Board-ready security leadership, delivered as flexibly as the business needed it.
How a fintech in the Middle East closed its regulatory and enterprise-sales security gaps through a part-time fractional CISO engagement, built on the NIST Cybersecurity Framework.
Trigger event
A fintech operating in the Middle East had just closed a growth funding round. Security had been owned informally by the CTO alongside product work. Two enterprise prospects paused their contracts pending a completed security questionnaire and evidence of a named security leader; the board separately asked for a risk report ahead of the next funding conversation. Rather than commit to a full-time hire before it was the right fit, the company engaged a fractional CISO: flexible, part-time, and able to start immediately.
Initial 30-day assessment, rated by risk
| # | Finding | Risk | Business impact |
|---|---|---|---|
| 1 | No formal risk register or board-approved risk appetite statement | Critical | Board cannot see or approve what risk the company is actually carrying |
| 2 | No incident response plan; no tested runbook or named responders | Critical | A real incident would be handled ad hoc, with no defined containment or notification path |
| 3 | No third-party or vendor risk process, despite 40+ vendors handling customer data | High | Vendor exposure is inherited with no visibility or tiering by data sensitivity |
| 4 | Security policies existed on paper but had not been reviewed or ratified in 3 years | High | Policies do not reflect current systems; unusable as audit evidence |
| 5 | No board-level security reporting cadence | Medium | Leadership has no recurring visibility into risk trend or program status |
| 6 | MFA and SSO not enforced organization-wide | Medium | Account takeover remains the most likely and least defended attack path |
| 7 | No structured security awareness training for staff | Low | Elevated phishing susceptibility, no direct regulatory exposure yet |
Findings #1 and #2 blocked the board risk report directly, so they were sequenced first.
Fractional CISO, part-time and flexible
Structured as ongoing leadership rather than a fixed-scope project: strategy, governance, reporting, and program oversight, built on the NIST CSF and mapped to regional regulatory expectations. The engagement scaled with the business, starting immediately and flexing in cadence as priorities shifted, without the commitment of a full-time role.
Actions taken
- Built a risk register and a board-approved risk appetite statement, reported quarterly
- Designed and tabletop-tested an incident response plan with named responders and an executive escalation path
- Stood up a vendor risk program covering 40+ vendors, tiered by data sensitivity, with renewal-linked reviews
- Rewrote and ratified 12 core policies, mapped to the NIST CSF and to regional regulatory obligations
- Enforced MFA and SSO across the organization
- Established a recurring quarterly board security report, in the same format leadership already used for financial reporting
- Prepared the company for, and represented it through, its next regulatory examination cycle
Risk classification: before and after, month 6
The regulatory examination closed with no critical findings. The two paused enterprise contracts resumed once the completed security questionnaire and named CISO were provided, and the board received its first quarterly risk report ahead of the following funding round.
Additional business outcomes
Enterprise deal cycle
Security questionnaires that previously took weeks of scrambling across engineering and legal were answered from an existing evidence library within days.
Investor confidence
A recurring, board-ready risk report became a standing item in investor updates, ahead of the next funding conversation rather than a scramble before it.
Get your security program assessed
Findings like these surface in the first 30 days of a fractional CISO engagement. Start with a conversation about where your program stands today.
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