DORA under BaFin supervision, without a security team
Private bank · Frankfurt · ~220 FTEDORA enforced, BaFin attentive, and an internal IT team built for operations, not for an ICT risk framework. The bank needed a compliance programme that would satisfy a supervisor and a security lead who could sit across from one.
Built the DORA programme end to end: ICT risk framework, asset register, third-party register, and an incident process rehearsed against the 72-hour clock. A Lockpoint vCISO took ownership of posture, board reporting, and the regulator interface, on retainer.
Registers that update from daily operations instead of yearly panic, an incident process the team has actually run, and one named person accountable for every supervisory question. The co-managed model: their IT kept the keys.