NBU IN THE SYSTEM OF CRITICAL INFRASTRUCTURE PROTECTION IN THE CREDIT AND BANKING SECTOR

The article is devoted to the characterization of the role of the NBU in the system of protection of critical infrastructure in general and its segment in the credit and banking sector. The functions of the regulator concerning the provision of cyber protection and information security in the banking system of Ukraine as well as the formation of the list of critical infrastructure objects in its composition are analyzed. Characteristics of the NBU in the system of protection of critical infrastructure in the credit and banking sector is based on the specifics of its status in comparison with other banks, which consists, above all, in the fact that it is simultaneously the central body of state administration and banking institution (the central bank of the country), which performs banking operations. At the same time, as a state body NBU is a subject of critical infrastructure protection in the credit and banking sector, and as a banking institution it can also be the object of such protection. The specificity of the NBU status in the banking system is embodied in its main function, which is to ensure the stability of the monetary unit of Ukraine, and other functions assigned to it by law. At the present stage, these functions are supplemented with two new ones, which relate to cyber protection and information security, as well as the formation and maintenance of a list of critical infrastructure in the banking system of Ukraine. Some elements of these functions have been partially present in the activities of the NBU before. However, now they are separated from the total volume of banking regulation and supervision. Also, the introduction of a certain institutional mechanism to ensure the performance of these specific functions has begun, in particular, the Center for Cyber Protection of the NBU has been established. But relations between banks and the latter are built on a voluntary basis. It seems that further development of the cyber defense system adequate to existing and potential threats in the credit and banking sector requires clear normative fixation of key parameters of its functioning in the form of mandatory rules for banks. The conclusion is made that at the present stage the functions of the NBU as a subject of critical infrastructure protection are focused primarily on the issues of cyber protection and information security in the banking system. But potentially, the content of these functions is much broader, because we are talking not only about the information aspects of banking security, but also in general about the formation and maintenance of a list of critical infrastructure, the definition of criteria and procedures for attributing objects in the banking system of Ukraine to the objects of critical infrastructure, which in the future should become the basis for comprehensive protection of such objects. At the same time, these functions of the NBU cannot be considered separately from its other functions. First of all, the effectiveness of the critical infrastructure protection system in general and its segment in the credit and banking sector will largely depend on the improvement of banking regulation and supervision taking into account European standards, including through the consistent national legal implementation of the relevant provisions of the Association Agreement between Ukraine and the EU.