SOCI Compliance Guide: Adding Financial Egress to Your Risk Management Program

For entities regulated under the Security of Critical Infrastructure (SOCI) Act 2018, the focus of the Risk Management Program (RMP) has traditionally been on Operational Technology (OT) and core Cloud ERP security.

However, a specific attack vector is increasingly being flagged by external auditors during CIRMP reviews: Financial Egress.

This is the process of moving payment instructions (ABA files, BACS, ISO 20022) from your ERP (SAP, Dynamics 365, Oracle) to the Banking network.

If your current process involves downloading a file to a desktop or network drive before uploading it to a bank portal, you have a "Material Risk" regarding Data Integrity. This guide details the operational requirements for mitigating this risk in-house to satisfy a SOCI audit.

Step 1: Updating the Risk Register

Under the SOCI Act, entities must identify "Material Risks" that could impact the availability or integrity of the critical asset. Financial insolvency due to fraud or ransomware falls under this category.

To be compliant, you must formally acknowledge the "Desktop Gap." Add the following entry to your Risk Register:

Step 2: Designing Mitigation Controls (The In-House Protocol)

To reduce the Residual Risk rating to "Acceptable" without using a sovereign tunneling tool, you must enforce a strict Manual Chain of Custody.

Below is the standard protocol required to prove mitigation during an audit.

Control A: The Air-Gapped Workstation

You cannot allow financial files to rest on standard employee laptops that are connected to the open internet (email, web browsing).

• Requirement: Provision a dedicated, hardened workstation ("The Banking PC").
• Configuration: This machine must be restricted via firewall rules to access only the ERP IP range and the Bank IP range.
• Operational Cost: This machine cannot be used for daily work. Finance staff must physically move to this terminal to perform payment runs.

Control B: Manual Cryptographic Verification

If a human handles the file, you must prove the file has not changed between the ERP download and the Bank upload. Relying on "Visual Checks" is not a valid control under ISO 27001.

• The Procedure:
  1. Finance Officer exports the file from the ERP.
  2. Officer runs a checksum utility (e.g., CertUtil -hashfile payment.aba SHA256).
  3. Officer records the generated Hash string in a separate, immutable log (e.g., a SharePoint list with versioning).
  4. Officer uploads the file to the Bank.
  5. Officer confirms the Bank's receipt hash matches the local log.

Control C: Encryption at Rest (PGP Management)

If the payment file touches a disk (hard drive or network share), it constitutes "Data at Rest" and must be encrypted under the SOCI CIRMP rules.

• Requirement: Implement PGP (Pretty Good Privacy) encryption for local storage.
• The Burden: Your IT team must manage Public/Private key pairs manually.
• Maintenance: Keys must be rotated every 90–180 days. If a key is lost or a Finance Officer leaves the organization, you risk losing access to historical audit trails.

Step 3: The Auditing Burden

Under SOCI, having the controls is not enough; you must provide Evidence of Effectiveness.

To satisfy an external audit of a manual process, you will need to aggregate logs from three disparate systems for every single payment run to reconstruct the event:

1. ERP Logs: Evidence of file generation (User ID, Timestamp).
2. Endpoint Logs: Evidence that the file was not opened or edited by a text editor (e.g., Notepad++) on the local machine.
3. Bank Portal Logs: Evidence of upload.

The Weakness: This proves activity, but it is difficult to defend in a court of law or an insurance claim. It does not technically prove that the user intended to authorize that specific file if it sat on an unencrypted drive for 10 minutes.

Step 4: Managing Technical Debt & Drift

Building custom scripts (Python/PowerShell) to automate this internal movement introduces significant technical debt that must be declared in your RMP.

• Bank Protocol Drift: Banks are currently migrating from ABA to ISO 20022 XML. Hard-coded internal scripts must be rewritten, tested, and re-certified every time a bank changes its schema.
• Library Vulnerabilities: In-house scripts often rely on open-source libraries. These must be patched and monitored for CVEs (Common Vulnerabilities and Exposures).

Summary: The "Reasonable Steps" Test

Directors and Officers must ask themselves: "Is relying on a manual checksum process or a custom script considered 'Reasonable Steps' to secure millions of dollars in egress?"

While it is possible to achieve SOCI compliance manually, the operational friction is immense. It transforms your Finance team into IT security operators and creates a permanent maintenance tax on your engineering team.

The Alternative: Infrastructure as a Service

Most Critical Infrastructure entities are moving away from manual egress towards Sovereign Financial Infrastructure.

Platforms like Demiton provide a pre-audited "Iron Layer" that streams data from ERP to Bank via RAM-only execution, managing the encryption, hashing, and audit logs automatically. This removes the need for "Banking PCs," manual hashing, and custom script maintenance, instantly satisfying the RMP requirements for financial egress.