So I like reading about what people think about security and the Government.  I know, you’re all surprised, so cue shock and awe amongst my reader population.

Anyway, this week it’s Fortify and a well-placed article in NextGov.  You remember Fortify, they are the guys with the cool FUD movie about how code scanning is going to save the world.  And oh yeah, there was this gem from SC Magazine: “Fortify’s Rachwald agrees that FISMA isn’t going anywhere, especially with the support of the paper shufflers. ‘It’s been great for people who know how to fill out forms. Why would they want it to go away?'”  OK, so far my opinion has been partially tainted–somehow I think I’m supposed to take something here personal but I’m not sure exactly what.

Fortify has been trying to step up to the Government feed trough over the past year or so.  In a rare moment of being touch-feely intuitive, from their marketing I get the feeling that Fortify is a bunch of Silicon Valley technologists who think they know what’s best for DC–digital carpetbagging.  Nothing new, all y’alls been doing this for as long as I’ve been working with the Government.

Now don’t get me wrong, I think Fortify makes some good products.  I think that universal adoption of code scanning, while not as foolproof as advertised, is a good thing.  I also think that software vendors should use scanning tools as part of their testing and QA.

Fortified cité of Carcassonne photo by http2007.

Now for a couple basic points that I want to get across:

• Security is not a differentiator between competing products unless it’s the classified world. People buy IT products based on features, not security.
• The IT industry is a broken market because there is no incentive to sell secure code.
• In fact, software vendors are often rewarded market-wise because if you arrive first to market with the largest market penetration, you become the defacto standard.
• The vendors are abstracted from the problems faced by their customers thanks to the terms of most EULAs–they don’t really have to fix security problems since the software is sold with no guarantees.
• The Government is dependent upon the private sector to provide it with secure software.
• It is a conflict of interest for the vendors to accurately represent their flaws unless the Government is going to pay to have them fixed.
• It’s been proposed numerous the Government use its “huge” IT budget to require vendors to sell secure projects.
• How do you determine that a vendor is shipping a secure product?

Or more to the point, how do I as a software vendor reasonably demonstrate that I have provided a secure product to the government without a making the economics infeasible for smaller vendors, creating an industry of certifiers ala PCI-DSS and SOX, or dramatically lengthening my development/procurement schedules?  Think of the problems with common criteria, because that’s our previous attempt.

We run into this problem all the time in Government IT security, but it’s mostly at the system integrator level.  It’s highly problematic to make contract requirements that are objective, demonstrable, and testable yet still take into account threats and vulnerabilities that do not exist today.

I’ve spent the past month writing a security requirements document for integrated special-purpose devices sold to the Government.  Part of this exercise was the realization that I can require that the vendor perform vulnerability scanning, but it becomes extremely difficult to include an amount of common sense into requirements when it comes to deciding what to fix.  “That depends” keeps coming back to bite me in the buttocks time and time again.  At this point, I usually tell my boss how I hate security folks, self included, because of their indecisiveness.

The end result is that I can specify a process (Common Criteria for software/hardware, Certification and Accreditation for integration projects) and an outcome (certification, product acceptance, “go live” authorization), leave the decision-making authority with the Government, and put it in the hands of contracts officers and subject-matter experts who know how to manage security.  Problems with this technique:

• I can’t find enough contracts officers who are security experts.
• As a contractor, how do I account for the costs I’m going to incur since it’s apparently “at the whim of the Government”?
• I have to apply this “across the board” to all my suppliers due to procurement law.  This might not be possible right now for some kinds of outsourced development.
• We haven’t really solved the problem of defining what constitutes a secure product.
• We’ve just deferred the problem from a strategic solution to a tactical process depending on a handful of clueful people.

Honestly, though, I think that’s as good as we’re going to get.  Ours is not a perfect world.

And as for Fortify?  Guys, quit trying to insult the people who will ultimately recommend your product.  It’s bad mojo, especially in a town where the toes you step on today may be attached to the butt you kiss tomorrow.  =)

• Comments on SCAP 2008
• Ed Bellis’s Little SCAP Project
• Sir Bruce Mentions FDCC, World Goes Nuts
• When Standards Aren’t Good Enough
• No, FISMA Doesn’t Require That, Silly Product Pushers

Yeah, it’s old but way too good to pass up.  According to Congressional testimony from some industry experts, the US needs to defend its “Cyber-Turf” and so we have today’s IKANHAZFIZMA:

• Lolcats Protect the End Users
• SCAP in Lulz
• Cyber-FEMA LOLCATS Prepare for Cyber-Katrina
• Bolt-On Security
• Cyber Command Goes LOLCATS

“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

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?

Security controls for cats:  Keep them out of bright light, keep them dry, and whatever you do, don’t feed them after midnight. kthnx bai.

• Yet More Security Controls You Won’t See in SP 800-53
• LOLCATS: Defending our Cyber-Turf
• Aurora and LOLCATS
• Cyber-FEMA LOLCATS Prepare for Cyber-Katrina
• LOLCATS Take on Catalog of Controls