This is the first article in a series about reframing cybersecurity as a cyber risk management issue, not a compliance issue. 

Throughout this series, we’ll share how cyber threats are evolving and how clients can stay ahead. You’ll discover why cybersecurity isn’t just a compliance issue, it’s a cyber risk management issue; how the government is directing cyber risk management (and the effect that has on best practices;) what you can expect as you move toward a robust cybersecurity governance standard that focuses on cyber risk management over compliance; and how service providers are evolving to help you get there. 

Cybersecurity and compliance are both integral to cyber risk management, but firms are emphasizing the latter to the detriment of their environment’s safety.

Cybersecurity governance is a strategic imperative that supports system confidentiality, integrity, and availability; protects your firm’s most valuable assets; and builds trust with customers and stakeholders. Unfortunately, its importance and effectiveness are undercut when firms subscribe to a compliance mindset. They check the necessary regulatory boxes but can neglect cybersecurity efforts beyond that.

A compliance-only mindset for cyber governance is shortsighted and fails to address the scope of broader cyber risk management. More importantly, it fails to reflect the current paradigm shift in the cyber governance world: a move to a more holistic approach to cybersecurity governance that encompasses compliance, not the other way around.

The Problem

When compliance is your end goal, you ignore significant components of cybersecurity that affect your entire environment and leave you vulnerable. Your cyber posture is precarious because you have no base to build on. This is a top-down approach to cyber risk management, which leaves your cyber governance foundation weak and exposed.

Conversely, a bottom-up approach builds upon each component—compliance, cybersecurity, and cyber governance—for a gestalt solution that protects your environment and ensures compliance.

Why do so many organizations settle for compliance over cyber risk management? One reason may be complacency. It’s easy to get comfortable with the status quo: it hasn’t happened, so it probably won’t. Another reason could be cost. Robust cyber risk management adds complexity and requires time, money, and effort, and cost centers don’t always get the attention that profit centers do.

The number of ways criminals can access your data is astounding. Hackers continue to push the envelope and some firms continue to ignore the security of their environment (to their detriment). It may be much easier (and cheaper) to check a box and call it a day, but the consequences can be devastating.

The Threats

Malicious cyber events are becoming more sophisticated and frequent. Criminals have shifted from tracking and attacking specific data to searching for and exploiting opportunities (regardless of industry) that lead to bigger paydays.  And they’re doing it in ways you may not be aware of.

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Hackers know if they can take you offline, you’ll pay a premium to recover your data and systems. Last year saw ransomware costs over $4.54 million (and that’s before the cost of the ransom). 

 If your firm lacks strong recovery procedures, you can count on significant financial and reputational loss, among other things (e.g., securing insurance coverage). 


Hackers aren’t just refining established tactics; they’re creating new ones. While artificial intelligence is making huge strides in bolstering cybersecurity, it’s also poised to aid would-be cybercriminals. Tools like ChatGPT and the upcoming Bard could potentially aid someone in creating weaponized files and accompanying phishing emails.  

Hackers, Inc. 

Cybercrime is business, and business is good. Like true entrepreneurs, criminals are creating startups to pool resources, distribute risk, and disseminate new tools like highly segmented Ransomware-as-a-Service (for a cut of the bounty, of course). These companies mirror traditional organizations in many ways: they have HR, help desks, and professional communications (even press releases).  

These new resources, along with forums, customer support, and freelancer networks make it ever easier for bad actors to innovate rapidly. Greater innovation means greater exploitation. 

Organizations relying on the minimum safeguards to meet regulatory requirements can be sure of one thing: their environment isn’t secure enough to go head-to-head with the latest threats. 

The Sea Change  

Executive Order 14028 triggered regulatory changes across the SEC, HIPAA, and PCI-DSS, as well as adjustments to the NIST framework. It represents a significant shift in how cyber risk management is being governed, what consumers of cybersecurity should expect from providers, and how cybersecurity providers will need to adjust their offerings to meet those demands. 

  • Organizations are seeing the inefficiency of a compliance mindset.   
  • The U.S. government is realizing the security issues related to a lack of holistic cyber risk management and updating standard practices accordingly. 
  • The SEC and Executive Order 14028 are pushing for more prescriptive regulation. 
  • Firms are looking to industry leaders like Agio to rework their cyber governance strategies and educate them on keeping up with industry trends. 


The current prescription is testing to evaluate cybersecurity performance once or twice a year. These exercises are scheduled (isn’t it always easier to prepare and plug holes when you know what’s coming?), and the result is a snapshot of your environment when it’s expecting and ready for an attack, not an accurate view of your day-to-day vulnerabilities. 

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Best practices are moving away from point-in-time compliance to more frequent monitoring, testing, and evaluation of your environment. Recursive, unplanned tests provide a better understanding of existing vulnerabilities and highlight the weak spots you need to address sooner rather than later. 

The Solutions 

Agio’s cybersecurity governance team has a proven understanding of how cybersecurity governance, cyber risk management, and compliance work together to create, if not a bulletproof security plan, certainly a more meaningful and successful one. 

Agio’s 360º cyber governance program provides straightforward, measurable tasks that bridge the gap between security and compliance so you’re prepared for worst-case scenarios.  

You can count on us to guide you to a more secure cyber posture while keeping an eye on regulatory changes. Throughout the process, our vCISOs track your progress and success from ownership to fortification: 

  • Ownership: understanding and acknowledging the basics necessary to create a foundation for security efforts.  
  • Control: Looking beyond the basics to critical and complex issues like third-party management and establishing loss prevention standards. 
  • Maturity: Addressing acute findings. 
  • Fortification: Recursive evaluation of policies and cyber posture to ensure agility. 


Mitigating cybersecurity risk depends on threat prediction, incident prevention, and quick response times. Our Extended Detection & Response (XDR) uses dynamic machine learning to identify unusual behavior and proactively prevent and preempt threats. It draws from a library of risks we’ve observed across our client base, protecting you from threats that weren’t even on your radar. 

The Wrap Up 

Cybersecurity, cyber governance, and compliance are all part of cyber risk management, but how you frame and implement them informs how well your firm is truly protected.  

We aren’t suggesting that regulatory requirements aren’t necessary. We’re saying that when checking a box for those requirements becomes your only approach to cyber risk management, you can count on trouble down the line.  

Protecting yourself against financial and reputational pain requires a long-haul plan focused on risk prevention that leads to compliance, not the other way around.  

Agio can help you weather the sea change from cybersecurity is a compliance issue to cybersecurity is a cyber risk management issue 

 Ready to take security to the next level? Let’s connect. 

This is the first in a series of articles about cyber risk management and cyber governance. In future articles, we’ll discuss how the U.S. government is rethinking its best practices and how those changes affect you, how you can keep up with the changes happening right now, and how suppliers are meeting client demands and ensuring they have a solid cyber posture.