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Blockchain Security for Executives — 90-Day Plan

Блокчейн безопасность для руководителей — 90‑дн план

Blockchain Security for the Board of Directors: 90-Day Corporate Asset Protection Plan

Executive Summary

This document presents a 90-day plan for the comprehensive security enhancement of corporate crypto assets. The objective of the plan is to minimize financial and reputational risks associated with cyberattacks and regulatory non-compliance.

In an environment where losses in the crypto industry amount to billions of dollars annually and regulatory pressure is intensifying, shifting from reactive measures to proactive defense is critical for business resilience. The key risk addressed by this plan is potential direct financial loss from smart contract hacks or key compromises, as well as fines for non-compliance with AML/CFT standards.

Our risk assessment model shows that the Annual Loss Expectancy (ALE) is $187,500. The proposed investments will reduce this figure by 84%, to $30,000.

Three key decisions are submitted for Board approval:

  1. Adoption of the 90-day plan starting 01.01.2025.
  2. Budget allocation under one of three scenarios (from $50,000 to $115,000).
  3. Establishment of monthly oversight for plan execution.

Implementing this plan will not only protect company assets but also strengthen investor and regulator confidence, creating a solid foundation for further growth.


1. Decisions for the Board of Directors

To protect assets and ensure business continuity, the following decisions are proposed for approval:

  1. Approve the 90-day plan for strengthening the security of corporate crypto assets starting 01.01.2025. The person responsible for execution is the Chief Information Security Officer (CISO).

  2. Approve the budget for plan implementation under one of three scenarios. The funding source is the IT/Security department's operating budget. Expenses are tracked weekly, and any overspend exceeding 10% must be approved by the Chief Financial Officer (CFO).

    ScenarioBudgetExpense Item Details
    Minimal$50,000Smart contract audit ($20k), AML license ($15k), internal resources for IRP ($5k), buffer ($10k).
    Basic$85,000Expanded audit ($35k), AML license ($25k), external IRP consultants ($10k), integration ($5k), buffer ($10k).
    Advanced$115,000+Comprehensive audit from a market leader ($50k), premium AML with API ($35k), Bug Bounty platform ($15k), buffer ($15k).
  3. Establish monitoring procedures: The CISO shall report monthly to the CTO and CFO on progress and budget utilization. The final report on the results of the 90-day plan will be presented at the Board of Directors meeting in April 2025. In the event of a deadline slippage exceeding 10 working days, the CISO is required to initiate an escalation to the CEO.


2. Dependencies and Resources

ResourceRequirementStatus
Internal FTEs1.5 FTE (1 CISO, 0.5 CTO) for project management; 2 Engineer FTEs for integration and vulnerability remediation.Resources allocated and confirmed.
External ContractorsAudit firm, AML solution provider, legal consultants.Procurement process will be launched immediately upon budget approval.
Procurement TimelinesAuditor/vendor contracting: 15–20 working days.Accounted for in the schedule.
Access and EnvironmentsSource code access for auditors, staging environment for AML integration, API availability for key systems.Availability confirmed.

3. 90-Day Implementation Schedule (01.01.2025 – 10.04.2025)

The schedule includes buffer days for potential delays in contracting and integration.

Phase 1: Audit and Analysis (Days 1–35)

TaskOwnerDeadlineDefinition of Done (Acceptance Criteria)
1.1Selection and contracting of smart contract auditorCISO20.01.2025Contract signed, audit scope defined.
1.2Execution of independent security auditExternal Auditor, CTO10.02.2025Final report with vulnerability list (CVSS) received and accepted.
1.3Selection and contracting of AML providerCompliance Officer25.01.2025Contract signed, SLAs established.

Phase 2: Implementation and Setup (Days 36–70)

TaskOwnerDeadlineDefinition of Done (Acceptance Criteria)
2.1AML solution integration for transaction screeningCTO, Compliance Officer10.03.2025>99.5% of transactions pass automated screening in the staging environment.
2.2Development of the first version of the Incident Response Plan (IRP)CISO01.03.2025Document approved by CISO, CTO, and Legal; roles assigned.
2.3Remediation of critical vulnerabilities (CVSS 9.0+) from auditCTO10.03.2025100% of critical vulnerabilities closed, fixes verified by auditor.

Phase 3: Testing and Optimization (Days 71–90+)

TaskOwnerDeadlineDefinition of Done (Acceptance Criteria)
3.1Conducting IRP tabletop exercisesCISO, CEO, Legal25.03.2025Exercise conducted, report with MTTD/MTTR metrics and recommendations prepared.
3.2Development and approval of external communication templatesPR, Legal, CISO30.03.2025Templates for press releases and regulator notifications approved.
3.3Preparation of final report for the Board of DirectorsCISO10.04.2025Report with results, KPIs, and next quarter's plan presented.

4. Investment Justification: Threats and Risks

The rise in attacks and tightening regulations necessitate a shift toward proactive defense. In 2023, damages from cyberattacks in the crypto industry totaled $1.7 billion (Immunefi [1]), and in Q1 2024, 232 incidents were recorded (CertiK [2]). While our risk profile may differ, these data points highlight systemic threats in the industry.

Quantitative Key Risk Assessment (detailed model in Appendix 4):

ThreatAnnual ProbabilitySingle Loss Expectancy (SLE)Annual Loss Expectancy (ALE)Risk Reduction by Plan
Smart Contract Hack5%$2,000,000$100,000Audit and Bug Bounty reduce probability to 1% (ALE = $20,000).
Key Compromise10%$500,000$50,000MPC/Multi-sig implementation reduces SLE to $50,000 (ALE = $5,000).
Regulatory Fines (AML)15%$250,000$37,500AML screening reduces probability to 2% (ALE = $5,000).

Total Annual Loss Expectancy (ALE): $187,500
Reduction to: $30,000 (by 84%)

Investments ranging from $50,000–$115,000 allow for an annual risk reduction of ~$157,500, confirming their economic feasibility.


5. Key Activity Details

5.1. Security Audit and Vulnerability Management

  • Methodology: Audits are conducted annually and before every major release. Companies with a proven reputation in auditing DeFi protocols (at least 5 public reports) are engaged.
  • Remediation Policy: Vulnerabilities with a CVSS rating of 9.0+ must be remediated within 7 days. For CVSS 7.0–8.9 vulnerabilities, a remediation plan is created or a risk acceptance document is signed by the CTO.

5.2. AML/CFT Compliance

  • Screening Policy: All transactions are screened automatically. Transactions with a risk score >25% are blocked for manual review. This threshold is a starting point and will be adjusted based on false-positive analysis.
  • Processing: SLA for manual review is no more than 4 working hours.

5.3. Incident Response Plan (IRP) and Recovery

  • IRP: The document includes clear escalation criteria. The Board of Directors is informed immediately of incidents with potential damage >$500,000.
  • Backup & Disaster Recovery: A backup and recovery plan has been developed for key infrastructure nodes and wallets. Testing of recovery procedures will be conducted quarterly.

5.4. Key Management: Migration Plan to MPC/Multi-sig

  • Migration Plan:

    1. Phase 1 (PoC, 1 month): Testing solutions from 2–3 providers on testnets. TCO assessment.
    2. Phase 2 (Pilot, 1 month): Moving a small portion of operational funds (<5%) under the management of the chosen solution.
    3. Phase 3 (Implementation): Phased transfer of assets with the development of clear operational procedures.
  • Rollback Scenario: At all stages, the ability to revert to existing storage remains in case of failure or discovery of a vulnerability in the new solution.

5.5. Legal Compliance

JurisdictionRegulator / LawOwnerKey Actions and Notification Deadlines
EUMiCALegal DeptObtaining VASP license, compliance with Travel Rule. Incident notification to regulator — within 72 hours.
USAFinCEN / OFACCompliance OfficerRegular screening against OFAC lists, filing SAR reports. Notification — according to state requirements.
UAEVARARegional ManagerObtaining VASP license. Incident notification — within 24 hours.

5.6. Communications Plan

  • Internal Stakeholders: Weekly status updates for the project team, monthly reports for the CTO/CFO.
  • Investors: Quarterly security status updates as part of standard reporting. In the event of an incident — proactive communication after approval by the Legal Department.

6. Success Metrics and KPIs

Metric (KPI)Measurement Methodology and Data SourceBaselineTarget ValueOwner
MTTD/MTTRData from SIEM and ticketing system, recorded during exercises.Determined after the first exercise.MTTD < 1 hour, MTTR < 4 hoursCISO
Critical Vulnerability RemediationAuditor and scanner reports.Determined after the first audit.0 known critical vulnerabilities (CVSS 9.0+) in productionCTO
AML Screening Transaction CoverageReports from the AML system.0%>99.5%Compliance Officer
False Positive Rate (AML)Reports from the AML system.Determined after 1 month of operation.<5% (or 20% reduction from baseline)Compliance Officer
Manual AML Review TimeData from CRM / ticketing system.Determined after 1 month of operation.< 4 working hoursCompliance Officer

Tags

blockchain security
corporate crypto assets
board of directors governance
crypto risk management
aml cft compliance