Rajah & Tann Regional Round-Up
your snapshot of key legal developments in Asia
Issue 2 - Apr/May/Jun 2023
 

Additional Requirements under Revised Policy Document on Risk Management in Technology (RMiT)

On 1 June 2023, the Central Bank of Malaysia, Bank Negara Malaysia ("BNM"), issued a revised version of its Policy Document on Risk Management in Technology ("Revised RMiT PD").


This document sets out additional requirements for a financial institution's ("FI") management of cloud technology risks and the adoption of multi-factor authentication ("MFA") security controls by financial institutions, including the following:


  1. New Requirements for Adoption of Public Cloud for Critical Systems

  2. Under the Revised RMiT PD, an FI is only required to consult BNM prior to the first-time adoption of a public cloud for critical systems, and to notify BNM for any subsequent such adoptions. For non-critical systems involving the cloud, an FI is no longer required to notify BNM of its intention to use the same.

  3. Guidance on Assessment of Common Key Risks and Control Measures for Adoption of Public Cloud for Critical Systems

  4. The Revised RMiT PD incorporates a new Appendix 10 which adopts the Cloud Technology Risk Assessment Guideline (CTRAG) Exposure Draft released in 2022. FIs are encouraged to carry out an assessment of common key risks and control measures specified in Appendix 10 when adopting a public cloud for critical systems.

  5. MFA Security Controls as a Standard Requirement

The Revised RMiT PD makes it mandatory for FIs to deploy MFA technology and channels that are more secure than the unencrypted short messaging service (SMS), and to ensure that the MFA solution is resistant to interception or manipulation by any third party throughout the authentication process.


The Revised RMiT PD came into effect on 1 June 2023. However, for the new amendments specifically related to cloud technology risk management, the amendments will take effect as follows:


  1. 1 June 2023 – for licensed digital banks and Islamic digital banks; and
  2. 1 June 2024 – for FIs other than licensed digital banks and Islamic digital banks.



Please note that whilst the information in this Update is correct to the best of our knowledge and belief at the time of writing, it is only intended to provide a general guide to the subject matter and should not be treated as a substitute for specific professional advice.

 

Christopher & Lee Ong
Level 22, Axiata Tower ,
No. 9 Jalan Stesen Sentral 5
Kuala Lumpur Sentral,
50470 Kuala Lumpur, Malaysia
www.christopherleeong.com


Contacts:

Kuok Yew Chen
Partner
D +603 7958 8310
F +603 7958 8311
yew.chen.kuok@christopherleeong.com

John Mathew
Partner
D +603 2267 2626
F +603 2273 8310
john.mathew@christopherleeong.com

Yon See Ting
Partner
D +603 2278 8311
F +603 2278 8322
see.ting.yon@christopherleeong.com

Yau Yee Ming
Partner
D +603 2278 8311
F +603 2273 8322
yee.ming.yau@christopherleeong.com

Deepak Pillai
Partner
D +603 2267 2675
F +603 2273 8310
deepak.pillai@christopherleeong.com

Sri Sarguna Raj
Partner
D +603 2267 2737
F +603 2273 8310
sri.sarguna.raj@christopherleeong.com

Chor Jack
Partner
D + 603 2267 2729
F +603 2273 8310
jack.chor@christopherleeong.com

Rubini Murugesan
Partner
D +603 2267 2616
F +603 2273 8310
rubini.murugesan@christopherleeong.com

Lim Siaw Wan
Partner
D +603 2267 2731
F +603 2273 8310
siawwan.lim@christopherleeong.com

Rajah & Tann Asia is a network of legal practices based in Asia.

Member firms are independently constituted and regulated in accordance with relevant local legal requirements. Services provided by a member firm are governed by the terms of engagement between the member firm and the client.

This update is solely intended to provide general information and does not provide any advice or create any relationship, whether legally binding or otherwise. Rajah & Tann Asia and its member firms do not accept, and fully disclaim, responsibility for any loss or damage which may result from accessing or relying on this update.