasizing threat identification, risk management, and control assessments.
As specified in the guidelines:
“Institutions shall have a process in place to detect, manage and monitor ICT and security risks, including threat identification and anomaly detection, based on effective and continuous monitoring of the ICT systems and supported by appropriate internal and external intelligence and sources of information.”
Geography: Asia-Pacific
MAS TRM Guidelines (2021) – Singapore
Description: Mandates cyber risk controls for financial institutions in Singapore.
Specifics: Covers anomaly detection, secure architecture, and monitoring.
Threat Modeling Alignment: Aligns with threat modeling by requiring proactive identification and response to system threats.
As specified in the guideline:
“Establish and implement robust processes for the timely detection of cyber threats and system anomalies.”
APRA CPS 234 (2019) – Australia
Description: Cybersecurity requirements for Australian financial institutions.
Specifics: Focuses on security capabilities, testing, and incident management.
Threat Modeling Alignment: This principle demands the identification of threats and the implementation of appropriate controls, which are the core principles of threat modeling.
As specified in the standard:
“An APRA-regulated entity must maintain information security capability commensurate with the size and extent of threats to its information assets.”
Geography: Latin America
LGPD – Lei Geral de Proteção de Dados (2018) – Brazil
Description: Brazil’s data protection law governing personal and sensitive financial data.
Specifics: Applies to data controllers and processors, including financial institutions.
Threat Modeling Alignment: Mandates technical measures to prevent data compromise, requiring the identification of potential threats, akin to threat modeling.
As specified in the law:
“The controller shall adopt security, technical and administrative measures able to protect personal data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication or any type of improper or illicit processing.”
CNBV Cybersecurity Guidelines (2020) – Mexico
Description: Mexican regulations for financial cybersecurity resilience.
Specifics: Mandates the establishment of detection and response processes.
Threat Modeling Alignment: Supports threat modeling by requiring early identification and response to cyber threats.
As specified in the guidelines:
“Institutions must establish cybersecurity strategies that include detection and timely response to cyber incidents, based on risk assessments.”