The American Transaction Processors Coalition (ATPC), the leading payments-processing advocacy organization in the United States, commends the United States Department of Homeland Security (DHS) Cyber Infrastructure (CISA) on its inclusion of “payment, clearing, and settlement services” in the National Critical Functions Set released April 2019.

As part of its ongoing education efforts within federal agencies, on Capitol Hill, and at the state and local government level, the ATPC reminds these key stakeholders of the critical nature of the payments processing industry and its related activities. The recognition this list brings is significant as the National Critical Functions are “the functions of government and the private sector so vital to the United States that their disruption, corruption, or dysfunction would have a debilitating effect on security, national economic security, national public health or safety, or any combination thereof.”

There are three items on the list of particular interest to the ATPC and its member companies, one directly related and two with a secondary, indirect relationship.

• Provide Payment, Clearing, and Settlement Services – direct
• Provide Consumer and Commercial Banking Services – indirect
• Provide Funding and Liquidity Services – indirect

The National Critical Functions approach to risk management is featured in the National Cyber Strategy and the DHS Cybersecurity Strategy, and is the foundational element for the development of a “Risk Register.” This process is accomplished with expert representatives from government and industry to provide analysis, policy opinion, and operational insight resulting in a tiered (prioritized) manner based on need of mitigation and collective action.