The 20 Controls That Arent – The Falcons View.

I would like to respond to Ben Tomhave’s attack on the SANS 20 Critical Security Controls.

Ben says they are not actionable. They surely are actionable. While SANS refrains from specifying actual implementation recommendations, Cymbel does not. Also each control includes metrics to enable you to evaluate its effectiveness.

Ben says they are not scalable, i.e. they are only appropriate for large organizations with deep pockets. In reality the SANS 20CCs provide a maturity model with four levels, so you can start with the basics and mature over time.

Ben says they are designed to sell products. Sure, 15 of 20 are technical controls. As the SANS 20CCs document says, the attackers are automated so the defenders must be as well. And while technical controls without well trained people and good process are useless, the inverse is also true. And SANS surely covers this in the 20CCs document. I’ve seen too many really good security people forced to waste their time with poor tools.

Most importantly, I would contend that the SANS 20CCs were developed from a threat perspective, while the IT UCF which Ben favors (and is the basis of the GRC product Ben’s employer, LockPath sells) is more compliance oriented. In fact, UCF stands for “Unified Compliance Framework.”

While I surely don’t agree with every aspect of the SANS 20CCs, there is a lot of value there.

For example, the first four controls relate to discovering devices and the adherence of their configurations to policies. How can you argue with that? If you don’t know what’s connected to your network, how can you assure the devices are configured properly?

How many organizations can actually demonstrate that all network-attached devices are known and properly configured? Who would attempt to do this manually? How many organizations perform the recommended metric, i.e. add several new devices and see how long it takes to discover them – minutes, hours, days, months?

In closing, I find SANS to be a great organization and I applaud their efforts at developing a set of threat-oriented controls. In fact, I post a summary of the 20 Critical Security Controls on our web site.

30. August 2011 · Comments Off on TaoSecurity: TaoSecurity Security Effectiveness Model · Categories: blog · Tags: , , ,

TaoSecurity: TaoSecurity Security Effectiveness Model.

I like Richard Bejtlich’s Security Effectiveness Model because it highlights the key notion that information security must start with (my words) an understanding of your organization’s adversaries’ motives and methods. Richard calls these “Threat Actions.” From there, you would develop a “Defensive Plan,” and implement “Live Defenses.”

This is represented as a Venn Diagram made up of three circles. The more overlap you have, the more effective your infosec security program is. Here is the diagram:

Bejtlich calls this”threat-centric” security.

So the first question that needs to be addressed in making this approach operational is, how do you get the needed visibility to understand the Threat Actions?

I see this visibility coming from two sources:

  1. Third party, generally available research. One such source would be SANS. In fact, SANS developed the SANS 20 Critical Security Controls specifically in response to its understanding of threat actions. In fact, the latest version provides a list of “Attack Types” in Appendix C on page 72.
  2. Organizational assessment. At the organizational level, it seems to me you are faced with an evaluation problem of selecting controls that are good at finding Threat Actions. Based on my experience, there is agreement that the primary attack vector today is at the application level. If this is correct, then the organizational assessment would focus on (a) a black-box vulnerability assessment of the organization’s customer-facing web applications and (2) an assessment of the web applications (and related threats) the organization’s employees and contractors are using.

I am looking forward to Richard and others expanding on his ideas. Could be another book is coming. 🙂




30. August 2011 · Comments Off on Compliance Is Not Security – Busted! « PCI Guru · Categories: blog · Tags: , ,

Compliance Is Not Security – Busted! « PCI Guru.

The PCI Guru defends the PCI standard as a good framework for security in general, arguing against the refrain that compliance is not security.

My view is that the PCI Guru is missing the point. PCI DSS is a decent enough security framework. Personally I feel the SANS 20 Critical Security Controls is more comprehensive and has a maturity model to help organizations build a prioritized plan.

The issue is the approach management teams of organizations take to mitigate the risks of information technology. COSO has called this “Tone at the Top.”

A quote that rings true to me is, “In theory, there is no difference between theory and practice. But in practice there is.”

Applying here, I would say, in theory there should be no difference between compliance and security. But in practice there often is when management teams of an organizations do not take an earnest approach to mitigating the risks of information technology. Rather they take a “check-box” mentality, i.e. going for the absolute minimum on which the QSA will sign off. It is for this reason that many in our industry say that compliance does not equal security.


06. March 2011 · Comments Off on Your guide to the seven types of malicious hackers | Security Central – InfoWorld · Categories: blog · Tags: ,

Your guide to the seven types of malicious hackers | Security Central – InfoWorld.

As you may have gathered from previous posts, I recommend the SANS 20 Critical Security Controls for Effective Cyber Defense as an information security road map for medium and large enterprises. The controls are selected and prioritized by answering the following questions:

  • Who are the attackers?
  • What are their objectives?
  • What attack vectors do they use?
  • What target systems did they use to gain entry?
  • What types of protection could have stopped them?

Roger Grimes provides a comprehensive answer to the first question with the following seven types of attackers:

  1. Cyber criminals
  2. Spammers and adware spreaders
  3. Advanced Persistent Threat agents
  4. Corporate spies
  5. Hacktivists
  6. Cyber warriors
  7. Roue hackers
03. March 2011 · Comments Off on Securosis Blog | What No One is Saying About that Big HIPAA Fine · Categories: blog · Tags: , ,

Securosis Blog | What No One is Saying About that Big HIPAA Fine.

Rich Mogull at Securosis is claiming that security vendors should not use the HHS HIPAA fine to Cignet Health for $4.3 million as a motivator to improve information security.

While I agree that this HHS fine and the $1 million Mass General fine had nothing to do with IT security, it seems to me that HHS is signaling that it is serious about enforcing HIPAA security and privacy rules. After all, HIPAA was passed in 1996 and these are the first ever fines issued.

You certainly can take Rich’s approach that the Cignet fine is just about “big boxes of paper and a bad attitude.” But I would not want to be the organization that suffers an information security breach due to lax controls.

For example, if you had decided to use the SANS 20 Critical Security Controls as your prescriptive information security guide and had implemented all of the Quick Wins and Visibility/Attribution sub-controls, some/most of the Config/Hygiene sub-controls, with a plan for the rest and the appropriate Advanced sub-controls, and still suffered a breach, you surely could not be tagged with “willful negligence.”

We will see what if any fine HHS levies against the New York City hospital system which admitted to a breach affecting 1.7 million hospital staff, patients, vendors, and contractors.


27. February 2011 · Comments Off on Information Rights Management Monitor: Survey: Insider attacks cause more damage than outside assault · Categories: blog · Tags: , ,

Information Rights Management Monitor: Survey: Insider attacks cause more damage than outside assault.

The debate continues about outsider vs. insider attacks. Which are more prevalent? Which are more costly?

A recent survey conducted by SCO Magazine and sponsored by Deloitte, claims that:

58 percent of attacks are caused by outsiders and only 21% by insiders. At the same time, however, 33% view the insider attacks to be more costly than outside attacks, compared to 25% in 2010.

Now one might think that it’s in Deloitte’s interest to promote the growing threat of insider attacks because it’s an audit firm. However, I found this statistic to be interesting:

The authors noted that the public may not be aware of the number of insider events or the level of the damage caused because 70% of insider incidents are handled internally without legal action.

In my view, the difference between an outsider and an insider attack is narrowing if you define an insider as one who has authorized access. This is due to the increasing prevalence of botnet attacks which steal credentials. Thus an outsider becomes an insider. Of course, if the definition is based on the identity type of the attacker the difference between outsider and insider is clearer.

Therefore when planning your security defenses, it’s critically important to use an approach which starts with identifying the attacker types and their objectives. That’s why I like the SANS 20 Critical Security Controls for Effective Cyber Defense.


29. November 2010 · Comments Off on What is Information Security: New School Primer « The New School of Information Security · Categories: blog · Tags: , , , ,

What is Information Security: New School Primer « The New School of Information Security.

I would like to comment on each of the three components of Alex’s “primer” on Information Security.

First, InfoSec is a hypothetical construct. It is something that we can all talk about, but it’s not directly observable and therefore measurable like, say, speed that we can describe km/hr.   “Directly” is to be stressed there because there are many hypothetical constructs of subjective value that we do create measurements and measurement scales for in order to create a state of (high) intersubjectivity between observers (don’t like that wikipedia definition, I use it to mean that you and I can kind of understand the same thing in the same way).

Clearly InfoSec cannot be measured like speed or acceleration or weight. Therefore I would agree with Alex’s classification.

Second, security is not an engineering discipline, per se.  Our industry treats it as such because most of us come from that background, and because the easiest thing to do to try to become “more secure” is buy a new engineering solution (security product marketing).   But the bankruptcy of this way of thinking is present in both our budgets and our standards.   A security management approach focused solely on engineering fails primarily because of the “intelligent” or adaptable attacker.

Again, clearly InfoSec involves people and therefore is more than purely an engineering exercise like building a bridge. On the other hand, if, for example, you look at the statistics from the Verizon Business 2010 Data Breach Investigation Report, page 3, 85% of the analyzed attacks were not considered highly difficult. In other words, if “sound” security engineering practices are applied, the number of breaches would decline dramatically.

This is why we at Cymbel have embraced the SANS 20 Critical Security Controls for Effective Cyber Defense.

Finally, InfoSec is a subset of Information Risk Management (IRM).  IRM takes what we know about “secure” and adds concepts like probable impacts and resource allocation strategies.  This can be confusing to many because of the many definitions of the word “risk” in the english language, but that’s a post for a different day.

This is the part of Alex’s primer with which I have the most concern – “probable impacts.” The problem is that estimating probabilities with respect to exploits is almost totally subjective and there is still far too little available data to estimate probabilities.On the other hand, there is enough information about successful exploits and threats in the wild, to give infosec teams a plan to move forward, like the SANS 20 Critical Controls.

My biggest concern is Alex referencing FAIR, Factor Analysis of Information Risk in a positive light. From my perspective, any tool which when used by two independent groups sitting in different rooms to analyze the same environment can generate wildly different results is simply not valid. Richard Bejtlich, in 2007, provided a thoughtful analysis of FAIR here and here.

Bejtlich shows that FAIR is just a more elaborate version of ALE, Annual Loss Expectency. For a more detailed analysis of the shortcomings of ALE, see Security Metrics, by Andrew Jaquith, page 31. In summary, the problems with ALE are:

  • The inherent difficulty of modeling outlier
  • The lack of data for estimating probabilities of occurrence or loss expectancies
  • Sensitivity  of the ALE model to small changes in assumptions

I am surely not saying that there are no valid methods of measuring risk. It’s just that I have not seen any that work effectively. I am intrigued by Douglas Hubbard’s theories expressed in his two books, How to Measure Anything and The Failure of Risk Management. Anyone using them? I would love to hear your results.

I look forward to Alex’s post on Risk.

13. October 2010 · Comments Off on Outgunned: How Security Tech Is Failing Us — InformationWeek · Categories: blog · Tags: , , , , , ,

Outgunned: How Security Tech Is Failing Us — InformationWeek.

Our testing shows we’re spending billions on defenses that are no match for the stealthy attacks being thrown at us today. What can be done?

Greg Shipley has written an excellent article about the state of information security. The hard copy version in this week’s InformationWeek magazine sums up the situation – “Epic Fail.”

…collectively, we’ve spent billions of dollars on security technologies, and we still can’t curb these threats. Intruders trot through firewalls deployed to block them, while malware flourishes on systems that antivirus vendors pledge to immunize. Meantime, our identity management efforts guzzle funds faster than politicians before a crucial vote.

Recent events suggest that we are at a tipping point, and the need to reassess and adapt has never been greater. That starts with facing some hard truths and a willingness to change the status quo.

Greg points out what we’ve been saying for the last three years:

…sometime in the last few years a number of our key security technology controls crossed that threshold and ceased to be effective, yet as an industry we have yet to adjust. We’re pouring billions of dollars–literally–into security products that are gaining us very little. We don’t retire anything but rather pile on more layers, leading to increased complexity, expense, and exposure.

One of the big three security technology controls Greg calls out is firewalls. I would be more specific and say “stateful inspection” firewalls. These have been the staple of network security for 15 years. But Web 2.0 applications and social networking breeze right by the stateful inspection firewall. In fact, the stateful inspection firewall provides practically no control or protection at all.

Fortunately, we have begun to see the rise of what Gartner calls the Next Generation Firewall as exemplified by Palo Alto Networks. NextGen Firewalls are application aware and more importantly enable you to build policies based on applications and users rather than ports, protocols, and IP addresses.

Greg’s four recommendations are:

1) Start spending money on controls that are more in line with threats. This is in fact why Cymbel has embraced (and enhanced) the SANS 20 Critical Security Controls for Effective Cyber Defense. Controls were selected based knowledge of exploits. For example, Controls #1 and #2 are about Discovery of network assets and the software running on them. Unknown and/or unmanaged devices will thwart a patch management program every time.

2) Adjust assumptions and put to rest some age-old debates. For example the insider vs. outsider debate. Due to what we call the ‘inside-out” attack vector, the outside attacker becomes an insider once the attacker steals the insider’s credentials. We discuss this in more detail in the Threats section of the Five Forces of Change. This is why internal network segmentation based on application and user policies has become critical.

3) Stop rewarding ineffectiveness and start rewarding innovation. Here Greg repeats his observations about the ineffectiveness of (stateful inspection) firewalls and antivirus. It is for this reason that we developed our Next Generation Defense-in-Depth architecture, which features real, proven, innovative solutions which mitigate these new threats. Another good example is FireEye, which prevents 0-day and unknown malware attacks using heuristics plus virtual sandboxes to test suspicious code. The virtual sandbox capability practically eliminates false positives, the bane of heuristics-based intrusion prevention systems.

4) Know when security products cannot help you. Technology is not always the answer. Our Approach, based on the SANS 20 Critical Controls acknowledges this as well. While the first 15 are automation oriented, the last five are not: Secure Network Engineering, Penetration Testing, Incident Response Capability, Data Recovery Capability, Security Training.

The validation of our approach to information security is gratifying. Thanks Greg.

13. October 2010 · Comments Off on Read ‘Em All: Pentagon’s 193 Mind-Numbing Cybersecurity Regs | Danger Room | · Categories: SANS 20 Critical Controls · Tags:

Read ‘Em All: Pentagon’s 193 Mind-Numbing Cybersecurity Regs | Danger Room |

According to the Deputy Assistant Secretary of Defense for Cyber, Identity & Information Assurance (DASD CIIA) there are 119 different information security documents published by the Department of Defense (including the NIST SP 800 series). DASD CIIA helpfully published a two-foot long chart to help you make sense of it all.

Perhaps they ought to take a look at the SANS 20 Critical Security Controls for Effective Cyber Defense. The whole thing is only 58 pages.