OK, so I lied unintentionally all those months ago when I said I wouldn’t write any more PCI-DSS posts.

My impetus for this blog post is a PCI-DSS panel at ShmooCon that several of my friends (Jack Daniel, Anton Chuvakin, Mike Dahn, and Josh Corman, in no particular order) were on.  I know I’m probably the pot calling the kettle black, but the panel (as you would expect for any PCI-DSS discussion in the near future) rapidly disolved into chaos.  So as I’m sitting in the audience watching @Myrcurial’s head pop off, I came to the realization that this is really 4 different conversations disguised into one topic:

1. The Cost-Benefit Assessment of replacing credit card # and CVV2 with something else–maybe chip and pin, maybe something entirely different–and what responsibility does Visa and Mastercard have towards protecting their business.  This calls for something more like an ROI approach because it’s infrastructure projects.  Maybe this CBA has already been done but guess what–nobody has said anything about the result of that analysis.
2. Merchants’ responsibility to protect their customers, their business, and each other.  This is the usual PCI-DSS spiel.  The public policy equivalent here is overfishing: everybody knows that if they come back with full nets and by-catch, they’re going to ruin the fishery long-term for themselves and their peers, but they can’t stop the destruction of the fishery by themselves, they need everybody in the community to do their part.  In the same way, merchants not protecting card data mess over each other in this weird shared risk pool.
3. Processor and bank responsibility.  Typically this is the Tier-1 and Tier-2 guys.  The issue here is that these guys are most of the processing infrastructure.  What works in PCI-DSS for small merchants doesn’t scale up to match these guys, and that’s the story here: how do you make a framework that scales?  I think it’s there (IE, the tiers and assurance levels in PCI-DSS) but it’s not communicated effectively.
4. Since this is all a shared risk pool, at what places does it make sense to address particular risks?  IE, what is the division of roles and responsibilities inside the “community”?  Then how do you make a community standard that is at least reasonably fair to all the parties on this spectrum, Visa and MasterCard included?

PCI-DSS Tag Cloud photo by purpleslog.

There are a bunch of tangential questions, but they almost always circle
back to the 4 that I’ve mentioned above:

• Regulatory capture and service providers
• The pitfalls of designing a framework by committee
• Self-regulation v/s legislation and Government oversight
• Levels of hypocrisy in managing the “community”
• Effectiveness of specific controls

Now the problem as I see it is that each of these conversations points to a different conversation as a solution and in doing so, they become thought-terminating cliches.  What this means is that when you do a panel, you’re bound to bounce between these 4 different themes without coming to any real resolution.  Add to this the fact that it’s a completely irrational audience who only understand their 1 piece of the topic, and you have complete chaos when doing a panel or debate.

Folks, I know this is hard to hear, but as an industry, we need to get over being crybabies and pointing fingers when it comes PCI-DSS.  The standard (or a future version of it anyway) and self-regulation is here to stay because even if we fix the core problems of payment, we’ll still have security problems because payment schemes are where the money is.  The world as I see it is that the standards process needs to be more transparent and the people governed by the standard need a seat at the table with their rational, adult, and constructive arguments on what works and what doesn’t work to help them do their job to help themselves.

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Part 1

Part 2

Takeaways from the 20 CSC and what they do right (hey, it’s not all bad):

You have to prioritize. On a system basis, there are maybe 50-60 800-53 controls (out of a number just shy of 200) that need to be built 100% correctly and working every single time.  The rest (I know, I’m putting on my heretic hat here) can lapse from time to time.  For example, if I don’t have good event monitoring, my incident response team doesn’t have much work because I don’t know if I’m pwned or not.  What 20 CSC does is try to reduce that set of stuff that I should be concerned about into a set of controls that are technical, tactical, and track to classes taught by SANS vulnerability-based .

Common controls are more important than ever. They help you scope the smaller systems.  In fact, roughly half of the 20 CSC apply to the modern Enterprise and should be absorbed there, meaning that for systems not owning infrastructure, we only have 10 or so controls that I have to worry a bunch about, and 10 that I just need to be aware of what’s provided by my CISO.

Give examples. I’ll even go as far as to say this:  it should be a capital offense to release a catalog of controls without a reference implementation for both an Enterprise/GSS and a smaller IT system/Major Application inside of it.  20 CSC stops maybe one step short of that, but it’s pretty close in some controls to what I want if they were structured differently.

Security Management v/s IT Management. IT asset inventory, configuration management, change control:  these are IT management activities that somehow get pushed onto the security team because we are more serious about them than the people who should care.  I think 20 CSC does an OK job of just picking out the pieces that apply to security people instead of the “full meal deal” that ITIL and its ilk bring.

Control Key photo by .faramarz.

Now for what they did wrong:

It’s Still Not a Consensus, Dammit! That is, it’s a couple of smart people making a standard in a vacuum and detached from the folks who will have to live by the work that they do.  Seriously, ask around inside the agencies:  who admits to helping develop 20 CSC aside from “yeah, we looked at it briefly”?  And I’m not talking about the list that SANS claims, that’s stripped from the bios of the handful of people who did work on 20 CSC.  Sadly, this is the quick path to fail, it’s like building an IT system without asking the users what they need to get their job done on a daily basis.  Guys, we should know better than this.

It’s Still Not a Standard. It’s still written as guidance–more anecdote than hard requirements.  This isn’t something I can put into a contract and have my contractors execute without modifying it heavily.  It’s also not official, something I’ve already touched on before, which means that it’s not mandatory.  If you want to make this a standard, you need to turn it into ~50 controls each written as a “contracting shall”.  More to come on this in the future.

It Has Horrible Metrics. And I’m talking really horrible…it’s like the goatse of security metrics (NSFW link, even though it’s wikipedia).  Why?  Because they’re time-based for controls that are not time-based.  Metrics need to be a way to evaluate that the control works, not the indirect effects of the control.  Of course, metrics are just a number, but at the end of whatever assessment, my auditor/IG/GAO/$foo has to come up with some way to rank the work that I’ve done as a security officer.  If 20 CSC is the vehicle for the audit and the metrics are hosed, it doesn’t matter what I can do to provide real security, the perception from my management is that I don’t know what I’m doing.

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OK, now for the control-by-control analysis of the 20 Critical Security Controls.  This is part 2.  Look here for the first installment.  Read part 3 here.

Critical Control 1: Inventory of Authorized and Unauthorized Devices. This is good: get an automated tool to do IT asset discovery.  Actually, you can combine this with Controls 2, 3, 4, 11, and 14 with some of the data center automation software–you know the usual suspects, just ask your ops folks how you get in on their tools.  This control suffers from scope problems because it doesn’t translate down to the smaller-system scale:  if I have a dozen servers in an application server farm inside of a datacenter, I’ll usually know if anybody adds something.  The metric here (detect all new devices in 24 hours) “blows goats” because you don’t know if you’re detecting everything.  A better test is for the auditor to do their own discovery scans and compare it to the list in the permanent discovery tool–that would be validation that the existing toolset does work–with a viable metric of “percentage of devices detected on the network”.  The 24 hour metric is more like a functional requirement for an asset discovery tool.  And as far as the isolation of unmanaged assets, I think it’s a great idea and the way things should be, except for the fact that you just gave us an audit requirement to implement NAC.

Critical Control 2: Inventory of Authorized and Unauthorized Software. Sounds like the precursor to whitelisting.  I think this is more apropos to the Enterprise unless your system is the end-user computing environment (laptops, desktops).  Yes, this control will help with stuff in a datacenter to detect when something’s been pwned but the real value is out at the endpoints.  So yes, not happy with the scope of this control.  The metric here is as bad as for Control 1 and I’m still not happy with it.  Besides, if you allow unauthorized software to be on an IT device for up to 24 hours, odds are you just got pwned.  The goal here should be to respond to detected unauthorized software within 24 hours.

Critical Control 3: Secure Configurations for Hardware and Software on Laptops, Workstations, and Servers. This is actually a good idea, provided that you give me a tool to apply the settings automagically because manual configuration sucks.  I think it’s about a dozen different controls all wrapped into one, it’s just trying to do too much in one little control.  The time-based metric for this control is really bad, it’s like watching a train wreck.  But hey, I’ll offer up my own: percentage of IT assets conforming to the designated configuration.  It’s hinted at in the implementation guide, make it officially the metric and this might be a control I can support.

Critical Control 4: Secure Configurations for Network Devices such as Firewalls, Routers, and Switches. This is basically Control 3 for network devices.  The comments there also apply here.

Critical Control 5: Boundary Defense. This control is too much stuff crammed into one space.  As a result, it’s not concise enough to be implemented–it’s all over the map.  In fact, I’ll go as far as to say that this isn’t really one control, it’s a control theme with a ton of controls inside of it.  The “audit requirements” here are going to utterly kill me as a security manager because there is so much of a disparity between the control and the actual controls therein.

Critical Control 6: Maintenance, Monitoring, and Analysis of Audit Logs. Some of this control should be part of Controls 3 and 4 because, let’s be honest here, you’re setting up logging on devices the way that the hardening guide says you should.  The part that’s needed in this control is aggregation of logs and review of logs–get them off all the endpoints and into a centralized log management solution.  This is mentioned as the last “advanced” implementation technique but if you’re operating a modern Enterprise, I don’t see how you can get the rest of the implementation done without some kind of SIEM piece.   I just don’t get the metric here, again with the 24 hours.  How about “percentage of devices reporting into the SIEM”?  Yeah, that’s the easy money here.  The testing of this control makes me do a facepalm:  “At a minimum the following devices must be tested: two routers, two firewalls, two switches, ten servers, and ten client systems.”  OK, we’ve got a LAN/WAN with 15000 endpoints and that’s all we’re going to test?

Critical Control 7: Application Software Security. You keep using those words, I do not think they mean what you think they mean.  Application security is a whole different world and 20 CSC doesn’t even begin to scratch the surface of it.  Oh, but guess what?  It’s a tie-in to the 25 Most Dangerous Programming Errors which is about all this control is:  a pointer to a different project.  The metric here is very weak because it’s not tied back to the actual control.

Critical Control 8: Controlled Use of Administrative Privileges. This should be part of Controls 3 and 4, along with something about getting an Identity and Access Management system so that you have one ID repository.  I know this is a shocker to you, but the metric here sucks.

Critical Control 9: Controlled Access Based on Need to Know. This is a great idea, but as a control it’s too broad to achieve, which is why the 20 CSC were created in the first place.  What do we really want here?  Network share ACLs are mentioned, which is a control in itself, but the rest of this is hazy and leaves much room for interpretation.  Cue “audit requirements” and the part where Rybolov says “If it’s this hazy, it’s not really a standard, it’s a guideline that I shouldn’t be audited against.

Critical Control 10: Continuous Vulnerability Assessment and Remediation. All-in-all, not too bad.  I would suggest “Average time to resolve scan findings” here as a metric or even something as “hoakey” as the FoundScan metric just to gauge overall trends.

Arm Control photo by Crotchsplay.

Critical Control 11: Account Monitoring and Control. Haven’t we seen this before?  Yep, this should be incorporated into Controls 8, 3, and 4.  However, periodic account reviews are awesome if you have the patience to do it.

Critical Control 12: Malware Defenses. OK, this isn’t too bad.  Once again, the metric sucks, but I do like some of the testing steps.  The way I would test this is to compare our system inventory with my total list of devices.  A simple diff later, we have a list of unmanaged devices.

Critical Control 13: Limitation and Control of Network Ports, Protocols, and Services. Host firewalls was not what I thought of… I’m thinking more like firewalls and network segmentation where you have to get change control approval to add a firewall rule.  As far as the host setup, this should be part of Control 3.

Critical Control 14: Wireless Device Control. Not bad, but this should be dumped into a technical standard that you use like a hardening guide.  Metric here still sucks, but I don’t really need to say this again… oh wait, I just did.

Critical Control 15: Data Loss Prevention. Puh-lease.  I’ll be the first to admit, I’m a big believer in DLP done right, and that it’s an awesome tool to solve some of the unique .  But I don’t think that the market is mature enough to add it into your catalog of controls.  Also this will fall flat on its face if your system is just a web application cluster:  DLP addresses the endpoints (desktops, laptops, mobiles) and the outbound gateways (email, web, etc).  The problem with this control is that if you don’t buy and implement a full DLP solution (cue Rich Mogull and his DLP guide), there isn’t anything else that has a similar capability.  This is one of those controls where the 800-53 mapping gets really creative–Good Ship Lollipop Creative because we’re tapdancing around the issue that DLP-type solutions aren’t specifically required in 800-53.

These controls don’t have automated ways to implement and test them:

Critical Control 16: Secure Network Engineering. This control is a steaming crater.  It’s very much a guideline instead of an auditable standard.

Critical Control 17: Penetration Tests and Red Team Exercises. Not bad.  Still too easy to shop around for the bargain-basement penetration test team.  But yeah, pretty good overall.

Critical Control 18: Incident Response Capability. Good control.  Hard to test/audit except to look at after-incident reports.

Critical Control 19: Data Recovery Capability. Not bad here.  Not real COOP/DR/ITCP but about on par with typical controls frameworks.

Critical Control 20: Security Skills Assessment and Appropriate Training to Fill Gaps. Good idea.  Hard to implement without something like 8570.10 to give you a matrix by job position.  You want to change the world here, give your own mapping in the control.

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Every once in a while an opportunity presents itself to affect some real change in federal information security practice.  Now is such a time.  A slew of new NIST documents are being released between now and April.  These are the core NIST documents that describe how to satisfy FISMA.  They include NIST SPs 800-30 Revision 1, 800-39, 800-37 Revision 1 and 800-53A Revision 1. That’s where you come in.

The documents define what federal government practice will look like in the coming years.  If they are flawed then the practice will be flawed.  To prevent stupidity from leaking in when nobody is looking NIST releases the documents as drafts so everyone gets a chance to eyeball them.  First you eyeball, then you comment.  They look at the comments and they fix the flaws.  Fix the flaws now and you don’t live with them later.

The most important document in draft right now is the NIST Special Publication 800-37 Revision 1.  This document describes the central processes involved in the authorization of information systems that support the federal government.  Notice I didn’t say Certification and Accreditation?  That’s because C&A is deader than a sheep at a wolf convention. Want to know what replaces it?  Pick up a copy of NIST SP 800-37r1 FPD, give it a read and send in your comments.

Better yet, consider joining a formal document review process.  I’m leading a team of hale and hearty volunteers at OWASP in a NIST SP 800-37r1 FPD review and we’d love to have you come join the fun.   We’re on a tight schedule so now is the time to act.

Time is short, the comment period for NIST SP 800-37 Revision 1 FPD ends on December 31st, 2009.

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A small presentation Dan Philpott and I put together for Potomac Forum about getting sane social media policy out of your security staff. I also recommend reading something I put out a couple of months ago about Social Media Threats and Web 2.0.

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So most of the security world is familiar with the Web 2.0 and Social Media threats in the private sector.  Today we’re going to have an expose on the threats specific to Government because I don’t feel that they’ve been adequately represented in this whole push for Government 2.0 and transparency.

Threat: Evil Twin Agency Attack. A person registers on a social media site using the name of a Government entity.  They then represent that entity to the public and say whatever it is that they want that agency to say.

What’s the Big Deal: Since for the most part there is no way to prove the authenticity of Government entities on social media sites short of a “catch us on <social media site>” tag on their .gov homepage.  This isn’t an attack unique to Government but because of the authority that people give to Government Internet presences means that the attacker gains perceived legitimacy.

Countermeasures: Monitoring by the agencies looking for their official and unofficial presences on Social Media and Web 2.0 sites.  Any new registrations on social media are vetted for authenticity through the agency’s public affairs office.  Agencies should have an official presence on social media to reserve their namespace and put these account names on their official website.

References:

• Evil Twin Attack on GNUCITIZEN

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Threat: Web Hoax. A non-government person sets up their own social media or website and claims to be the Government.

What’s the Big Deal: This is similar to the evil twin attack only maybe of a different scale.  For example, an entire social media site can be set up pretending to be a Government agency doing social networking and collecting data on citizens or asking citizens to do things on behalf of the Government.  There is also a thin line between parody and

Countermeasures: Monitoring of URLs that claim to be Government-owned.  This is easily done with some Google advanced operators and some RSS fun.

References:

• Network Neighborhood Watch

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Threat: Privacy Violations on Forums. A Government-operated social media site collects Personally Identifiable Information about visitors when they register to participate in forums, blog comments, etc.

What’s the Big Deal: If you’re a Government agency and going to be collecting PII, you need to do a Privacy Impact Assessment which is overkill if you’re collecting names and email which could be false anyway.  However, the PIA is a lengthy process and utterly destroys the quickness of web development as we know it.

Countermeasures: It has been proposed in some circles that Government social media sites use third-party ID providers such as OpenID to authenticate simple commenters and forum posts.  This isn’t an original idea, Noel Dickover has been asking around about it for at least 9 months that I know of.

References:

• Should Government be an ID Provider
• OpenID

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Threat: Monitoring v/s Law Enforcement v/s Intelligence Collection. The Government has to be careful about monitoring social media sites.  Depending on which agency is doing it, at some point you collect enough information from enough sources that you’re now monitoring US persons.

What’s the Big Deal: If you’re collecting information and doing traffic analysis on people, you’re most likely running up against wiretap laws and/or FISA.

Countermeasures: Government needs Rules of Engagement for creating 2-way dialog with citizens complete with standards for the following practices:

• RSS feed aggregation for primary and secondary purposes
• RSS feed republishing
• Social networking monitoring for evil twin and hoax site attacks
• Typical “Web 2.0 Marketing” tactics such as group analysis

References:

• How to Create a Social Media Monitoring Strategy.  Note that most of what this blog post advises can get a Government agency in trouble even though it’s sound advice for the private sector.

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Threat: Hacked?  Not Us! The Government does weird stuff with web sites.  My web browser always carps at the government-issued SSL certificates because they use their own certificate authority.

What’s the Big Deal: Even though I know a Government site is legitimate, I still have problems getting alert popups.  Being hacked with a XSS or other attack has much more weight than for other sites because people expect to get weird errors from Government sites and just click through.  Also the sheer volume of traffic on Government websites means that they are a lucrative target if the attacker’s end goal is to infect desktops.

Countermeasures: The standard web server anti-XSS and other web application security stuff works here.  Another happy thing would be to get the Federal CA Certificate embedded in web browsers by default like Thawt and Verisign.

References:

• MyBarackObama profile hack punts malware
• Barack Obama’s Site Leading to Trojan

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Threat: Oh Hai I Reset Your Password For You AKA “The Sarah Palin Attack”.  The password reset functions in social media sites work if you’re not a public figure.  Once the details of your life become scrutinized, your pet’s name, mother’s maiden name, etc, all become public knowledge.

What’s the Big Deal: It depends on what kind of data you have in the social media site.  This can range anywhere from the attacker getting access to one social media site that they get lucky with to complete pwnage of your VIP’s online accounts.

Countermeasures: Engagement with the social media site to get special considerations for Government VIPS.  Use of organizational accounts v/s personal accounts on social media sites.  Information poisoning on password reset questions for VIPs–don’t put the real data up there.  =)

References:

• Sarah Palin “hack”

Tranparency in Action photo by Jeff Belmonte.

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