Contributed By:
In January 2024, Canada’s Office of the Superintendent of Financial Institutions (OSFI) introduced the Integrity and Security Guideline — a significant update aimed at protecting the country’s financial sector from emerging technical surveillance threats.
By July 2025, compliance with these measures will become mandatory for banks, insurers, pension plans, and major transportation companies. Yet, as the deadline approaches, many organizations are still working to fully understand and integrate these standards into their existing operations.
The risks associated with technical surveillance might not always be top-of-mind for financial institutions, given the extensive array of security measures already in place. However, the subtle and sophisticated nature of today’s surveillance threats requires organizations to expand their vigilance beyond conventional security practices.
What are Technical Surveillance Countermeasures?
Technical Surveillance Countermeasures (TSCM) involves a systematic approach to detecting and mitigating hidden electronic surveillance risks. These extend beyond traditional cybersecurity threats and include vulnerabilities from hidden microphones, compromised office equipment, wireless communication breaches, and unintended internal exposures.
A comprehensive TSCM sweep involves meticulous examinations of physical spaces and electronic infrastructures — boardrooms, telecommunications systems, wireless networks, and everyday office devices like printers and conference phones. The goal is both to find hidden devices and identify potential vulnerabilities that might be exploited.
Why OSFI is Implementing These Guidelines
Financial institutions handle sensitive data and transactions daily, making them prime targets for espionage and surveillance threats. A breach or leak can profoundly impact both financial stability and institutional reputation.
OSFI’s updated guidelines — designed to align with internationally recognized standards, like those in Europe — underscore the country’s commitment to proactively protecting both financial integrity and the confidentiality of sensitive data.
Common Challenges in Compliance
Institutions are well aware of the importance of compliance, but many are finding challenges in implementing TSCM due, in part, to misconceptions about what it fully entails.
While traditional cybersecurity measures (e.g. firewalls, antivirus software, password protections) remain important, they don’t wholly address hidden surveillance risks and vulnerabilities. Employee-owned devices, unsecured applications, or simple human oversight can unintentionally open doors to threats.
Achieving compliance involves a combination of technical and organizational measures, including comprehensive education and awareness across all levels of staff.
Steps to Meet OSFI TSCM Requirements
To successfully navigate OSFI’s guidelines, institutions should consider the following:
- Conduct thorough risk assessments. Evaluate current security practices to identify vulnerabilities specific to https://pinkerton.com/our-insights/blog/technical-surveillance-countermeasures-to-prevent-corporate-espionage.
- Engage TSCM specialists. Work with experts like Pinkerton who specialize in TSCM to perform detailed inspections and offer tailored recommendations.
- Develop clear, actionable policies. Establish and communicate specific procedures and guidelines to address identified risks effectively.
- Establish regular employee training. Implement ongoing educational initiatives to help employees recognize and respond to potential surveillance risks.
- Perform routine physical and electronic security audits. Establish regular schedules for reassessing security measures to adapt to new and evolving threats.
Consequences of Not Complying with OFSI Security Guidelines
OSFI has clearly stated the potential consequences of non-compliance, including substantial financial penalties and increased oversight. But beyond regulatory repercussions, the most enduring impact may be on an institution’s reputation. Clients and partners place considerable trust in financial companies to safeguard their information and assets, and any breach of that trust can be profoundly damaging.
The Path Forward
Canada’s financial sector is accustomed to oversight. Regulations aren’t new, and neither is the pressure to comply. But OSFI’s latest Integrity and Security guidelines, coming into full force this July, are practical instructions for organizations to protect the trust they’ve earned from their clients.
TSCM compliance, therefore, is a signal that organizations understand what’s really at stake — that in a world increasingly defined by hidden risks, they’re ready. And readiness, more than ever, is what sets industry leaders apart
