The Spanish Civil War and the Rise of Cyberwar

Posted June 22nd, 2009 by

As usual, I greatly enjoyed your blog from 17 June, A Short History of Cyberwar Look-alikes, Rybolov. Moreover I really appreciated your historical examples. It warms my heart whenever an American uses the Russo-Japanese War of 1904/5 as a historic example of anything. Most Americans have never even heard of it. Yet, it is important event today if for no other reason than it established the tradition of having the US President intercede as a peace negotiator and win the Nobel Prize for Peace for his efforts. Because of this, some historians mark it as the historic point at which the US entered the world stage as a great power. By the way the President involved was Teddy Roosevelt.

Concerning the state and nature of Cyberwar today, I’ve seen Rybolov’s models and I think they make sense. Cyberwar as an extension of electronic warfare makes some sense. The analogy does break down at some point because of the peculiarity of the medium. For example, when considering exploitation of SCADA systems as we have seen in the Baltic States and in a less focused manner here in North America, it is hard to see a clear analogy in electronic warfare. The consequences look more like old-fashion kinetic warfare. Likewise, there are aspects of Cyberwarfare that look like good old-fashion human intelligence and espionage. Of course I also have reservations with the electronic warfare model based on government politics. Our friends at NSA have been suggesting that Cyberwarfare is an extension of signals intelligence for years, with the accompanying claim that they (NSA) should have the technical, legal, and of course budgetary resources that go along with it.

I’ve also have seen other writers propose other models of Cyberwarfare and they tend to be a mixed bag at best. At worst, many of the models proposed appear to be the laughable writings of individuals with no more insight to or knowledge of intelligence operations beyond the latest James Bond movie. My own opinion is that two models or driving forces behind international Cyberwarfare activity. The first is pure opportunism. Governments and criminal organizations alike, even authoritarian governments have seen the Hollywood myths and the media hysteria about hacker exploits. Over time, criminal gangs have created and expanded on their cyber capabilities driven by a calculation of profits and risks much like conventional businesses. Combine an international banking environment that allows funds to be transferred across borders with little effort and less time and an international legal environment that is largely out of touch with the Internet and international telecommunications, and we have a breeding ground for Cyber criminals in which the risks of cross-border criminal activity is often much less risky than domestic criminal activity.

As successful Cyber criminal gangs have emerged in totalitarian regimes, it shouldn’t be a surprise that eventually the governments involved would eventually take an interest in both their activities and techniques. There are several reasons that totalitarian government might want to do this. Perhaps the simplest motivation is that the corrupt officials would be drawn to share in the profits in exchange for protection. In addition, the intelligence arms of these nations could also leverage their services and techniques at a fraction of the cost of developing similar capabilities themselves. Additionally, using these capabilities would also provide the intelligence agencies and even the host government with an element of deniability if operations assigned to the criminal gangs were detected.

Monument to the International Brigade photo by Secret Pilgrim.  For more information, read the history of the International Brigade.

Perhaps the most interesting model of development and Cyberwarfare activity today would be based on the pre-WW II example of the Spanish Civil War. After World War I, a period of mental and societal exhaustion followed on the part of all participating nations. This was quickly follow by a period of self-assessment and rebuilding. In the case of the defeated Germany the reconstruction period protracted due to difficult economic conditions, in part created by the harsh conditions of surrender imposed by the winning European governments.

It was also important to remember that these same victorious European governments undermined many of social and moral underpinnings of German society by systematically all the basis of traditional German government and governmental legitimacy without regard for what should replace it. The assessments of most historians is that these factors combined to sow the seed of hatred against the victorious powers and created a social climate in which a return to open warfare at some time in the future was seen as unavoidable and perhaps desirable. The result was that Germany actively prepared and planned for what was seen as the commonly inevitable war in the future. New systems and technologies were considered, tested. However, treaty limitations also hampered some of these efforts.

In the Soviet Union a similar set of conclusions developed during this period of history within the ruling elite, specifically that renewed war with Germany was inevitable in the near term. Like Germany, the Soviet Union also actively prepared for this war. Likewise they considered and studied new technologies and approaches to war. Somewhat surprisingly, they also secretly conspired with the Germans to provide them with secret proving grounds and test facilities to study some to the new technologies and approaches to war that would otherwise have been banned under provisions of the peace treaties of World War I.

So, when Civil War broke out in Spain in the summer of 1936, both Germany and the Soviet Union were positively delirious at the prospects of testing their new military equipment and theories out under battlefield conditions but, without the risks of participating in a real shooting war as an active belligerent. So, both governments sent every military technology possible to their proxies in Spain under the auspices of “aid”. In some cases they even sent “advisors” who were nothing less than active soldiers and pilots in the conflict. At first, this activity took place under a shroud of secrecy. But, when you send military equipment and people to fight in foreign lands it usually takes no time at all for someone to notice that, “those guys aren’t from here”.

Bomber During the Spanish Civil War photo by -Merce-.  Military aviation, bombing in particular, was one of the new technologies that was tested during the Spanish Civil War.

Since the fall of the Soviet Union, I think the world has looked at the United States as the world’s sole superpower. Many, view this situation with fear and suspicion. Even some of our former Cold War allies have taken this view. Certainly our primary Cold War adversaries have adopted this stance. If you look at contemporary Chinese and Russian military writing it is clear that they have adopted a position similar to the pre- World War II notion that war between the US and Russia or war between the US and China is inevitable. To make matters worse, during much of the Cold War the US never seemed to pull it together militarily long enough to actually win a war. Toward the end of the Cold War we started smacking smaller allies of the Soviet Union like Grenada and succeeded.

We then moved on to give Iraq a real drubbing after the Cold War. The so-call “Hyperwar” in Iraq terrified the Russians and Chinese alike. The more they studied what we did in Iraq the more terrified they became. On of the many counters they have written about is posing asymmetric threats to the US, that is to say threatening the US in a way in which it is uniquely, or unusually vulnerable. One of these areas of vulnerability is Cyberspace. All sorts of press reporting indicate that the Russians and Chinese have made significant investments in this area. The Russians and Chinese deny these reports as quickly as they emerge. So, it is difficult to determine what the truth is. The fact that the Russians and Chinese are so sensitive to these claims may be a clear indication that they have active programs – the guilty men in these cases have a clear record of protesting to much when they are most guilty.

Assuming that all of this post-Cold War activity is true, I believe this puts us in much the same situation that existed in the pre-World War II Spanish Civil War era. I think the Russian and Chinese governments are just itching to test and refine their Cyberwarfare capabilities. But, at the same time I think they want to operate in a manner similar to how the Germans and the Soviet Union operated in that conflict. I think they want and are testing their capabilities but in a limited way that provides them with some deniability and diplomatic cover. This is important to them because the last thing they want now is to create a Cyber-incident that will precipitate a general conflict or even a major shift in diplomatic or trade relationships.

One of the major differences between the Spanish Civil War example and our current situation of course is that there is no need for a physical battlefield to exist to provide as a live testing environment for Cyber weapons and techniques. However, at least in the case of Russia with respect to Georgia, they are exploiting open military conflicts to use Cyberwar techniques when those conflicts do arise. We have seen similar, but much smaller efforts on the part of Iran, and the Palestinian Authority as embrace what is seen as a cheap and low risk weapon. However, their efforts seem to be more reactionary and rudimentary. The point is, the longer this game goes on without serious consequence the more it will escalate both vertically (in sophistication) and horizontally (be embraced by more countries). Where all of this will lead is anyone guess. But, I think the safe money is betting that the concept of Cyberwar is here to stay and eventually the tools and techniques and full potential of Cyberwar will eventually be used as part of as part of a strategy including more traditional weapons and techniques.



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Why We Need PCI-DSS to Survive

Posted June 9th, 2009 by

And by “We”, I mean the security industry as a whole.  And yes, this is your public-policy lesson for today, let me drag my soapbox over here and sit for a spell while I talk at you.

By “Survive”, I mean that we need some kind of self-regulatory framework that fulfills the niche that PCI-DSS occupies currently. Keep reading, I’ll explain.

And the “Why” is a magical phrase, everybody say it after me: self-regulatory organization.  In other words, the IT industry (and the Payment Card Industry) needs to regulate itself before it crosses the line into being considered for statutory regulation (ie, making a law) by the Federal Government.

Remember the PCI-DSS hearings with the House Committe on Homeland Security (AKA the Thompson Committee)?  All the Security Twits were abuzz about it, and it did my heart great justice to hear all the cool kids become security and public policy wonks at least for an afternoon.  Well, there is a little secret here and that is that when Congress gets involved, they’re gathering information to determine if they need to regulate an industry.  That’s about all Congress can do: make laws that you (and the Executive Branch) have to follow, maybe divvy up some tax money, and bring people in to testify.  Other than that, it’s just positioning to gain favor with other politicians and maybe some votes in the next election.

Regulation means audits and more compliance.  They go together like TCP and IP.  Most regulatory laws have at least some designation for a party who will perform oversight.  They have to do this because, well, if you’re not audited/assessed/evaluated/whatever, then it’s really an optional law, which doesn’t make sense at all.

Yay Audits photo by joebeone.

Another magical phrase that the public policy sector can share with the information security world: audit burden.  Audit burden is how much a company or individual pays both in direct costs (paying the auditors) and in indirect costs (babysitting the auditors, producing evidence for the auditors, taking people away from making money to talk to auditors, “audit requirements”, etc).  I think we can all agree that low audit burden is good, high audit burden is bad.  In fact, I think that’s one of the problems with FISMA as implemented is that it has a high audit burden with moderately tangible results. But I digress, this post is about PCI-DSS.

There’s even a concept that is mulling around in the back of my head to make a metric that compares the audit burden to the amount of security that it provides to the amount of assurance that it provides against statutory regulation.  It almost sounds like the start of a balanced scorecard for security management frameworks, now if I could get @alexhutton to jump on it, his quant brain would churn out great things in short order.

But this is the lesson for today: self-regulation is preferrable to legislation.

  • Self-regulation is defined by people in the industry.  Think about the State Bar Association setting the standards for who is allowed to practice law.
  • Standards ideally become codified versions of “best practices”.  OK, this is if they’re done correctly, more to follow.
  • Standards are more flexible than laws.  As hard/cumbersome as it is to change a standard, the time involved in changing a law is prohibitive most of the time unless you’re running for reelection.
  • Standards sometimes can be “tainted” to force out competition, laws are even more so.

The sad fact here is that if we don’t figure out as an industry how to make PCI-DSS or any other forms of self-regulation work, Congress will regulate for us.  Don’t like PCI-DSS because of the audit burden, wait until you have a law that requires you to do the same controls framework.  It will be the same thing, only with bigger penalties for failure, larger audit burdens to avoid the larger penalties, larger industries created to satisfy the market demand for audit.  Come meet the new regulatory body, same as the old only bigger and meaner. =)

However, self-regulation works if you do it right, and by right I mean this:

  • The process is transparent and not the product of a secret back-room cabbal.
  • Representation from all the shareholders.  For PCI-DSS, that would be Visa/MasterCard, banks, processors, large merchants, small merchants, and some of the actual customers.
  • The standards committee knows how to compromise and come to a consensus.  IE, we can’t have both full hard drive encryption, a WAF, code review, and sacrificing of chickens in the server room, so we’ll make one of the 4 mandatory.
  • The regulatory organization has a grievance process for its constituency to present valid (AKA “Not just more whining”) discrepencies in the standards and processes for clarification or consideration for change.
  • The standard is “owned” by every member of the constituency.  Right now, people governed by PCI-DSS are not feeling that the standard is their standard and that they have a say in what comprises the standard and that they are the ones being helped by the standard.  Some of that is true, some of that is an image problem.  The way you combat this is by doing the things that I mentioned in the previous bullets.

Hmm, sounds like making an ISO standard, which brings its own set of politics.

While we need some form of self-regulation, right now PCI-DSS and ISO 27001 are the closest that we have in the private sector.  Yeah, it sucks, but it sucks the least, just like our form of government.



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When Standards Aren’t Good Enough

Posted May 22nd, 2009 by

One of the best things about being almost older than dirt is that I’ve seen several cycles within the security community.  Just like fashion and ladies’ hemlines, if you pay attention long enough, you’ll see history repeat itself, or something that closely resembles history.  Time for a short trip “down memory lane…”

In the early days of computer security, all eyes were fixed on Linthicum and the security labs associated with the NSA.  In the late 80’s and early 90’s the NSA evaluation program was notoriously slow – glacial would be a word one could use…  Bottom line, the process just wasn’t responsive enough to keep up with the changes and improvements in technology.  Products would be in evaluation for years before coming out of the process with their enabling technology nearly obsolete.   It didn’t matter, it was the only game in town until NIST and the Common Criteria labs  came onto the scene.  This has worked well, however the reality is, it’s not much better at vetting and moving technology from vendors to users.  The problem is, the evaluation process takes time and time means money, but it also means that the code submitted for evaluation will most likely be several revisions old by the time it emerges from evaluation.   Granted, it may only be 6 months, but it might take a year – regardless, this is far better than before.

So…  practically speaking, if the base version of FooOS submitted for evaluation is, say Version 5.0.1, several revisions —  each solving operational problems affecting the  organization — may have been released.  We may find that we need to run Version 5.6.10r3 in order to pass encrypted traffic via the network.  Because we encrypt traffic we must use FIPS-Level 2 certified code – but in the example above, the validated version of the FooOS will not work in our network…    What does the CISO do?  We’ll return to this in a moment, it gets better!

In order to reach levels of FIPS-140 goodness, one vendor in particular has instituted “FIPS Mode.”  What this does is require administration of the box from apposition directly in front  of the equipment, or at the length of your longest console cable…  Clearly, this is not suitable for organizations with equipment deployed worldwide to locations that do not have qualified administrators or network engineers.  Further, having to fly a technician to Burundi to clear sessions on a box every time it becomes catatonic is ridiculous at worst.  At best it’s not in accordance with the network concept of operations.  How does the CISO propose a workable, secure solution?


Standard Hill photo by timparkinson.

Now to my point.  (about time Vlad)   How does the CISO approach this situation?  Allow me to tell you the approach I’ve taken….

1. Accept the fact that once Foo OS has achieved a level of FIPS-140 goodness, the likelihood that the modules of code within the OS implementing cryptographic functionality in follow-on versions have not been changed.  This also means you have to assume the vendor has done a good job of documenting the changes to their baseline in their release notes, and that they HAVE modular code…

2. Delve into vendor documentation and FIPS-140 to find out exactly what “FIPS Mode” is, its benefits and the requirement.  Much of the written documentation in the standard deals with physical security of the cryptographic module itself (e.g., tamper-evident seals) – but most helpful is Table 1.

Security Level  1 Security Level 2 Security Level 3 Security Level 4
Cryptographic

Module Specification

Specification of cryptographic module, cryptographic boundary, Approved algorithms, and Approved modes of operation. Description of cryptographic module, including all hardware, software, and firmware components. Statement of module security policy.
Cryptographic Module Ports and Interfaces Required and optional interfaces. Specification of all interfaces and of all input and output data paths. Data ports for unprotected critical security parameters logically or physically separated from other data ports.
Roles, Services, and Authentication Logical separation of required and optional roles and services Role-based or identity-based operator authentication Identity-based operator authentication.
Finite State Model Specification of finite state model.  Required and optional states.  State transition diagram and specification of state transitions.
Physical Security Production grade equipment. Locks or tamper evidence. Tamper detection and response for covers and doors. Tamper detection and response envelope.  EFP or EFT.
Operational Environment Single operator. Executable code. Approved integrity technique. Referenced PPs evaluated at EAL2 with specified discretionary access control mechanisms and auditing. Referenced PPs plus trusted path evaluated at EAL3 plus security policy modeling. Referenced PPs plus trusted path evaluated at EAL4.
Cryptographic Key Management Key management mechanisms: random number and key generation, key establishment, key distribution, key entry/output, key storage, and key zeroization.
Secret and private keys established using manual methods may be entered or output in plaintext form. Secret and private keys established using manual methods shall be entered or output encrypted or with split knowledge procedures.
EMI/EMC 47 CFR FCC Part 15. Subpart B, Class A (Business use). Applicable FCC requirements (for radio). 47 CFR FCC Part 15. Subpart B, Class B (Home use).
Self-Tests Power-up tests: cryptographic algorithm tests, software/firmware integrity tests, critical functions tests. Conditional tests.
Design Assurance Configuration management (CM). Secure installation and generation. Design and policy correspondence. Guidance documents. CM system. Secure distribution. Functional specification. High-level language implementation. Formal model. Detailed explanations (informal proofs). Preconditions and postconditions.
Mitigation of Other Attacks Specification of mitigation of attacks for which no testable requirements are currently available.

Summary of Security Requirements From FIPS-140-2

Bottom line — some “features” are indeed useful,  but this one particular vendor’s implementation into a “one-size fits all” option tends to limit the use of the feature at all in some operational scenarios (most notably, the one your humble author is dealing with.)  BTW, changing vendors is not an option.

3. Upon analyzing the FIPS requirements against operational needs, and (importantly) the environment the equipment is operating in, one has to draw the line between “operating in vendor FIPS Mode,” and using FIPS 140-2 encryption.

4. Document the decision and the rationale.

Once again, security professionals have to help managers to strike a healthy balance between “enough” security and operational requirements.   You would think that using approved equipment, operating systems, and vendors using the CC evaluation process would be enough.  Reading the standard, we see the official acknowledgement that “Your Mileage May Indeed Vary:” TM

While the security requirements specified in this standard are intended to maintain the security provided by a cryptographic module, conformance to this standard is not sufficient to ensure that a particular module is secure. The operator of a cryptographic module is responsible for ensuring that the security provided by a module is sufficient and acceptable to the owner of the information that is being protected and that any residual risk is acknowledged and accepted.”     FIPS 140-2 Sec 15, Qualifications

The next paragraph constitutes validation of the approach I’ve embraced:

“Similarly, the use of a validated cryptographic module in a computer or telecommunications system does not guarantee the security of the overall system. The responsible authority in each agency shall ensure that the security of the system is sufficient and acceptable.”  (Emphasis added.)

One could say, “it depends,” but you wouldn’t think so at first glance – it’s a Standard for Pete’s sake!

Then again, nobody said this job would be easy!

Vlad



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The World Asks: is S.773 Censorship?

Posted May 15th, 2009 by

Here in the information assurance salt mines, we sure do loves us some conspiracies, so here’s the conspiracy of the month: S.773 gives the Government the ability to view your private data and the President disconnect authority over the Internet, which means he can sensor it.

Let’s look at the sections and paragraphs that would seem to say this:

Section 14:

(b) FUNCTIONS- The Secretary of Commerce–

(1) shall have access to all relevant data concerning such networks without regard to any provision of law, regulation, rule, or policy restricting such access;

Section 18: The President–

(2) may declare a cybersecurity emergency and order the limitation or shutdown of Internet traffic to and from any compromised Federal Government or United States critical infrastructure information system or network;

(6) may order the disconnection of any Federal Government or United States critical infrastructure information systems or networks in the interest of national security;

Taken completely by itself, it would seem like this gives the president the authorities to do all sorts of wrong stuff, all he has to do is to declare something as critical infrastructure and declare it compromised or in the interests of national security.  And some people have:

And some movies (we all love movies):

Actually, Shelly is pretty astute and makes some good points, she just doens’t have the background in information security.

It makes me wonder since when have people considered social networking sites or the Internet as a whole as “critical infrastructure”. Then the BSOFH in me things “Ye gods, when did our society sink so low?”

Now, as far as going back to Section 14 of S.773, it exists because most of the critical infrastructure is privately-held.  There is a bit of history to understand here and that is that the critical infrastructure owners and operators are very reluctant to give the information on their piece of critical infrastructure to the Government.  Don’t blame them, I had the same problem as a contractor: if you give the Government information, the next step is them telling you how to change it and how to run your business.  Since the owners/operators are somewhat non-helpful, the Government needs more teeth to get what it needs.

But as far as private data traversing the critical infrastructure?  I think it’s a stretch to say that’s part of the requirements of Section 14, it’s to collect data “about” (the language of the bill) the critical infrastructure, not “processed, stored, or forwarded” on the critical infrastructure. But yeah, let’s scope this a little bit better, CapHill Staffers.

On to Section 18.  Critical infrastructure is defined elsewhere in law.  Let’s see the definitions section from HSPD-7, Critical Infrastructure Identification, Prioritization, and Protection:

In this directive:

The term “critical infrastructure” has the meaning given to that term in section 1016(e) of the USA PATRIOT Act of 2001 (42 U.S.C. 5195c(e)).

The term “key resources” has the meaning given that term in section 2(9) of the Homeland Security Act of 2002 (6 U.S.C. 101(9)).

The term “the Department” means the Department of Homeland Security.

The term “Federal departments and agencies” means those executive departments enumerated in 5 U.S.C. 101, and the Department of Homeland Security; independent establishments as defined by 5 U.S.C. 104(1);Government corporations as defined by 5 U.S.C. 103(1); and the United States Postal Service.

The terms “State,” and “local government,” when used in a geographical sense, have the same meanings given to those terms in section 2 of the Homeland Security Act of 2002 (6 U.S.C. 101).

The term “the Secretary” means the Secretary of Homeland Security.

The term “Sector-Specific Agency” means a Federal department or agency responsible for infrastructure protection activities in a designated critical infrastructure sector or key resources category. Sector-Specific Agencies will conduct their activities under this directive in accordance with guidance provided by the Secretary.

The terms “protect” and “secure” mean reducing the vulnerability of critical infrastructure or key resources in order to deter, mitigate, or neutralize terrorist attacks.

And referencing the Patriot Act gives us the following definition for critical infrastructure:

In this section, the term “critical infrastructure” means systems and assets, whether physical or virtual, so vital to the United States that the incapacity or destruction of such systems and assets would have a debilitating impact on security, national economic security, national public health or safety, or any combination of those matters.

Since it’s not readily evident from what we really consider to be critical infrastructure, let’s look at the implemention of HSPD-7.  They’ve defined critical infrastructure sectors and key resources, each of which have a sector-specific plan on how to protect them.

  • Agriculture and Food
  • Banking and Finance
  • Chemical
  • Commercial Facilities
  • Communications
  • Critical Manufacturing
  • Dams
  • Defense Industrial Base
  • Emergency Services
  • Energy
  • Government Facilities
  • Healthcare and Public Health
  • Information Technology
  • National Monuments and Icons
  • Nuclear Reactors, Materials and Waste
  • Postal and Shipping
  • Transportation System
  • Water

And oh yeah, S.773 doesn’t mention key resources, only critical infrastructure.  Some of this key infrastructure isn’t even networked (*cough* icons and national monuments *cough*). Also note that “Teh Interblagosphere” isn’t listed, although you could make a case that information technology and communications sectors might include it.

Yes, this is not immediately obvious, you have to stitch about half a dozen laws together, but if we didn’t do pointers to other laws, we would have the legislative version of spaghetti code.

Going back to Section 18 of S.773, what paragraph 2 does is give the President the authority to disconnect critical infrastructure or government-owned IT systems from the Internet if they have been compromised.  That’s fairly scoped, I think.  I know I’ll get some non-technical readers on this blog post, but basically one of the first steps in incident response is to disconnect the system, fix it, then restore service.

Paragraph 6 is the part that scares me, mostly because it has the same disconnect authority as paragraph 2and the same scope (critical infrastructure and but the only justification is “in the interests of national security”. In other words, we don’t have to tell you why we disconnected your systems from the Internet because you don’t have the clearances to understand.

So how do we fix this bill?

Section 14 needs an enumeration of the types of data that we can request from critical infrastructure owners and operators. Something like the following:

  • Architecture and toplogy
  • Vulnerability scan results
  • Asset inventories
  • Audit results

The bill has a definitions section–Section 23.  We need to adopt the verbiage from HSPD-7 and include it in Section 23.  That takes care of some of the scoping issues.

We need a definition for “compromise” and we need a definition for “national security”. Odds are these will be references to other laws.

Add a recourse for critical infrastructure owners who have been disconnected: At the very minimum, give them the conditions under which they can be reconnected and some method of appeal.



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Preliminary Findings on Cybersecurity Review Now Out

Posted April 1st, 2009 by

In a surprise move, the Obama administration is expected to announce abandonment of NIST’s Framework for FISMA in lieu of adopting the Payment Card Industry Data Security Standard (PCI-DSS).

In information leaked to the Guerilla-CISO staff, an undisclosed source deep inside the 60-day cybersecurity review made the following observations:

  • Since everybody is complaining that FISMA is failing, the time for change is now while the Government is still in transition chaos.
  • The leading metrics support the fact that the Payment Card Industry standards do work.
  • There exists a large, relatively inexpensive and certified workforce focused around PCI-DSS.  This is preferrable to the expensive, non-certified FISMA compliance workforce.
  • Billions of credit card transactions occur every day.  How could Visa and MasterCard be wrong?
  • WAFs and code review are all we need in a web-enabled Government 2.0 world.
  • PCI flip-flops on data encryption and the use of DLP solutions, so do we.
  • Since one compliance framework is as good as another, we might as well pool our resources.
  • A significant amount of money is spent on FISMA compliance.  That would all be eliminated under a PCI compliance framework.
  • Technologies such as Scanless PCI can reduce the audit burden on the agencies to a couple bottles of beer and a handshake.
  • The House testimony on the effectiveness of PCI-DSS was convincing that it is a viable standard.

In the interests of due diligence in reporting, the Guerilla-CISO staff tried to contact NIST’s Computer Security Resource Center and gained the following unofficial opinion:

“Screw those Obama guys.  Where were they when we were trying to create Government 1.0 and the FISMA Framework?  They haven’t put in the all-nighters because some yahoo at an agency lost a USB drive full of classified documents–they don’t have the experience to make this call.  I bet the administration thinks that they can outsource all responsibility to the cloud and get some ‘security through abstraction’.  Talk about gratitude for you, I’m going to go work for the International Standards Organization.”

PCI Plug-and-Play photo by ryan_franklin_az.



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Cyber Security coming to a boil

Posted March 16th, 2009 by

During his campaign, then candidate Obama promised he would, “make cyber-security the top priority that it should be in the 21st century. I’ll declare our cyber-infrastructure a strategic asset, and appoint a national cyber-adviser, who will report directly to me.” Since Obama was elected there has been a great deal of speculation as to what real-life changes in direction and policy that promise would bring.

Last month, President Obama appointed Melissa Hathaway to be a Senior Director of the National Security Council. She immediately launched a 60-day review of security of Federal IT systems. As a result of this effort, there is much speculation that at the end of the 60-day review she will be appointed the National Cyber Advisor–the so-called Cyber Security Czar.

Just this week, the Director of the National Cyber Security Center, Rod A. Beckstrom, over at the Department of Homeland Security resigned. The press reports of Beckstrom’s resignation indicate some frustration on Beckstrom’s part. His frustration seems to be primarily aimed at the National Security Agency (NSA). Beckstrom suggests that the NSA has been subverting his efforts to coordinate cyber security efforts across the intelligence community.

A good friend of mine has suggested that the resignation is simply political and an artifact of the transition from one administration to another. He further suggests that this also signals a shift from leadership in cyber security from civilian agencies toward the Intelligence Community taking its turn at leadership. I think he may be right, too. However, I think there is more history here than just a shift in policy from one administration to another.

In my opinion, this isn’t just about politics. There are two drivers for this move. First, congress and the administration recognize that that the on-going assault on government and commercial networks is a national security issue and an economic security and competitiveness issue too. In today’s economic droop people often forget that two of our greatest economic strengths are our accumulated intellectual property and our hard working human capital. Both of these assests are discounted when criminal and national groups successfully attack our nations IT infrastructure. Recognizing this is a good thing, I’m not going to recount the long history of cyber assault on Federal IT systems by international cyber criminals, and “state-sponsored entities.” Facts and figures concerning this on-going assault and the damage associated with it is just a Google search away.

The second driver for a policy shift is that congress and the administration recognize that the FBI, Justice, DHS approach to cyber security is an utter failure. This failed approach sees cyber security as a criminal problem with industry participating in its own defense on a ‘voluntary’ basis. This has led to comical activities such as FBI delegation going to Moscow with hat in hand asking the Russians for help in tracking down successful Cyber Organized Crime groups based in Russia. The fact that these groups may have had strong official or unofficial connections with the Russian government should have given the FBI an indication of the lack of cooperation they would face –- I believe in Law Enforcement circles this is usually called a “clue”. Likewise, FBI delegations to Russia trying to track down Russian Cyber attackers that may have had some direct level of state support were equally unproductive. To be fair, the FBI was placed in an impossible position when they were asked to organize delegations like this.

So that kind of sums up the civilian or “law enforcement” approach toward national cyber security.

That leaves us to consider the much discussed alternative, specifically a shift in policy toward giving the intelligence community leadership in providing cyber national security. There have been attempts in the past to give the Intelligence Community greater responsibility for cyber security, but while the Intelligence Community seemed to have the technical resources to address these responsibilities, they were often confused by the mission and hampered by legislation and culture. By temperament, the Intelligence Community is about collection and analysis of information. Once you start asking them to do something about a situation that they have studied or understand well, you are often asking them to not just change their mission but also act against the very culture that made them successful. To understand a situation, the Intelligence Community works quietly, secretly, and in the shadows. To take action, they have to emerge for the shadows and act very publically. This transition can be difficult and even disastrous. Such transitions can give you the Bay of Pigs, non-judicial detention at Gitmo, and odd-ball assassinations–all sorts of activities that people hate because the actions themselves were not “peer-reviewed” as best security practices.

It’s not that the Intelligence Community is incompetent (well everyone makes mistakes or hides them), it’s just that that transition from intelligence/information collection to public coordination, and policy leadership, with all of the very public meetings, policy reviews, and planning drives the Intelligence Community from a position of strength and expertise to new ground. Unfortunately, another strong element of the culture of the Intelligence Community is that if the President calls, “they haul…” They just can’t bring themselves to say no, even if it’s a bad idea.

That brings us to the question, who should be responsible for cyber security? Well, every government agency wants the mission because of the funding that goes with it. But, it’s not clear who has the right perspective and culture. I suspect that the right answer is to combine the experience, and technical know-how from several agencies and to develop some new capabilities. This means that leadership of the effort has to be unambiguous. That is precisely why I believe the Obama Administration will keep the leadership on their new approach to Cyber Security right inside the White House itself. That really shouldn’t be a surprise since that is exactly what the Obama as a candidate said he would do.

Enigma Machines Collection at the National Cryptologic Museum photo by brewbooks.



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