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

Go check it out.  The project management folks have been jokingly grilled over numerous times for being ~2-3 months late.

However, comments are being accepted until December 2nd.  Do yourselves a favor and submit some comments.

• Reinventing FedRAMP
• Old Saint NIST: Ho Ho Hold on, what’s this?
• NIST Cloud Conference Recap
• A Funny Thing Happened Last Week on Capital Hill
• FedRAMP: It’s Here but Not Yet Here

I’ve been waiting all of September for FedRAMP to be released and hoping they get over the last-minute hurdles to put something out into view. Our lolcats will feel much more secure now with a squishy buddy.

• Lolcats Coming to you from the Cloud
• Lolcats and QR Codes
• Shmoocon: Less Moose, More LOLCATS
• Redundant Lolcats
• Lolcats, Capital Hill, and a Haiku

So last week Anonymous staged a Distributed Denial of Service against the RIAA, MPAA, and Aiplex over Aiplex’s announcement that they were launching DDoS attacks of their own against torrent sites sharing copyrighted content.  In doing a bit of research on techniques that were being used, I came across this wonderful bit of script:

while true; do wget ‘http://riaa.com/goldandplatinumdata.php?table=SEARCH_RESULTS&title=&artist=&label=&format=&category=&type=&awardDescription=&startMonth=1&startYear=0&endMonth=12&endYear=2009&sort=Date&sense=ASC&perPage=5000000000&go=Search’ > /dev/null &  done

For those of you who don’t get it just yet, this is an awesome attack to study.  Basically what it does is to run an endless loop grabbing a search page url with parameters that will do a huge database query.  The beauty of the attack is that it’s “highly leveraged”: for one http get, you generate a sizeable amount of database load.  Now multiply that by thousands of yahoos out there running the same script, and it will rollover the target’s database server and possibly the applications servers that query it.

• A Little Story About a Tool Named #RefRef
• The Rise of the Slow Denial of Service
• Apache Killer Effects on Target
• DDoS and Elections
• DDoS Planning: Business Continuity with a Twist

Going Off the Deep End

So I was thinking the other day (this is the part where people who know me in person usually go “oh cr*p”), partially spurred by a conversation I had with @csoandy and @secbarbie a couple of months ago.  I’ll get the idea out there: as an industry we need to embrace the concept of split-horizon assessments.

Two Purposes for Assessments

Because this is an insane approach that I’m just feeling out, let me go on a solo riff and explain what I’m talking about.  You see, I have two distinct purposes for getting a security assessment, both of which are in contention with each other:

• I want to fix my security by asking for money to fix the things that need attention.  When I get an assessment for this purpose, enumeration of my badness/suckness is good.  If I have a set of results that say that everything is great, then there’s no need for me to be given any more resources (time, money, people, gear).  Short-term, I’m fine, but what about my infrastructure-type long-term projects?  The net effect of a highly-scored annual assessment just might kill my program in 2 years as my funding and people are shifted elsewhere, especially in a .
• I want to keep my job and help my {company|agency|group} stay out of trouble by showing my zero-defects face and by demonstrating my due-diligence in protecting what has been given to me.  While the assessor has helped me short-term by identifying my problems and being a total hardass, if I’m not around in 6 months to adopt the recommendations into my security program, has the assessor actually helped me?

And this is the dilemma for just about every security manager out there.  One of the strategies is to alternate assessment types, but then your management wonder just what the heck it is you’re doing because you’re on top one year, then on the bottom the next.

Split Rock Lighthouse and Horizon photo by puliarf.

Assessor Window-Shopping

Now for the dirty little secret of the testing business:  there are really good testers who are the ninjas of the InfoSec world and there are really bad testers who don’t even validate their unlicensed Nessus scan.  I know, you’re shocked and it’s so blindingly obvious that Bruce Schneier will blog it 3 years from now.  =)

But there’s the part that you didn’t know:  security managers pick their assessor depending on the political mood inside their organization.  This is nowhere near a science, from what I’ve seen it involves a lot of navel-gazing on the part of the security team to see which is the lesser evil: having everybody think you’re incompetent or never getting anything new ever again?

Building a Better Rat Race

In order to accomplish both of the goals that I’ve listed, what I really need is a split-horizon assessment.  In other words, I need 2 reports from one assessment with different views for different audiences.  I know this sounds highly cynical, but it’s something we’ve been doing for some time now but just informally.  Might as well make it formal.

So are you sold on this concept yet?  In true form, I have an idea on how to get to a world of split-horizon assessments.  You can take any catalog of controls and divide it into “gotta have it” and “nice to have” (I almost divide these along the lines of “vulnerability mitigation” and “sustainable security program” or the “CISO” and “OMB and Congress”) buckets.  Then in your compliance assessment standard, require 2 reports for each assessment.  One is reported to the regulating authority and the other stays with the organization.

Indecision Strikes

I don’t know if I’ve solved the problemspace or not, but I’m looking for feedback “from the Peanut Gallery” so leave some comments.

• Security Assessment Economics
• Engagement Economics and Security Assessments
• Workin’ for the ‘Counters: an Analysis of my Love-Hate Relationship with the CPAs
• Security Assessments as Fraud, Waste, and Abuse
• A Funny Thing Happened Last Week on Capital Hill

A couple of weeks ago I went to the NIST Cloud Conference for the afternoon security sessions.  You can go grab the slides off the conference site.  Good stuff all around.

Come to think of it, I haven’t blogged about FedRAMP, maybe it’s time to.

FedRAMP is a way to do security authorization (formerly certification and accreditation, get with the times, man) on a cloud then let tenant projects use that authorization.  Hmmm, sounds like…. a General Support System with common controls and Major Applications that inherit those controls.  This isn’t really anything new, just the “bread and butter” security management concepts scoped to a cloud.  Basically what will happen with FedRAMP is that they have 3 standards: DoD, DHS, and GSA (most stringent first) and cloud providers get authorized against that standard.  Then when a project wants to build on that cloud, they can use that authorization for their own authorization package.

All things considered, FedRAMP is an awesome idea.  Now if we can get the holdout agencies to actually acknowledge their internal common controls, I’ll be happy–the background story being that some number of months ago I was told by my certifier that “we don’t recognize common controls so even though you’re just a simple web application you have to justify every control even if it’s provided to you as infrastructure.”  No, still not bitter at all here, but I digress….

And then there are the pieces that I haven’t seen worked out yet:

• Mechanism of Sharing: As a service provider, it’s hard enough to keep one agency happy.  Add in 5 of them and it gets nearly impossible.  This hasn’t really been figured out, but in Rybolov’s small, myopic world, a panel of agencies owning an authorization for a cloud provider means that the cloud never gets authorized.  The way this has been “happening in the wild” is that one agency owns the authorization and all the other agencies get the authorization package from that agency.
• Using FedRAMP is Optional: An agency or project can require their own risk assessment and authorization even though a FedRAMP one is available.  This means that if the agency’s auditors don’t understand the process or the “risk monkeys” (phrase courtesy of My Favorite Govie) decree it, you lose any kind of cost savings and time savings that you would get by participating in FEDRAMP.
• Cloud Providers Rule the Roost: Let’s face it, as much as the Government wants to pretend that the cloud providers are satisfying the Government’s security requirements, we all know that due to the nature of catalogs of controls and solution engineering, the vendor here has the advantage.  Nothing new, it’s been happening that way with outsourcing, only now it’s immediately evident.  Instead of trying to play ostrich and stick our heads in the sand, why don’t we look at the incentives for the cloud providers and see what makes sense for their role in all this.
• Inspector General Involvement: I don’t see this happening, and to be honest, this scares the hell out of me.  Let me just invoke Rybolov’s Law: “My solution is only as good as my auditor’s ability to understand it.”  IE, if the IGs and other auditors don’t understand FedRAMP, you don’t really have a viable solution.

The Big Ramp photo by George E. Norkus.  FedRAMP has much opportunity for cool photos.

• Reinventing FedRAMP
• Cloud Computing and the Government
• FedRAMP: It’s Here but Not Yet Here
• Clouds, FISMA, and the Lawyers
• How to Not Let FISMA Become a Paperwork Exercise