Contrary to what you might hear this week in the trade press, FedRAMP is not fully unveiled although there was some much-awaited progress. There was a memo that came out from the administration (PDF caveat).  Basically what it does is lay down the authority and responsibility for the Program Management Office and set some timelines.  This is good, and we needed it a year and a half ago.

However, people need to stop talking about how FedRAMP has solved all their problems because the entire program isn’t here yet.  Until you have a process document and a catalog of controls to evaluate, you don’t know how the program is going to help or hinder you, so all the press about it is speculation.

• Reinventing FedRAMP
• NIST Cloud Conference Recap
• An Open Letter to NIST About SP 800-30
• The Guerilla CISO Rants: Don’t Write a System Security Plan
• Clouds, FISMA, and the Lawyers

So since I’ve semi-officially been granted the title of “The DDoS Kid” after some of the incident response, analysis, and talks that I’ve done, I’m starting to get asked a lot about how much the average DDoS costs the targeted organization.  I have some ideas on this, but the simplest way is to recycle Business Continuity/Disaster Recovery figures but with some small twists.

Scoping:

• Plan on a 4-day attack.  A typical attack duration is 2-7 days.
• Consider an attack on the “main” (www) site and anything else that makes money (shopping cart, product pages)

Direct:

• Downtime: one day’s worth of downtime for both peak times (for most eCommerce sites, that’s Thanksgiving to January 5th) and low-traffic times x  (attack duration).
• Bandwidth: For services that charge by the bit or CPU cycle such as cloud computing or some ISP services, the direct cost of the usage bursting.  The cost per bit/cpu/$foo is available from the service provider, multiply your average rate for peak times by 1000 (small attack) or 10000 (large attack) x (attack duration) worth of usage.  This is the only big difference in cost from BCP/DR data.
• Mitigation Services:  Figure $5K to $10K for a DDoS mitigation service x (duration of attack).

Indirect:

• Increased callcenter load: A percentage (10% as a starting guess) of user calls to the callcenter x (average dollar cost per call) x (attack duration).
• Increased physical “storefront” visits: A percentage (10%) of users now have to go to a physical location x (attack duration).
• Customer churn: customer loss due to frustration.  Figure 2-4% customer loss x (attack duration).

Brand damage, these vary from industry to industry and attack to attack:

• Increased marketing budget: Percentage increase in marketing budget.  Possible starting value is 5%.
• Increased customer retention costs: Percentage increase in customer retention costs.  Possible starting value is 10%.

Note that it’s reasonably easy to create example costs for small, medium, and large attacks and do planning around a medium-sized attack.

However we recycle BCP/DR figures for an outage, mitigation of the attack is different:

• For high-volume attacks, you will need to rely on service providers for mitigation simply because of their capacity.
• Fail-over to a secondary site means that you now have two sites that are overwhelmed.
• Restoration of service after the attack is more like recovering from a hacking attack than resuming service at the primary datacenter.

• DDoS and Elections
• Keeping Up With the DDoS Kids
• DojoCon DDoS Video
• The Rise of the Slow Denial of Service
• A Little Story About a Tool Named #RefRef

Considering that it’s a secondary source and therefore subject to being corrected later in an official announcement, but this is pretty big.  Requiring the Departments and Agencies to consider cloud solutions both scares me (security, governance, and a multitude of other things about rushing into mandated solutions) and excites me (now cloud solutions are formally accepted as viable).

However, before you run around either proclaiming that “this is the death of serverhuggers” or “the end is nigh, all is lost” or even “I for one welcome our fluffy white overlords”, please consider the following:

• A “secure, reliable, cost-effective cloud option” is a very loaded statement very open to interpretation
• They already have to consider open source solutions
• They already have to consider in-sourcing
• They already have to consider outsourcing
• “Cloud” more often than not includes private clouds or community clouds
• Isn’t this just another way to say “quit reinventing the wheel”?
• Some Government cloud initiatives are actually IT modernization initiatives riding the bandwagon-du-jour
• Switching from Boeing, Northrup, and SAIC beltway bandit overlords to Google, Amazon, and SalesForce cloud overlords still mean that you have overlords

• Clouds, FISMA, and the Lawyers
• NIST Cloud Conference Recap
• FedRAMP: It’s Here but Not Yet Here
• Analyzing Fortify’s Plan to “Fix” the Government’s Security Problem
• Wanted: Some SCAP Wranglers

Ah yes, I’ve explained this about a hundred times this week (at that thing that I can’t blog about, but @McKeay @MikD and @Sawaba were there so fill in the gaps), thought I should get this down somewhere.

the 3 factors that determine how much money you will make (or lose) in a consulting practice:

• Bill Rate: how much do you charge your customers.  This is pretty familiar to most folks.
• Utilization: what percentage of your employees’ time is spent being billable.  The trick here is if you can get them to work 50 hours/week because then they’re at 125% utilization and suspiciously close to “uncompensated overtime”, a concept I’ll maybe explain in the future.
• Leverage: the ratio of bosses to worker bees.  More experienced people are more expensive to have as employees.  Usually a company loses money on these folks because the bill rate is less than what they are paid.  Conversely, the biggest margin is on work done by junior folks.  A highly leveraged ratio is 1:25, a lowly leveraged ratio is 1:5 or even less.

Site Assessment photo by punkin3.14.

And then we have the security assessments business and security consulting in general.  Let’s face it, security assessments are a commodity market.  What this means is that since most competitors in the assessment space charge the same amount (or at least relatively close to each other), this means some things about the profitability of an assessment engagement:

• Assuming a Firm Fixed Price for the engagement, the Effective Bill Rate is inversely proportionate to the amount of hours you spend on the project.  IE, $30K/60 hours=$500/hour and 30K/240 hours = $125/hour.  I know this is a shocker, but the less amount of time you spend on an assessment, the bigger your margin but you would also expect the quality to suffer.
• Highly leveraged engagements let you keep margin but over time the quality suffers.  1:25 is incredibly lousy for quality but awesome for profit.  If you start looking at security assessment teams, they’re usually 1:4 or 1:5 which means that the assessment vendor is getting squeezed on margin.
• Keeping your people engaged as much as possible gives you that extra bit of margin.  Of course, if they’re spending 100% of their time on the road, they’ll get burned out really quickly.  This is not good for both staff longevity (and subsequent recruiting costs) and for work quality.

Now for the questions that this raises for me:

• Is there a 2-tier market where there are ninjas (expensive, high quality) and farmers (commodity prices, OK quality)?
• How do we keep audit/assessment quality up despite economic pressure?  IE, how do we create the conditions where the ninja business model is viable?
• Are we putting too much trust in our auditors/assessors for what we can reasonably expect them to perform successfully?
• How can any information security framework focused solely on audit/assessment survive past 5 years? (5-10 years is the SWAG time on how long it takes a technology to go from “nobody’s done this before” to “we have a tool to automate most of it”)
• What’s the alternative?

• Security Assessment Economics
• Split-Horizon Assessments and the Oversight Effect
• Security Assessments as Fraud, Waste, and Abuse
• The CyberArmy You Have…
• How to Not Let FISMA Become a Paperwork Exercise

Some days I feel like all this “continuous monitoring” talk around the beltway is just really a codeword for “buy our junk”, much like the old standby “defense in depth”, only instead of firewalls and IDS, it’s desktop and server configuration management.  Even better that it works for both products and services.  The BSOFH in me likes having a phrase like “Near Real-Time Continuous Compliance Monitoring” which can mean anything from “tying thermite grenades to the racks in case of being captured” to “I think I’ll make a ham sandwich for lunch and charge you for the privilege”.

Anyway, our IKANHAZFIZMA lolcats have finally found a control worth monitoring:  the world’s supply of overstuffed cheeseburgers.  This continuous monitoring thing is serious business, just like the Internets.

• Federal Computer Week and S.773
• Metricon is Next Week
• Oh Lookie, Somebody’s Doing What I Said To Do….
• CISOin’ Ain’t Easy, But It’s a Living
• Draft of SP 800-37 R1 is Out for Public Review

Rybolov’s note:  Vlad’s on a rant, at times like this it’s best sit back, read, and laugh at his curmudgeonly and snark-filled sense of humor.

So there I am having a beer at my favorite brew pub Dogfish Head Alehouse, in Fairfax, when my phone vibrates to this ditty…. I couldn’t get past the “breaking news.”

From: <The SANS Institute>

Sent: Friday, May 28, 2010 4:05 PM

To:Vlad_the_Impaler@myoldisp.net

Subject: SANS NewsBites Vol. 12 Num. 42 : House attaches FISMA corrections to Defense Authorization Bill for rapid action

* PGP Signed by an unmatched address: 5/28/2010 at 2:52:21 PM

Breaking News: US House of Representatives attaches new FISMA rewrite to Defense Authorization Bill. The press hasn’t picked it up yet, but NextGov.Com will have a story in a few minutes. This puts one more nail in the coffin of the Federal CISOs and security contractors who think they can go on ignoring OMB and go on wasting money on out of date report writing contracts.

Alan

Yet another millstone (pun intended) piece of legislation passed on a Friday with… a cheerleader?!?!??? Whoa.

This ruined what was turning out to be a decent Friday afternoon for me…

My beef is this — I guess I really don’t understand what motivates someone who vilifies Federal CISOs and security contractors in the same sentence? Does the writer believe that CISOs are in the pocket of contractors? Even I am not that much of a cynic… Which CISO’s are “ignoring OMB?” All of them except NASA? Are all of our Government CISOs so out of touch that they LIKE throwing scarce IT dollars away on “out of date report writing contracts?” (sic.) (Vlad – Are hyphens too costly?)

I could drop to an ad hominem attack against the writer, but that’s pretty much unnecessary and probably too easy. I’ll leave that to others.

Suffice to say that what is motivating this newsbit appears IMHO to be less about doing things the right way, and more about doing things their way while grabbing all the headlines and talking head interviews they possibly can. (See “self-licking Ice Cream Cone” in my last post)

Yeah, I’m a cynic. I’m a security professional. What’s yer point?

• Next Up in Security Legislation: S3474
• No, FISMA Doesn’t Require That, Silly Product Pushers
• Ooh, “The Word” is out on S 3474
• In Other News, I’m Saying “Nyet” on S.3474
• HR 5983–DHS Now Responsible for Contractor Security