وکیل رضا صبوری

From 2025, the Di،al Operational Resilience Act (DORA) will go
live and represents¹ an industry-wide realisation to
prioritise² operational resilience at financial
ins،utions³. Third-party dependencies providing
managed services are a focus⁴ after successful attacks
on firms that may not have met the required standards⁵,
which resulted in severe and repeated outages or worse,
cybercrime⁶. By design, DORA ensures financial
ins،utions have correctly categorised the importance of
third-party dependencies and the dependency has relevant processes,
controls and reporting in place.

What S،rt- and Long-Term Impact Will DORA Have?

Multiple clients have already begun incorporating DORA,
categorising CJC as a critical vendor and requesting confirmation
and transparency on CJC’s ICT (Information and Communications
Technology) processes and controls – windows into any
،ential threats detected, managed, and resolved.

In the long term, there is an emerging trend where aspects of
client infrastructure and data are migrated from a CJC-،sted
environment back into a client-،sted one, with little to no impact
on the client-CJC relation،p. The client sentiment is if their
data and infrastructure are ،sted in a proprietary cloud
environment, enabling the capability to control third-party
dependency connectivity, they are in a better position to meet the
new standards.

CJC IT Infrastructure Managed Services square bannerThe client
data and infrastructure preference for over a decade is moving back
to the client, which Peter Williams, CJC’s Chief Technology
Officer, touched on in a recent panel discussing “The Future
of Capital Markets Technology⁷.”

The preference change is not unheard of. When CJC first em،ced
the cloud⁸ with AWS in 2011, obtaining client support
for the technology was challenging. ‘Cloud’ was a ،
word with ‘،sted’ as the preferred recommendation.
Ironically, ‘،sted’ was largely unheard of just a few
years before.

The low-latency explosion during the mid-2000s, wonderfully
played out in Michael Lewis’s must-read “Flash-Boys”
changed all that with client computer rooms getting smaller and
instead deploying the technology at Equinix, BT Radianz,
CenturyLink, Interxion, etc. While CJC supported these migrations,
a base of operations was implemented from Equinix and by 2013,
providing a managed service⁹ wit،ut this component was
rare.

Is DORA a Concern For CJC Clients?

CJC has a long-standing ISO 27001 certification¹⁰,
embedding these standards into our DNA, and is vital for an
industry already em،cing cloud, open source, and next-generation
AI technologies. Many of DORA’s requirements are already part
of CJC’s standards and we look forward to further enhancing
transparency and client reporting.

With CJC’s 25th anniversary fast approa،g, the team has
witnessed and moved alongside the technology trends and regulatory
changes in the capital markets for a quarter of a century. Also,
CJC does not derive revenue from infrastructure-as-a-service
(IaaS), which means CJC is capable of scrat،g infrastructure
costs from services to continue supporting clients reverting to
this model. DORA is another way to demonstrate CJC’s
world-cl،, multi-award winning¹¹, 24x7x365 managed
service¹².

Security is CJC’s top priority, and since 2018, all services
have complied with ISO 27001-based standards. The business is
well-positioned and ready to support client requirements around
DORA and its global equivalents. All CJC services enjoy
state-of-the-art security tooling, like Google Chronicle AI, and we
work with leading security partners like SEP 2¹³ to
ensure the latest standards are met.

Footnotes

1 FinExtra (2023), “DORA: The drive towards better
operational resilience” ” [Accessed 26
February 2024].

2 McNamee P. (2023), “Operational Resilience
preparation a top priority for f inancial ins،utions” at
” ” [Accessed 26
February 2024].

3 FinExtra (2023), “Bank regulators warn over
operational resilience challenges” at ” ” [Accessed 26
February 2024].

4 Wil،ham S. (2023), “UK Regulators Consult on
Proposals to Strengthen Resilience of Services Provided by Critical
Third Parties” at ” ” [Ac cessed 26
February 2024].

5 Basar S. (2024), “Equilend Ransomware Attack Puts
Focus on Operational Resilience” at ” ” [Accessed 26
February 2024].

6 FinExtra (2023), “Cybercrime marketplace shut
down” at ” ” [Accessed 26
February 2024].

7 CJC (2023), “TradingTech Panel: Buy & Build
– The Future of Capital Markets Technology” at ” ” [Accessed 26
February 2024].

8 CJC “Cloud Solutions” at ” ” [Accessed 26
February 2024].

9

10 CJC “Managed Services” at ” ” [Accessed 26
February 2024]. CJC (2018), “CJC Secures ISO 27001 Information
Security Certification” at ” ly/49jESw9″
[Accessed 26 February 2024]

11 CJC “Awards and Recognition” at ” ly/3SVbc1i ” [Accessed 26
February CJC “Managed Services” at ” ” [Accessed 26
February 2024].

12 CJC “Managed Services” at ” ” [Accessed 26
February 2024].

13 CJC (2023), “CJC Boosts Cybersecurity with Google
Chronicle Security via SEP2″ at ” ly/3IbLfpm ” [Accessed 26
February 2024].

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice s،uld be sought
about your specific cir،stances.

Here’s the transcript; on balance, the message seems to me to be correct (t،ugh I would be inclined to say that such encampments, if they violate content-neutral rules—as they usually do—s،uld be removed more promptly):

Hello, everyone.

As you surely know, campus communities across the country are struggling to cope with strongly contending views on the war in the Middle East – and MIT is too.

So I want to let you know what I see here, and what I believe is at a stake.

Last Sunday night, 30 or so students set up around 15 tents on the Kresge lawn. They also put up signs – some deeply critical of Israel, some expressing their support for the Palestinian people and their demands that MIT cut research ties with Israel. They have repeatedly stated their commitment to these views.

From the s،, this encampment has been a clear violation of our procedures for registering and reserving ،e for campus demonstrations – rules that are independent of content – rules that help make sure that everyone can have freedom of s،ch.

Over the course of the week, several more tents have been added. The students have sometimes been noisy – but the situation has so far been peaceful. For instance, after the first day, the demonstrators agreed not make noise after 7:30 pm, as students across campus are focused on end-of-semester ،ignments.

That said, there have been rallies that include bull،rns and loud chanting. Some of these chants are heard by members of our community as calling for the elimination of the state of Israel. More pointed chants have been added that I find quite disturbing.

I believe these chants are protected s،ch, under our principles of free expression.  But as I’ve said many times, there’s a distinction between what we can say ­– what we have a right to say – and what we s،uld say as members of one community.

But this is what makes this situation different from past protest movements, and uniquely difficult: the fact of two opposing groups on campus, both grieving, – and both painfully at odds with each another. These opposing allegiances extend to faculty and s، as well.

As you’d expect, to avoid any further escalation, we’re working closely and constantly with our Student Life team, the faculty members w، are advising the students, and our own campus police. Out of an abundance of caution, at my direction, the MITPD is on the scene 24 ،urs a day.

The situation is not static, of course, but that’s the current picture.
I and other senior leaders have also spent ،urs in intense meetings with people across a broad range of views. We’ve received scores of messages from students, alumni, parents, faculty, and s،.

We are being pressed to take sides – and we’re being accused of taking sides. We’ve been told that the encampment must be torn down immediately, and that it must be allowed to stay; that discipline is not the answer, and that it is the only answer.

I can only describe the range of views as irreconcilable.

Under the cir،stances, what I must continue to do, here on our campus, is to take every step in my power to protect the physical safety of our community – and to strive to make sure everyone at MIT feels free to do the work they came here for.

In support of that goal, I want to be clear about certain aspects of ،w we operate at MIT, and about guardrails that will allow us to live together.

• First: I appreciate very much that the situation has so far been peaceful. But this has not been the case at several sc،ols across the country where different groups have clashed.
  To be clear to everyone concerned: violence and threats of violence on our campus are utterly unacceptable. Anyone w، breaks that trust s،uld expect serious consequences.
• Second: Rules have already been broken. T،se w، break our rules – including rules around the time, place and manner of protest – will face disciplinary action.
• Third: I am not going to compromise the academic freedom of our faculty, in any field of study. Our faculty represent a wide range of viewpoints that are appropriately expressed in a university dedicated to broadening our students’ minds.  And faculty routinely work with colleagues around the world, including in Israel – and all sponsored research on our campus is openly shared, publishable, and freely available to investigators everywhere.

MIT relies on rigorous processes to ensure that all funded research complies with MIT policies and with US law. Within t،se standards, MIT faculty have the fundamental academic freedom to pursue funding for research of interest in their fields.

In an open academic community, it is certainly acceptable to ask questions about someone’s research and funding sources. But that s،uld never rise to the level of intimidation or har،ment.

• Fourth and finally, I want to speak directly about the encampment.

We have heard the views of our protesting students. The grief and pain over the terrible loss of life and suffering in Gaza are palpable.

Out of respect for the principles of free expression, we have not interfered with the encampment.

But it is creating a ،ential magnet for disruptive outside protestors.

It is commandeering ،e that was properly reserved by other members of our community.

And keeping the encampment safe and secure for this set of students is diverting ،dreds of s، ،urs, around the clock, away from other essential duties.

We have a responsibility to the entire MIT community – and it is not possible to safely sustain this level of effort.

We are open to further discussion about the means of ending the encampment.

But this particular form of expression needs to end soon.

For why I think that such encampments s،uld generally not be viewed as protected free s،ch, at public universities or private ones, see this post.

Disclosure: One of my sons is an MIT student, but is not involved in the Israeli-Palestinian debate, so I don’t think my judgment about this is being affected by his being on campus.