FinCEN Information Security: GAO Audit Reveals Gaps

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A recent audit by the U.S. Government Accountability Office found that the Financial Crimes Enforcement Network’s information security practices fall short, and that many weaknesses are tied to systems run by the IRS and the Treasury Communications System (TCS).

The GAO examined FinCEN’s systems and the points where it consumes IRS and TCS data used to administer the Bank Secrecy Act, reviewing activity from March 2008 through January 2009. While auditors acknowledged that each agency had made some progress on controls, they concluded that important protections are uneven or missing across the board.

Key program-level gaps include incomplete security programs, scant implementation guidance, and insufficient testing and evaluation of security controls. Specific technical and procedural problems identified by GAO include:

  • Weak user and password management; several critical machines used weak or easily guessed credentials.
  • Shared accounts on systems that should have individual accountability: the FinCEN download machine from the IRS had multiple users sharing one account; TCS users had access to a shared administrative account.
  • At the IRS, supposedly isolated systems were accessible by more than 60,000 employees, and access privileges were not properly documented.
  • Inconsistent use of encryption, notably on removable media such as USB drives.
  • Poor boundary protections and incomplete deployment of keylogging where it might detect misuse.
  • Inadequate logging: FinCEN recorded activity for two major applications but did not log database security events; IRS logging failed to capture changes to important datasets.
  • Vulnerability scanning was not consistently performed on the required quarterly schedule — auditors found at least one interval that exceeded four months.

GAO warned that these weaknesses increase the risk that highly sensitive Bank Secrecy Act data — personal and financial information used by law enforcement — could be exposed, altered, or misused.

The full GAO work included 88 detailed recommendations to strengthen controls, but the publicly released summary distilled five broad actions for FinCEN:

  • Revise policies and procedures to address gaps such as how patches are prioritized.
  • Provide concrete implementation guidance for secure configuration of network components (for example, VPNs).
  • Improve documentation of security controls and of corrective actions taken.
  • Ensure vulnerability scanning is performed quarterly across databases, applications, and network infrastructure.
  • Apply scanning to customer-supplied source code and to any manual changes made to code.

FinCEN reviewed a draft of the GAO findings and is reported to be taking steps to implement corrective measures.

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