Dawgen Decodes — Bank-of-Jamaica Cyber-Risk Series | Article 2
The Bank of Jamaica’s 2025 Standard of Sound Practice – Management of Cyber Risks requires every deposit-taking institution (DTI) to embed a four-lines-of-defence model inside its cyber-risk-management framework. The structure—Operational Management, Risk Management, Internal Audit, and Information-Sharing & External Assurance—creates clear ownership, independent challenge, and an external feedback loop that together drive faster detection, stronger controls, and regulator confidence.
1 | Why “Four Lines” Outperform Single-Layer Defences
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Cyber threats move laterally; isolated controls do not. Segregating duties across four lines reduces single-point failure and conflict of interest.
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The model aligns with corporate-governance best practice and is now a minimum expectation for Jamaican DTIs.
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Board minutes must show the lines interacting—reporting, challenging, and remediating—on a routine schedule.
2 | First Line of Defence — Operational Management
| Mandate | Practical Actions |
|---|---|
| Own & manage day-to-day cyber risk. | Structure & expertise: designate CIO, CISO, Cyber-Incident Response & Recovery (CIRR) leads, plus a PMO for tech change. |
| Cyber hygiene: mandatory awareness training, multi-factor authentication (MFA), social-engineering drills. | |
| Third-party due diligence: supplier screening, SOC 2 evidence, and contract clauses. |
Tip: Maintain a dynamic risk register and prioritise threats that could materially disrupt “critical operations,” as defined by the BOJ.
3 | Second Line of Defence — Risk Management Function
The CRO’s team oversees, challenges, and aggregates cyber risk across the enterprise. Core duties include:
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Propose risk-tolerance levels for board approval.
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Ensure cyber risk is embedded into the enterprise-risk-management framework.
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Track impact-driven metrics such as duration of system unavailability, records exposed, and revenue lost.
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Validate that First-Line treatment plans address the highest-severity items and are resourced.
4 | Third Line of Defence — Internal Audit
Internal Audit provides independent assurance that the first two lines are working:
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Test control design and operating effectiveness against NIST CSF or other recognised standards.
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Coordinate with external assessors and regulators to benchmark maturity.
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Report gaps directly to the Audit Committee—bypassing management if required.
5 | Fourth Line of Defence — Information-Sharing & External Assurance
This “outer ring” brings threat intelligence and impartial validation:
| Element | BOJ Expectation |
|---|---|
| Threat-intel sharing | Establish relationships with JaCIRT and sector ISACs; feed actionable intel into SOC. |
| Regulatory reporting | Notify BOJ of cyber incidents within 72 hours and supply forensic reports if requested. |
| External attestation | Alternate yearly between self-assessment (2nd/3rd line) and independent audit; include compensating controls for any gaps. |
| Continuous testing | External vulnerability scans (≥ twice yearly) and penetration tests (≥ annually). |
6 | Making the Lines Work Together — Reporting & Escalation
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Risk dashboards: First and Second Lines provide KPIs (RPO, RTO, dwell time, patch status) to the board each quarter.
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Escalation triggers: A critical vulnerability unresolved past SLA or any incident breaching tolerance limits must rise from First → Second → Board within 24 hours.
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Annual “four-lines” workshop: Align roles, update RACI, and rehearse cross-line communications.
7 | 90-Day Implementation Checklist
| Timeline | Key Deliverable | Accountable Line |
|---|---|---|
| Days 1–30 | Map existing functions to the four-line model; close any role gaps. | Board & Senior Mgmt |
| Days 31–60 | Launch integrated risk register; define tolerance thresholds & KPIs. | First & Second |
| Days 61–90 | Conduct a tabletop exercise with Internal Audit observing; ingest JaCIRT threat-intel feeds. | All Lines |
Dawgen Global View
A well-oiled four-line defence is more than governance—it’s a competitive differentiator that proves cyber resilience to regulators, investors, and customers alike.
How Dawgen Global Helps
| Service | Benefit |
|---|---|
| Four-Line RACI Design | Clear ownership, no overlaps, no gaps. |
| KPI & Dashboard Build-out | Real-time visibility for boards and regulators. |
| External Assurance & Pen-Testing | Meet the BOJ’s fourth-line requirements without overhead. |
| Cross-Line Simulation Drills | Stress-test communication and escalation pathways. |
Ready to operationalise the BOJ’s four-line mandate? Let’s talk.
Next Step!
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