Rybolov Note: this is part 2 in a series about S.773.  Go read the bill here.  Go read part one here. Go read part 3 here. Go read part four here.  Go read part 5 here. =)

SEC. 7. LICENSING AND CERTIFICATION OF CYBERSECURITY PROFESSIONALS. This section has received quite a bit of airtime around the blagosphere.  Everybody thinks that they’ll need some kind of license from the Federalies to run nessus.  Hey, maybe this is how it will all end up, but I think this provision will end up stillborn.

I know the NIST folks have been working on licensing and certification for some time, but they usually run into the same problems:

• Do we certify individuals as cybersecurity professionals?
• Do we certify organizations as cybersecurity service providers?
• What can the Government do above and beyond what the industry provides? (ISC2, SANS, 27001, etc)
• NIST does not want to be in the business of being a licensure board.

Well, this is my answer (I don’t claim that these are my opinion):

• Compulsory: the Government can require certifications/licensure for certain job requirements.  Right now this is managed by HR departments.
• Existing Precedent: We’ve been doing this for a couple of years with DoDI 8570.01M, which is mandatory for DoD contracts.  As much as I think industry certification is a pyramid scheme, I think this makes sense in contracting for the Government because it’s the only way to ensure some kind of training for security staff.If the Government won’t pay for contractor training (and they shouldn’t) and the contractor won’t pay for employees to get training because their turnover rate is 50% in a year, it’s the only way to ensure some kind of training and professionalization of the staff.  Does this scale to the rest of the country?  I’m not sure.
• Governance and Oversight: The security industry has too many different factions.  A Government-ran certification and license scheme would provide some measure of uniformity.

Honestly, this section of the bill might make sense (it opens up a bigger debate) except for one thing:  we haven’t defined what “Cybersecurity Services” are.  Let’s face it, most of what we think are “security” services are really basic IT management services… why should you need a certification to be the goon on the change control board.  However, this does solve the “problem” of hackers who turn into “researchers” once they’re caught doing something illegal.  I just don’t see this as that big of a problem.

Verdict: Strange that this isn’t left up to industry to handle.  It smells like lobbying by somebody in ISC2 or SANS to generate a higher demand for certs.  Unless this section is properly scoped and extensively defined, it needs to die on the cutting room floor–it’s too costly for almost no value above what industry can provide.  If you want to provide the same effect with almost no cost to the taxpayers, consider something along the 8570.01 approach in which industry runs the certifications and specific certifications are required for certain job titles.

SEC. 8. REVIEW OF NTIA DOMAIN NAME CONTRACTS. Yes, there is a bunch of drama-llama-ing going on between NTIA, ICANN, Verisign, and a cast of a thousand.  This section calls for a review of DNS contracts by the Cybersecurity Advisory Panel (remember them from section 3?) before they are approved.  Think managing the politics of DNS is hard now?  It just got harder–you ever try to get a handful of security people to agree on anything?  And yet, I’m convinced that either this needs to happen or NTIA needs to get some clueful security staffers who know how to manage contracts.

Verdict: DNSSEC is trendy thanks to Mr Kaminski.  I hate it when proposed legislation is trendy.  I think this provision can be axed off the bill if NTIA had the authority to review the security of their own contracts.  Maybe this could be a job for the Cybersecurity Advisor instead of the Advisory Panel?

SEC. 9. SECURE DOMAIN NAME ADDRESSING SYSTEM. OK, the Federal Government has officially endorsed DNSSEC thanks to some OMB mandates.  Now the rest of the country can play along.  Seriously, though, this bill has some scope problems, but basically what we’re saying is that Federal agencies and critical infrastructure will be required to implement DNSSEC.

Once again, though, we’re putting Commerce in charge of the DNSSEC strategy.  Commerce should only be on the hook for the standards (NIST) and the changes to the root servers (NTIA).  For the Federal agencies, this should be OMB in charge.  For “critical infrastructure”, I believe the most appropriate proponent agency is DHS because of their critical infrastructure mission.

And as for the rest of you, well, if you want to play with the Government or critical infrastructure (like the big telephone and network providers), it would behoove you to get with the DNSSEC program because you’re going to be dragged kicking and screaming into this one.  Isn’t the Great InfoSec Trickle-Down Effect awesome?

Verdict: If we want DNSSEC to happen, it will take an act of Congress because the industry by itself can’t get it done–too many competing interests.  Add more tasks to the agencies outside of Commerce here, and it might work.

Awesome Capitol photo by BlankBlankBlank.

SEC. 10. PROMOTING CYBERSECURITY AWARENESS. Interesting in that this is tasked to Commerce, meaning that the focus is on end-users and businesses.

In a highly unscientific, informal poll with a limited sample of security twits, I confirmed that nobody has ever heard of Dewie the Webwise Turtle.  Come on, guys, “Safe at any speed”, how could you forget that?  At any rate, this already exists in some form, it just has to be dusted off and get a cash infusion.

Verdict: Already exists, but so far efforts have been aimed at users.  The following populations need awareness: small-medium-sized businesses (SMBs), end-users, owners of critical infrastructure, technology companies, software developers.  Half of these are who DHS is dealing with, and this provision completely ignores DHS’s role.

SEC. 11. FEDERAL CYBERSECURITY RESEARCH AND DEVELOPMENT. This section is awesome to read, it’s additions to the types of research that NSF can fund and extensions of funding for the existing types of research.  It’s pretty hard to poke holes in, and based on back-of-the-envelope analysis, there isn’t much that is missing by way of topics that need to be added to research priorities.  What I would personally like to see is a better audit system not designed around the accounting profession’s way of doing things.  =)

Verdict: Keep this section intact.  If we don’t fund this, we will run into problems 10+ years out–some would say we’re already running into the limitations of our current technology.

SEC. 12. FEDERAL CYBER SCHOLARSHIP-FOR-SERVICE PROGRAM. This is an existing program, and it’s pretty good.  Basically you get a scholarship with a Government service commitment after graduation.  Think of it as ROTC-light scholarships without bullets and trips to SW Asia.

Verdict: This is already there.  This section of the bill most likely is in to get the program funded out to 2014.

• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 1
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 3
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 4
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 5
• The World Asks: is S.773 Censorship?

Some of my friends (and maybe myself) will be teaching the NIST Framework for FISMA in May and June with Potomac Forum.   This really is an awesome program.  Some highlights:

• Attendance is limited to Government employees only so that you can talk openly with your peers.
• Be part of a cohort that trains together over the course of a month.
• The course is 5 Fridays so that you can learn something then take it back to work the next week.
• We have a Government speaker ever week, from the NIST FISMA guys to agency CISOs and CIOs.
• No pitching, no marketing, no product placement (OK, maybe we’ll go through DoJ’s CSAM but only as an example of what kinds of tools are out there) , no BS.

See you all there!

• Security Automation Developers Conference Slides
• C&A Seminar, October 15th and 16th
• Comments on SCAP 2008
• New SP 800-60 is Out, Categorize Yerselves Mo Better
• The “Off The Record” Track

“Drawn” by an infosec engineer known simply as “TomBot” and passed down in email for years.  Click the diagram to get a bigger version.

Network Diagram by TomBot.

• Et Tu, TIC?
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 2
• When Standards Aren’t Good Enough
• Security Assessment Economics
• A Step Inside the Guerilla CISO’s Mind

Rybolov’s comment: This is Ian’s response to the comments for his post on Cybersecurity Coming to a Boil.  It was such a good dialog that he wanted to make a large comment which as we all know, eventually transforms itself into a blog post.  =)

You are making some excellent points; putting the leadership of the Administration’s new Cyber security initiative directly in the White House might appear to be a temporary solution or a quick fix. From my point of view, it looks more like an honest approach. By that I mean that I think the Administration is acknowledging a few things:

• This is a significant problem
• There is no coherent approach across the government
• There is no clear leadership or authority to act on the issue across the government
• Because of the perception that a large budget commitment will have to be allocated to any effective solution, many Agencies are claiming leadership or competing for leadership to scoop up those resources
• The Administration does not know what the specific solution they are proposing is — YET

I think this last point is the most important and is driving the 60-day security assessment. I also think that assessment is much more complex than a simple review of FISMA scores for the past few years. I suspect that the 60-day review is also considering things like legal mandates and authorities for various aspects of Cyber security on a National level. If that is the case, I’m not familiar with a similar review ever having taken place.

2004 World Cyber Games photo by jurvetson.  Contrary to what the LiquidMatrix Security folks might think, the purpose of this post isn’t to jam “cyber” into every 5th word.  =)

So, where does this take us? Well, I think we will see the Cyber Security Czar, propose a unified policy, a unified approach and probably some basic enabling legislation. I suspect that this will mean that the Czar will have direct control over existing programs and resources. I think the Cyber Security Czar taking control of Cyber Security-related research programs will be one of the most visible first steps toward establishing central control.

From this we will see new organizational and reporting authorities that will span existing Agencies. I think we can also anticipate that we will see new policies put in place and a new set of guidelines of minimum level of security capabilities mandated for all Agency networks (raising bottom-line security). This last point will probably prove to be the most trying or contentious effort within the existing Agency structure. It is not clear how existing Agencies that are clearly underfunding or under supporting Cyber Security will be assessed. It is even less clear where remedial funding or personnel positions will come from. And the stickiest point of all is…. how do you reform the leadership and policy in those Agencies to positively change their security culture? I noticed that someone used the C-word in response to my initial comments. This goes way beyond compliance. In the case of some Federal Agencies and perhaps some industries we may be talking about a complete change sea-change with respect to the emphasis and priority given to Cyber Security.

These are all difficult issues. And I believe the Administration will address them one step at a time.
In the long-term it is less clear how Cyber Security will be managed. The so-called war on drugs has been managed by central authority directly from the White House for decades. And to be sure, to put a working national system together that protects our Government and critical national infrastructure from Cyber attack will probably take a similar level of effort and perhaps require a similar long-term commitment. Let’s just hope that it is better thought-out and more effective than the so-called war on drugs.

Vlad’s point concerning Intelligence Community taking the lead with respect to Cyber Security is an interesting one, I think the Intelligence Community will be important players in this new initiative. To be frank, between the Defense and Intelligence Communities there is considerable technical expertise that will be sorely needed. However, for legal reasons, there are real limits as to what the Intelligence and Defense Communities can do in many situations. This is a parallel problem to the Cyber Security as a Law Enforcement problem. The “solution” will clearly involve a variety of players each with their own expertise and authorities. And while I am not anticipating that Tom Clancy will be appointed the Cyber Security Czar any time soon. I do expect that a long-term approach will require the stand-up of either a new organization empowered to act across current legal boundaries (that will require new legislation), or a new coordinating organization like the Counter Terrorism Center, that will allow all of the current players bring their individual strengths and authorities to focus on a situation on a case by case basis as they are needed (that may require new legislation).

If you press me, I think a joint coordinating body will be the preferred choice of the Administration. Everyone likes the idea of everyone working and playing well together. And, that option also sounds a lot less expensive. And that is important in today’s economic climate.

• Cyber Security coming to a boil
• Beware the Cyber-Katrina!
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 4
• Et Tu, TIC?
• The 10 CAG-egorically Wrong Ways to Introduce Standards

So way back in the halcyon days of 2008 when Dan Philpott, Chris Burton, Ian Charters, and I went to the NIST SCAP Conference.  Just by a strange coincidence, Ed Bellis threw out a twit along the lines of “wow, I wish there was a way to import and export all this vulnerability data” and I replied back with “Um, you mean like SCAP?

Fast forward 6 months.  Ed Bellis has been busy.  He delivered this presentation at SnowFROC 2009 in Denver:

So some ideas I have about what Ed is doing:

#1 This vulnerability correllation and automation should be part of vulnerability assessment (VA) products.  In fact, most VA products include some kind of ticketing and workflow nowadays if you get the “enterprise edition”. That’s nice, but…

#2 The VA industry is a broken market with compatibility in workflow.  Everybody wants to sell you *their* product to be the authoritative manager. That’s cool and all, but what I really need is the connectors to your competitor’s products so that I can have one database of vulnerabilities, one set of charts to show my auditors, and one trouble ticket system. SCAP helps here but only for static, bulk data transfers–that gets ugly really quickly.

#3 Ed’s correllation and automation software is a perfect community project because it’s a conflict of interest for any VA vendor to write it themselves. And to be honest, I wouldn’t be surprised if there aren’t a dozen skunkwork projects that people will admit to creating just in the comments section of this post. I remember 5 years ago trying to hack together some perl to take the output from the DISA SRR Scripts and aggregate them into a .csv.

#4 The web application security world needs to adopt SCAP. So far it’s just been the OS and shrinkwrapped application vendors and the whole race to detection and patching. Now the interesting part to me is that the market is all around tying vulnerabilities to specific versions of software and a patch, where when you get to the web application world, it’s more along the lines of one-off misconfigurations and coding errors. It takes a little bit of a mindshift in the vulnerability world, but that’s OK in my book.

#5 This solution is exactly what the Government needs and is exactly why SCAP was created. Imagine you’re the Federal Government with 3.5 million desktops, the only way you can manage all those is through VA automation and a tool that aggregates information from various VA products across multiple zones of trust, environments, and even organizations.

#6 Help Ed out! We need this.

• Save a Kitten, Write SCAP Content
• Security Automation Developers Conference Slides
• NIST and SCAP; Busting a cap on intruders Part 1
• Comments on SCAP 2008
• Federated Vulnerability Management

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.

• In Response to “Cyber Security Coming to a Boil” Comments….
• Inside the Obama Administration’s Cyber Security Agenda
• Beware the Cyber-Katrina!
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 3
• The World Asks: is S.773 Censorship?