SAMA ComplianceServices

The SAMA (Saudi Central Bank) Cybersecurity Framework (CSF) applies to all Member Organizations regulated by SAMA, including banks, insurance companies, reinsurance companies, finance companies, credit bureaus, and financial market infrastructure. The framework covers all information assets including electronic and physical assets, software, applications, databases, communication networks, premises, and third-party services.

All financial institutions must attain at least Maturity Level 3 across all SAMA CSF requirements. For specific subdomains including Cyber Event Management, Incident Management, Threat Management, and Vulnerability Management, organizations must develop a roadmap for Maturity Level 4 to enhance control effectiveness. Maturity Level 4 also requires defining Key Risk Indicators (KRIs) and thresholds to measure control performance.

A full-time senior manager (CISO) must be appointed at senior management level. For Maturity Level 4, the CISO should be a Saudi national, appropriately qualified, and require 'no objection' from SAMA. The organization must ensure sufficient budget, national talent, technical tools, and training for the cyber department.

SAMA requires financial institutions to implement Financial Sector Cyber Threat Intelligence Principles as part of the Threat Management subdomain. Organizations must conduct a gap assessment, prepare a roadmap, submit to the Board, and implement under the guidance of the Cybersecurity Committee. Basic, operational, and technical principles must be implemented within 6 months, while strategic principles require 12 months.

SAMA requires: (1) Board of Directors approval of the cybersecurity roadmap and support for implementation, (2) A Cybersecurity Committee responsible for oversight of execution, escalation of impediments, and monitoring progress, (3) A qualified CISO at senior management level, (4) Sufficient budget and resources for the cyber department, and (5) Regular internal audit reporting annually on compliance versus required maturity.

Non-compliance with SAMA Cybersecurity Framework can result in SAMA supervisory visits and audits, possible sanctions, revocation of license, and reputational damage. SAMA conducts inspections to verify compliance with the framework requirements and maturity level targets.

SAMA compliance timeline varies based on organization size, current state, and complexity. A comprehensive gap assessment typically takes 3-4 weeks, roadmap development takes 4-6 weeks, and full implementation can take 6-12 months for medium organizations and 12-18 months for large enterprises. Threat intelligence principles require 6-12 months depending on the principle type. Ongoing compliance requires continuous monitoring and annual internal audits.

For Maturity Level 4, organizations must: (1) Develop a roadmap for enhanced control effectiveness in specific subdomains, (2) Define Key Risk Indicators (KRIs) and thresholds to measure if controls are performing as intended, (3) Appoint a Saudi national CISO with SAMA 'no objection', (4) Implement advanced threat intelligence capabilities, and (5) Establish comprehensive control effectiveness measurement and monitoring.