Solving ransomware

We’re back in Baltimore. Unfortunately not to relive Arjun’s favourite pithy one-liners from The Wire, but to talk about something from the non-fiction genre: Ransomware.

In just a few years, ransomware has gone from nothing to a multi-billion dollar industry. And it continues to grow. It’s little wonder that law enforcement are quietly holding crises summits to ask for help.

In May of this year, the City of Baltimore was hit with a ransomware attack. The ransomware used was called RobbinHood and it encrypted an estimated 10,000 networked computers. Email systems and payment platforms were taken offline. Baltimore’s property market also took a hit as people were unable to complete real estate sales.

One click away

Like most public sector technology environments, there appears to have been a mix of old and new systems on the City of Baltimore networks. Precisely because they are old, aging systems are typically unable to be “patched” or updated for known security threats, making them vulnerable.

But getting funding to replace or update computing systems is difficult, especially when you are competing with critical services like police, fire and hospitals.

Given the hard reality that many large networks will have a high volume of outdated, and therefore vulnerable, systems that are only one mouse click away from becoming infected, should we not focus more on preventing malware from propagating?

Trust

Most global corporate networks operate using a trust principal. If you are part of the same domain or group of companies you are trusted to connect to each other’s network. This has obvious benefits, but it also brings a number of risks when we consider threats like ransomware.

Strategies

There are many strategies to mitigate the risk of a ransomware outbreak. Back up your files, patch your computers and avoid opening suspicious links or attachments are commonly advised. At elevenM, we recommend these strategies, however we also work closely with our clients on an often overlooked piece of the puzzle, Active Directory. The theory being: if your network cannot be used to spread malware, your exposure to ransomware is significantly reduced.

Monitoring Active Directory for threats

To understand this in more detail, let’s go back to Baltimore. According to reports, the Baltimore attack came through a breach of the City’s Domain Controller, a key piece of the Active Directory infrastructure. This was then used to deliver ransomware to 10,000 machines. What if Balitmore’s Active Directory had been integrated with security tools that allowed it to monitor, detect, and contain ransomware instead of being used to propagate it?

Working with our clients’ and Active Director specific tools we have been able to separate and monitor Active Directory based threat indicators including:

  • Lateral movement restriction
  • Obsolete systems
  • Brute force detection
  • Anonymous users behaviour

All the pieces of the puzzle

In mitigating cyber threats, defence teams today have access to many tools and strategies. Often, there emerges a promised silver bullet to a particular threat. But the truth is that most threats will require a layered defence, involving multiple controls and core knowledge of common IT infrastructure (like Active Directory). Or to put it again in the language of the streets of Baltimore: “All the pieces matter“.

Want to hear more? Drop us a line at hello@elevenM.com

End of year wrap

The year started with a meltdown. Literally.

New Year’s Eve hangovers had barely cleared when security researchers announced they had discovered security flaws that would impact “virtually every user of a personal computer”. “Happy new year” to you too. Dubbed “Meltdown” and “Spectre”, the flaws in popular computer processors would allow hackers to access sensitive information from memory – certainly no small thing. Chipmakers urgently released updates. Users were urged to patch. Fortunately, the sky didn’t fall in.

If all this was meant to jolt us into taking notice of data security and privacy in 2018 … well, that seemed unnecessary. With formidable new data protection regulations coming into force, many organisations were already stepping into this year with a much sharper focus on digital risk.

The first of these new regulatory regimes took effect in February, when Australia finally introduced mandatory data breach reporting. Under the Notifiable Data Breaches (NDB) scheme, overseen by the Office of the Australian Information Commissioner, applicable organisations must now disclose any breaches of personal information likely to result in serious harm.

In May, the world also welcomed the EU’s General Data Protection Regulation (GDPR). Kind of hard to miss, with an onslaught of updated privacy policies flooding user inboxes from companies keen to show compliance.

The promise of GDPR is to increase consumers’ consent and control over their data and place a greater emphasis on transparency.  Its extra-territorial nature (GDPR applies to any organisation servicing customers based in Europe) meant companies all around the world worked fast to comply, updating privacy policies, implementing privacy by design and creating data breach response plans. A nice reward for these proactive companies was evidence that GDPR is emerging as a template for new privacy regulations around the world. GDPR-compliance gets you ahead of the game.

With these regimes in place, anticipation built around who would be first to test them out. For the local NDB scheme, the honour fell to PageUp. In May, the Australian HR service company detected an unknown attacker had gained access to job applicants’ personal details and usernames and passwords of PageUp employees.

It wasn’t the first breach reported under NDB but was arguably the first big one – not least because of who else it dragged into the fray. It was a veritable who’s who of big Aussie brands – Commonwealth Bank, Australia Post, Coles, Telstra and Jetstar, to name a few. For these PageUp clients, their own data had been caught up in a breach of a service provider, shining a bright light on what could be the security lesson of 2018: manage your supplier risks.

By July we were all bouncing off the walls. Commencement of the My Health Record (MHR) three month opt-out period heralded an almighty nationwide brouhaha. The scheme’s privacy provisions came under heavy fire, most particularly the fact the scheme was opt-out by default, loose provisions around law enforcement access to health records, and a lack of faith in how well-versed those accessing the records were in good privacy and security practices. Things unravelled so much that the Prime Minister had to step in, momentarily taking a break from more important national duties such as fighting those coming for his job.

Amendments to the MHR legislation were eventually passed (addressing some, but not all of these issues), but not before public trust in the project was severely tarnished. MHR stands as a stark lesson for any organisation delivering major projects and transformations – proactively managing the privacy and security risks is critical to success.

If not enough attention was given to data concerns in the design of MHR, security considerations thoroughly dominated the conversation about another national-level digital project – the build out of Australia’s 5G networks. After months of speculation, the Australian government in August banned Chinese telecommunications company Huawei from taking part in the 5G rollout, citing national security concerns. Despite multiple assurances from the company about its independence from the Chinese government and offers of greater oversight, Australia still said ‘no way’ to Huawei.

China responded frostily. Some now fear we’re in the early stages of a tech cold war in which retaliatory bans and invasive security provisions will be levelled at western businesses by China (where local cyber security laws should already be a concern for businesses with operations in China).

Putting aside the geopolitical ramifications, the sobering reminder for any business from the Huwaei ban is the heightened concern about supply chain risks. With supply chain attacks on the rise, managing vendor and third-party security risks requires the same energy as attending to risks in your own infrastructure.

Ask Facebook. A lax attitude towards its third-party partners brought the social media giant intense pain in 2018. The Cambridge Analytica scandal proved to be one of the most egregious misuses of data and abuses of user trust in recent memory, with the data of almost 90 million Facebook users harvested by a data mining company to influence elections. The global public reacted furiously. Many users would delete their Facebook accounts in anger. Schadenfreude enthusiasts had much to feast on when Facebook founder and CEO Mark Zuckerberg’s uncomfortably testified in front of the US Senate.

The social network would find itself under the pump on various privacy and security issues throughout 2018, including the millions of fake accounts on its platform, the high profile departure of security chief Alex Stamos and news of further data breaches.

But when it came to brands battling breaches, Facebook hardly went it alone in 2018. In the first full reporting quarter after the commencement of the NDB scheme, the OAIC received 242 data breach notifications, followed by 245 notifications for the subsequent quarter.

The scale of global data breaches has been eye-watering. Breaches involving Marriott International, Exactis, Aadhar and Quora all eclipsed 100 million affected customers.

With breaches on the rise, it becomes ever more important that businesses be well prepared to respond. The maxim that organisations will increasingly be judged not on the fact they had a breach, but on how they respond, grew strong legs this year.

But we needn’t succumb to defeatism. Passionate security and privacy communities continue to try to reduce the likelihood or impact of breaches and other cyber incidents. Technologies and solutions useful in mitigating common threats gained traction. For instance, multi-factor authentication had more moments in the sun this year, not least because we became more attuned to the flimsiness of relying on passwords alone (thanks Ye!). Security solutions supporting other key digital trends also continue to gain favour – tools like Cloud Access Security Brokers enjoyed strong momentum this year as businesses look to manage the risks of moving towards cloud.

Even finger-pointing was deployed in the fight against hackers. This year, the Australian government and its allies began to publicly attribute a number of major cyber campaigns to state-sponsored actors. A gentle step towards deterrence, the attributions signalled a more overt and more public pro-security posture from the Government. Regrettably, some of this good work may have been undone late in the year with the passage of an “encryption bill”, seen by many as weakening the security of the overall digital ecosystem and damaging to local technology companies.

In many ways, in 2018 we were given the chance to step into a more mature conversation about digital risk and the challenges of data protection, privacy and cyber security. Sensationalist FUD in earlier years about cyber-attacks or crippling GDPR compliance largely gave way to a more pragmatic acceptance of the likelihood of breaches, high public expectations and the need to be well prepared to respond and protect customers.

At a strategic level, a more mature and business-aligned approach is also evident. Both the Australian government and US governments introduced initiatives that emphasise the value of a risk-based approach to cyber security, which is also taking hold in the private sector. The discipline of cyber risk management is helping security executives better understand their security posture and have more engaging conversations with their boards.

All this progress, and we still have the grand promise that AI and blockchain will one day solve all our problems.  Maybe in 2019 ….

Till then, we wish you a happy festive season and a great new year.

From the team at elevenM.

Our view on APRA’s new information security regulation

For those of you who don’t work in financial services and may not know the structure associated with APRA’s publications, there are Prudential Practice Guides (PPGs) and Prudential Standards (APSs or CPSs). A PPG provides guidance on what APRA considers to be sound practice in particular areas. PPGs discuss legal requirements but are not themselves legal requirements. Simply put, this is APRA telling you what you should be doing without making it enforceable.

On the other hand, APSs and CPSs are regulatory instruments and are therefore enforceable.

Until now, those working within a cyber security team at an Australian financial services company had PPG 234 – Management of security risk in information and information technology (released in 1 February 2010) as their only reference point as to what APRA were expecting from them in regard to their cyber security controls. But things have moved on a fair bit since 2010. Don’t get us wrong, PPG 234 is still used today as the basis for many ‘robust’ conversations with APRA.

APRA’s announcement

That leads us to the Insurance Council of Australia’s Annual Forum on 7th March 2018. It was at this esteemed event that APRA Executive Board Member Geoff Summerhayes delivered a speech which noted:

“APRA views cyber risk as an increasingly serious prudential threat to Australian financial institutions. To put it bluntly, it is easy to envisage a scenario in which a cyber breach could potentially damage an entity so badly that it is forced out of business.

“….What I’d like to address today is APRA’s view on the extent to which the defences of the entities we regulate, including insurers, are up to the task of keeping online adversaries at bay, as well as responding rapidly and effectively when – and I use that word intentionally – a breach is detected”

Summerhayes then went on to announce the release of the consultation draft of CPS 234 – Information Security. Yeah, actual legislative requirements on information security.

So what does it say?

Overall there are a lot of similarities to PPG 234 but the ones that caught our eye based upon our experience working within financial services were:

Roles and responsibilities

  • “The Board of an APRA-regulated entity (the Board) is ultimately responsible for ensuring that the entity maintains the information security of its information assets in a manner which is commensurate with the size and extent of threats to those assets, and which enables the continued sound operation of the entity”. – Interesting stake in the ground from APRA that Boards need to be clear on how they are managing information security risks. The next obvious question is what reporting will the Board need from management for them to discharge those duties?

Information security capability

  • “An APRA-regulated entity must actively maintain its information security capability with respect to changes in vulnerabilities and threats, including those resulting from changes to information assets or its business environment”. – Very interesting. There is a lot in this provision. First, there is a push to a threat based model, which we fully endorse (see our recent blogpost: 8 steps to a threat based defence model). Next, there is a requirement to have close enough control of your information assets to determine if changes to those assets somehow adjust your threat profile. Definitely one to watch. That brings us nicely to the following:

Information asset identification and classification

  • “An APRA-regulated entity must classify its information assets, including those managed by related parties and third parties, by criticality and sensitivity. Criticality and sensitivity is the degree to which an information security incident affecting that information asset has the potential to affect, financially or non-financially, the entity or the interests of depositors, policyholders, beneficiaries, or other customers”. – This really is a tough one. From our experience, many companies say they have a handle on this for their structured data with plans in place to address their unstructured data. In our experience however, very few actually do anything that would stand up to scrutiny.

Implementation of controls

  • “An APRA-regulated entity must have information security controls to protect its information assets, including those managed by related parties and third parties, that are implemented in a timely manner”. – Coming back to the previous point, there is now a requirement to have a clear line of sight of the sensitivity of data, this just adds to the requirement to build effective control over that data.
  • “Where information assets are managed by a related party or third party, an APRA-regulated entity must evaluate the design and operating effectiveness of that party’s information security controls”. – Third party security assurance is no longer a nice to have folks! Third party risk is referenced a couple of times in the draft, and so definitely seems to be a focus point. This will be very interesting as many companies struggle getting to grips with this risk. The dynamic of having to face into actual regulatory obligations however, is a very different proposition.

Incident management

  • “An APRA-regulated entity must have robust mechanisms in place to detect and respond to information security incidents in a timely manner. An APRA-regulated entity must maintain plans to respond to information security incidents that the entity considers could plausibly occur (information security response plans)”. – We love this section. A very important capability that often gets deprioritised when the dollars are being allocated. Whilst the very large banks do have mature capabilities, most do not. Pulling the ‘Banks’ industry benchmark data from our NIST maturity tool we see that for the NIST domain Respond, the industry average is sitting at 2.39. So in maturity terms it is slightly above Level 2 – Repeatable, where the process is documented such that repeating the same steps may be attempted. In short, many have a lot to do in this space.

Testing control effectiveness

  • “An APRA-regulated entity must escalate and report to the Board or senior management any testing results that identify information security control deficiencies that cannot be remediated in a timely manner, to enable an assessment and potential response by the Board or senior management to mitigate the exposure, as appropriate”. – Yep, we also love this. Putting formal requirements around the basic principle of ‘fix what you find’! The key message from us to Boards and senior management is make sure you are clear on what is in/out of scope for this testing and why.
  • “Testing must be conducted by appropriately skilled and functionally independent specialists”.- The Big 4 audit firms will be very excited about this one!

APRA Notification

  • “An APRA-regulated entity must notify APRA as soon as possible, and no later than 24 hours, after experiencing an information security incident”. –  Eagle-eyed readers will spot that this reflects mandatory data breach obligations that recently came into force under the Privacy Act on 22 February. The Privacy Act requires entities that experience a serious breach involving personal information, to notify the OAIC and affected individuals ‘as soon as practicable’ after identifying the breach. Another example of how companies now have to contend with notifying multiple regulators, on different time-frames. 

Conclusion

CPS 234 is just a draft, and ultimately the final product may be vastly different. Nevertheless, we feel APRA’s approach is a positive step to drive awareness of this significant risk, and one which will hopefully be used to baseline the foundational cyber security capabilities noted within. Well done, APRA!

Consultation on the package is open until 7 June 2018. APRA intends to finalise the proposed standard towards the end of the year, with a view to implementing CPS 234 from 1 July 2019.

Link to the consultation draft.


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