Perform a Risk Assessment:
Immediate Action: The first step when discovering a non-compliant implementation is to understand the potential risks it poses to the organization. This involves identifying threats, vulnerabilities, and potential impacts of the non-fungible token (NFT) asset program.
Risk Identification and Evaluation: Assess the new program’s impact on the organization’s risk profile. Determine if it introduces significant security, compliance, or operational risks.
Documentation and Reporting: Document the findings and present them to senior management along with recommendations for mitigation or further action.
Comparison with Other Options:
Report the Infraction: Reporting is necessary but should follow the risk assessment to provide a clear understanding of the implications and necessary mitigations.
Conduct Risk Awareness Training: Training is preventive and should be part of a long-term strategy, not the immediate response to a specific incident.
Discontinue the Process: Discontinuing the process may be a necessary step after assessing the risk, but the assessment must come first to justify such an action.
Best Practices:
Comprehensive Risk Assessment: Ensure that the risk assessment covers all aspects, including financial, reputational, and regulatory risks.
Stakeholder Involvement: Involve relevant stakeholders in the assessment process to gather diverse perspectives and ensure a thorough evaluation.
Actionable Recommendations: Provide clear, actionable recommendations based on the risk assessment findings.
[References:, CRISC Review Manual: Discusses the importance of performing risk assessments when new systems or processes are implemented without following established procedures., ISACA Standards: Emphasize the need for a systematic approach to identifying and assessing risks introduced by new initiatives or changes within the organization., , , , , , , , ]
