The "World Bank" Simulated Environment for NIS2 

Introduction: The "World Bank" Simulated Environment

This suite of documents establishes the framework for the "World Bank" (hereinafter referred to as "WDB" or "the Bank"), a fictitious, large-scale, multinational financial institution. The WDB's notional mission encompasses facilitating sustainable development through financing critical infrastructure projects, providing extensive economic research and policy advice to member nations, and fostering international policy coordination on global economic and financial stability. Its operations are presumed to span multiple continents, engaging with a diverse array of stakeholders including governments, international organizations, private sector entities, and civil society.

The inherent complexity of such a global mission, coupled with the sensitive nature of the financial and economic data handled, underscores the critical necessity for a robust and comprehensive cybersecurity governance framework. The following sections detail the WDB's governance structures, organizational roles, key policies, IT assets, and architectural principles, designed to provide a realistic and detailed environment for simulating and studying the practical application of cybersecurity governance in a complex international financial institution.

Disclaimer: This is a simulated use case. The documents were drafted with the help of Artificial Intelligence.

World Bank Documentation

This section presents a curated set of simulated documents for the World Bank scenario, designed to illustrate best practices in Cybersecurity Governance and IT Architecture Management.

World Bank Governance and Organization

Organizational Structure and Security Responsibilities
Download
Register of Information Resource Owners (Asset Owners)
Download
Governance Policies
Download
Vendor Management Policy (Supply Chain Security)
Download
Information Classification Policy
Download

World Bank IT Assets and Architecture

Asset Inventory
Download
Infrastructure Architecture Map
Download
Critical IT Services Documentation
Download
Network Interface Documentation
Download
Data Flow Maps
Download

World Bank Security Controls

In our simulated environment of World Bank, the last CISO implemented a comprehensive security approach aligned with international best practices and frameworks (e.g., ISO/IEC 27001, NIST CSF). The security controls are structured into five key areas:

🔒 Organizational Controls

Clear governance, defined roles and responsibilities, formalized security policies, risk management practices, and business continuity planning. All critical processes are subject to regular monitoring and audits. Download

👥 People Controls

Ongoing staff training, access management based on the principle of least privilege, codes of conduct, and employee background checks to prevent insider threats. Download

🏢 Physical Controls

Controlled physical access to data centers and critical facilities, video surveillance, environmental protections (e.g., UPS, fire suppression), access badges, and visitor logs. Download

💻 Technological Controls

Firewalls, IDS/IPS systems, network segmentation, data encryption at rest and in transit, multi-factor authentication (MFA), patch management, and continuous monitoring via SIEM and SOC. Download

☁️ Cloud & Third-Party Controls

Vendor risk assessments and monitoring (due diligence), contractual security clauses, third-party risk management frameworks, and dedicated cloud security controls (e.g., CSPM, centralized logging, resource isolation). Download

NIS2 Compliance Process for World Bank

Overall Goal: To establish and demonstrate robust cybersecurity risk management measures, incident handling capabilities, and resilience in line with the NIS2 Directive, ensuring the security of network and information systems supporting "World Bank's" essential services.

Phase 1: Understanding Obligations & Gap Analysis
Phase 2: Governance & Risk Management Framework Enhancement
Phase 3: Implementation of Cybersecurity Measures & Controls
Phase 4: Incident Handling & Reporting
Phase 5: Monitoring, Auditing, & Continuous Improvement

Phase 1: Understanding Obligations & Gap Analysis

1. Deep Dive into NIS2 Requirements:
  • Thoroughly review the NIS2 Directive text, focusing on articles relevant to essential entities in the banking sector.
  • Analyze national transpositions of NIS2 in all relevant jurisdictions where "World Bank" operates, as these may contain specific national requirements.
  • Consult guidance from relevant EU bodies (e.g., ENISA) and national competent authorities (NCAs).

2. Scope Definition ("Am I in Scope?"):

  • Formally confirm "World Bank" as an "essential entity" under NIS2 based on its size, services provided (critical banking functions like payment processing, deposit taking, lending), and potential impact of disruption.
  • Identify all critical services and the underlying network and information systems supporting them. This includes core banking systems, payment gateways, online banking platforms, mobile banking apps, internal communication systems, and data centers.
3. Stakeholder Identification & Kick-off:
  • Identify key stakeholders across the bank: Board of Directors, senior management, IT, Legal, Compliance, Risk Management, Human Resources, Physical Security, and critical third-party service providers.
  • Conduct a kick-off meeting to communicate the importance of NIS2, roles, responsibilities, and the overall project plan.
4. Comprehensive Gap Analysis:
  • Compare "World Bank's" current cybersecurity posture, policies, procedures, and technical controls against NIS2 requirements. This involves:
    • Reviewing existing risk assessments, security audits, and penetration test results.
    • Assessing current incident response plans and capabilities.
    • Evaluating existing cybersecurity policies (e.g., access control, data security, cryptography, HR security, asset management).
    • Analyzing supply chain risk management processes.
    • Reviewing business continuity and disaster recovery plans.
    • Assessing governance structures related to cybersecurity.

Output for Phase 1: 

Understanding Obligations & Gap Analysis

1. NIS2 Applicability Statement

This document formally declares and documents "World Bank's" status under the EU Network and Information Systems 2 Directive (NIS2). Download

2. List of Critical Services and Supporting Systems

This document provides a comprehensive inventory of services offered by "World Bank" that are deemed critical under the NIS2 Directive. Download

3. NIS2 Stakeholder Engagement Plan

This Plan outlines the comprehensive and strategically vital strategy for identifying, communicating, and collaborating with all key internal and external stakeholders. Download

4. NIS2 Detailed Gap Analysis Report

This Gap Analysis systematically compares "World Bank's" current cybersecurity posture, against the specific requirements of the EU NIS2 Directive.

5. NIS2 Initial Resource Estimation

This document provides a preliminary high-level estimate of the resources required for "World Bank" to address the gaps identified.



Phase 2: Governance & Risk Management Framework

1. Strengthening Cybersecurity Governance:

  • Ensure clear roles and responsibilities for cybersecurity risk management are defined and approved by management bodies. This includes direct accountability at the management/board level.
  • Establish or refine a cybersecurity steering committee or working group with representatives from key departments.
  • Develop or update a comprehensive cybersecurity strategy and policy framework aligned with NIS2, approved by the management body.
  • Implement a training and awareness program for all employees, with specialized training for management and those with specific cybersecurity responsibilities.

    • 2. Adopting a NIS2-Compliant Risk Management Framework:

  • Implement a systematic approach to risk assessment that is ongoing and covers all identified critical systems and services. This should include:
    • Asset Identification & Valuation: Identifying and valuing information assets.
    • Threat Modeling: Identifying potential threats (including insider threats, external attacks, supply chain vulnerabilities, environmental threats).
    • Vulnerability Assessment: Regularly identifying and analyzing vulnerabilities in systems and processes.
    • Impact Analysis: Assessing the potential business, financial, reputational, and societal impact of incidents.
    • Risk Treatment Plan: Defining actions to mitigate, transfer, accept, or avoid identified risks. This plan must prioritize actions based on risk levels.
  • Ensure risk assessments consider supply chain risks, including dependencies on critical ICT service providers.
  • Integrate cybersecurity risk management into the bank's overall enterprise risk management framework.