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a.  The Information Security Management System     c.  Political and social environment, this includes
               based on the ISO/IEC 27001 the normative docu-    demographics like level of education of the pop-
               ments must be considered or implemented.          ulation, mobile device uptake and level of smart-
            b.  DFS stakeholder overall organization structure   phone penetration to the target population.
               and how DFS fit into this structure of the organi-  d. Competing alternatives and complementing ser-
               zations and its objectives.                       vices to digital financial services.
            c.  The DFS assets this includes the supporting tech-  e.  Emerging risks and their influence, both to the
               nology and information  systems,  physical infra-  financial service and stakeholders.
               structure, software applications, hardware, agent
               networks, customer/agent/merchant devices that    The outcome of this phase is a recorded summary
               are used to access DFS.                         of all information gathered. The information will form
            d. Existing  internal controls,  previous  security  risk   input into the risk assessment process.
               events, previous  fraud  incidents,  previous audit
               reports and DFS project documents.              7�3  Security Assessment
            e.  Regulatory requirements.                       The risk assessment helps stakeholders to get indic-
            f.  The risk tolerance and risk appetite.          ative measures  of  the  current  security  level  in  the
                                                               DFS ecosystem, the security risk assessment process
               Amongst other aspects, the external context con-  includes identification, analysis and evaluation of
            siders the following.                              risks. The DFS risk assessment should be conduct-
                                                               ed periodically and the results feedback to manage-
            a.  Law and regulations related to digital financial   ment.
               services                                          The overview of the process flow is shown below.
            b.  Key DFS stakeholders.

            Figure 12 - Risk assessment process flow


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                     R Risk Identification n            R Risk Analysis s               R Risk Evaluation n
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              qIdentify DFS assets
              qIdentify associated vulnerabilities  qAssessment of consequences  qIdentify controls implemented to reduce
                                                                                  vulnerability
              qIdentify threats                qAssess likelihood & impact of occurrence  qEvaluate effectiveness of existing controls
                                               qAssess the inherent risks
              qIdentify existing controls      qAssess the residual risks      qDefine Risk Impact
              qIdentify consequences
            7�4  Risk Identification
            Risk identification is to determine what, how, where   hardware, agent equipment, customer/agent/
            and why DFS vulnerabilities might be exploited, this   merchant devices used to access DFS services
            involves  identifying  critical  DFS  assets,  associated   and the communication network devices. Identifi-
            threats and vulnerabilities, probability of occurrence,   cation enables the stakeholder to classify the DFS
            weaknesses  in  existing  controls,  impact  or  conse-  assets based the impact an incident to the asset
            quences of threats and vulnerabilities once exploited.   will have to the DFS ecosystem, classification aims
            In the process of risk identification, the stakehold-  at categorizing assets based on the value and crit-
            er should be cognizant of the internal and external   icality to the DFS ecosystem.
            considerations in section 7.2 above.               ii.  Vulnerability Identification: a vulnerability is a
               In risk identification DFS stakeholders should con-  weakness or flaw that enables a threat to attack
            sider five critical actions:                         an asset, these include, but are not limited to,
                                                                 weaknesses  in the:  physical layout, organization
            i.  Asset Identification: This entails listing all assets   procedures, personnel, management, hardware,
               in the DFS ecosystem and who is responsible for   software, network etc. They may be exploited by
               them, assets in DFS include, but not limited to   a threat, which may cause harm or damage to the
               the physical infrastructure, software applications,   system. The vulnerabilities identified should be
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