Showing posts with label Intellectual Property. Show all posts
Showing posts with label Intellectual Property. Show all posts

08 June 2019

New Vision: Security Operations Center and CIU...

Flashback over 8 years ago when there was a convergence of thinking about the topic of a "Defensible Standard of Care" going on in the industry.

The key Operational Risk Management news from the 2011 RSA Conference was coming in, yet there were inside sources who still needed to be interviewed. What did they think was the most brilliant presentation or idea(s) presented?

This particular release caught some eyes as it addressed much of the thinking on the latest evolution of the Security Operations Center (SOC).  How much of this is still relevant today:

New Vision for Security Operations: Six Core Elements
The vision includes six core elements and prescriptive guidance for how to incorporate these elements into existing security operations. These elements include:
  • Risk planning: The new SOC will take a more information-centric approach to security risk planning and invest in understanding which organizational assets are highly valuable and essential to protect. With priorities based on GRC policies, security teams need to conduct risk assessments that focus on the “crown jewels” of the enterprise.
  • Attack modeling: Understanding attack modeling in a complex environment requires determining which systems, people and processes have access to valuable information. Once the threat surface is modeled, organizations can then determine potential attack vectors and examine defense steps to isolate compromised access points efficiently and quickly. RSA® Laboratories has developed theoretical models based on known APT techniques and employed game theory principles to identify the most efficient means of severing an attack path and optimize defense costs.
  • Virtualized environments: Virtualization will be a core capability of tomorrow's SOC – delivering a range of security benefits. For example, organizations can "sandbox" e-mail, attachments and URLs suspected of harboring malware. Anything suspicious can be launched in an isolated hypervisor and the virtual machine can be cut off from the rest of the system.
  • Self- learning, predictive analysis: To remain relevant in tomorrow's IT environment, a SOC will need to truly integrate compliance monitoring and risk management. The system should continually monitor the environment to identify typical states which can then be applied to identify problematic patterns early. Statistic-based predictive modeling will be able to help correlate various alerts. Developing such a system will require real-time behavior analysis innovations, although some of these elements are available today.
  • Automated, risk-based decision systems: A key differentiator of a more intelligent SOC will be its ability to assess risks instantly and vary responses accordingly. Similar to risk-based authentication, the SOC will employ predictive analytics to find high-risk events and then automatically initiate remediation activities. The prospect of dynamic typography is one of the most exciting areas of this type of systems automation for the cloud. To implement an APT, an attacker must understand network mapping and be able to model it. In response to this, organizations can remap their entire network infrastructure to disrupt an attacker’s reconnaissance efforts. This is akin to physically rearranging a city at frequent intervals – and the entire process can be automated so that links between systems stay intact and dependencies are handled without human intervention.
  • Continual improvement through forensic analyses and community learning: Although forensic analysis can be resource-intensive, it is an imperative element of a SOC and key to mitigating the impact of subsequent attacks. Virtualized environments can provide snapshots of the IT environment at the time of the security event providing useful information if detection of the attack was delayed. Having a way to share information about attack patterns will be the future of the SOC. This concept should be embraced in order to exchange threat information within respective industries and better predict the path of the APT and thereby determine countermeasures.
The evolution of the SOC in your enterprise may start in some unconventional places. Who is it in your organization that is responsible for the loss of corporate assets?

Who in your company is the one who determines what items are counted as losses to the bottom line?

Who does the enterprise look to when the crisis hits and people are looking for answers in minutes, not hours, or days?

Who picks up the phone to answer the call from the local FBI Field Office?

These may not be the people you think of in the CIO's office or IT department. These people however need to be part of the combined Security Operations Center solution in the company.

The Advanced Persistent Threat (APT) now requires the intersection of prudent strategy from the business leadership, the accounting or finance leadership and the risk management leadership.

If the CIO is looked upon as the key executive running a "Utility" inside the enterprise, think again.

This blog has discussed the "Corporate Intelligence Unit" in years past :

Beyond the utilization of threat assessment or management teams, enterprises are going to the next level in creating a "Corporate Intelligence Unit" (CIU). The CIU is providing the "Strategic Insight" framework and assisting the organization in "Achieving a Defensible Standard of Care."

The framework elements that encompass policy, legal, privacy, governance, litigation, security, incidents and safety surround the CIU. It includes with effective processes and procedures that provides a push / pull of information flow. Application of the correct tools, software systems and controls adds to the overall milestone of what many corporate risk managers already understand.

The best way in most cases to defend against an insider attack and prevent an insider incident is to continuously help identify the source of the incident, the person(s) responsible and to correlate information on other peers that may have been impacted by the same incident or modus operandi of the subject. "Connecting The Dots" with others in the same company or with industry sector partners, increases the overall resilience factor and hardens the vulnerabilities that are all too often being exploited for months if not years.

In retrospect, you can be more effective investigating and collecting evidence in your company to gain a "DecisionAdvantage". To pursue civil or criminal recovery of losses from these insider incidents, you may not go to law enforcement, but it's likely they will come to you once they get a whistle blower report, catch the attacker and/or they have the evidence that you were a victim.
How your organization pulls together the right people to staff and operate your "CIU" is going to depend on your culture, funding and current state of the threat.
BALTIMORE— -
It has been a month since the City of Baltimore's networks were brought to a standstill by ransomware. On Tuesday, Mayor Bernard "Jack" Young and his cabinet briefed press on the status of the cleanup, which the city's director of finance has estimated will cost Baltimore $10 million—not including $8 million lost because of deferred or lost revenue while the city was unable to process payments. The recovery remains in its early stages, with less than a third of city employees issued new log-in credentials thus far and many city business functions restricted to paper-based workarounds.
Here is another thought. A thorough review of the current funding, staffing and strategy of a SOC or CIU in the enterprise, may even become a priority at the next "Board of Directors" meeting.

19 March 2017

Startup Strategy: Opportunity of Digital Trust in a New Era...

The startup ecosystem of new ideas for SaaS platforms or mission based digital solutions are becoming evermore robust, in our growing economy.  As a result, Operational Risk professionals are more in demand to help new co-founders adapt to the legal, compliance and consumer transparency requirements, that will soon descend upon them.

It makes sense, that when you are starting a new company you first are focused on the product/mission and who the intended market or user will be.  Yet soon after this is defined and the "Go-to-Market" strategy is in place, there is a tremendous amount of Operational Risk design and implementation of internal capabilities, that will be required.  In just Social Media, here is just one example:
"As social networks continue to mature, they increasingly take on roles they may not have anticipated. Moderating graphic imagery and hate speech, working to address trolling and harassment, and dealing with dissemination of fake news puts companies like Facebook and Twitter in powerful societal positions. Now, Facebook has acknowledged yet another challenge: Keeping your data safe from surveillance. That’s harder than it may sound. When you post something publicly on a social network, anyone can view it—including law enforcement or federal agencies."
Since the dawn of the Internet, new startup companies have been developing algorithms and bots to scour the vast landscape of "data oceans" for relevant content.  As public Internet tools, databases and consumer-oriented web sites were developed for even Blogs (Blogger.com) such as this one, other companies were figuring out how to capture the data content in their searchable systems.

Years later, startups developed ways to develop the API as a new product-set, so that other companies could embed and utilize a set of data or capability and have it more integrated with a new set of functionality or service mission.  What is one company in this category focused on Twitter?  Gnip.com:
"PowerTrack provides customers with the ability to filter a data source’s full firehose, and only receive the data that they or their customers are interested in. This is accomplished by applying Gnip’s PowerTrack filtering language to match Tweets based on a wide variety of attributes, including user attributes, geo-location, language, and many others. Using PowerTrack rules to filter a data source ensures that customers receive all of the data, and only the data they need for your app."
So what?

If you are a startup company that is planning on a pledge to your customers to "Keeping your data safe from surveillance," just as the juggernaut Facebook is also currently doing, you have a tremendous amount of work and new processes/systems to get in place.  You are embarking not only on the steep growth curve of adding new customers and revenue; you are simultaneously under the mandate to help achieve a higher level of "Digital Trust" with those same customers.

Developing the policy alone is only the start.  Here is how Twitter is addressing it:

"To be clear: We prohibit developers using the Public APIs and Gnip data products from allowing law enforcement — or any other entity — to use Twitter data for surveillance purposes. Period. The fact that our Public APIs and Gnip data products provide information that people choose to share publicly does not change our policies in this area. And if developers violate our policies, we will take appropriate action, which can include suspension and termination of access to Twitter’s Public APIs and data products."

How Facebook and Twitter and Snapchat or LinkedIn and all of the hundreds of Social Media companies will scale up enforcement, is now the big question.  Maybe they have the deep pockets and resources to build and operate their "Digital Trust" business unit.  What about the new startup with only 6 or 7 figures in the bank from a seed or even "A" round of funding?

The policy implications and new federal laws being drafted in the United States and the European Union may be good indicators of where the future requirements will be defined for a new startup.  In the EU this week, the G20 finance ministers are converging on the topic of "Cyber Crime" soon after a recent indictment:
"Two intelligence agents from Russia, another G20 member, with masterminding the 2014 theft of 500 million Yahoo accounts. The indictment was the first time U.S. authorities have criminally charged Russian spies for cyber offences including for computer fraud, economic espionage, theft of trade secrets, and wire fraud."
How will the new startup who is focused on addressing transparency, privacy, and surveillance now "Enable Digital Trust of  Global Enterprises."  Here is a glimpse from the latest PwC CEO Survey:

"Yet, if forfeiting people’s trust is a sure-fire route to failure, earning their trust is the single biggest enabler of success. As an example, the progression from assisted to augmented to autonomous intelligence depends on how much consumers and regulators trust machines to operate on their own. That, in turn, depends on whether those who create the machines have the right risk and governance structures, the means to verify and validate their claims independently and the mechanisms to engage effectively with stakeholders."

"In short, trust is an opportunity, not just a risk. Many CEOs recognise as much: 64% think the way their firm manages data will be a differentiating factor in future. These CEOs know that prioritising the human experience in a virtual world entails treating customers with integrity."


Welcome to the new era of achieving Digital Trust...

17 December 2016

Sprint: Accelerating into the Unknown...

"If you want to go fast, go alone.  If you want to go far, go together"...
  --African Proverb
When you or your organization makes the decision to trust a market, a client, a solution and a model for business; there has already been an adaptive process.  The Operational Risks that you take as an entrepreneur, a designer, a software developer, a financier and the delivery mechanism are continuously changing.  People, Process, Systems and External Events.

You started this project to solve a large problem.  A big issue in a market or with an industry.  The "World's Most Innovative Companies" have been following a proven formula for decades.  What is their secret Intellectual Property?

In the R & D sections of the Defense Industrial Base or the Information, Communications and Technology (ICT) sector, the lights are never turned off.  The competitive world we live in requires that the proven process runs, finishes and repeats.  Then it is replicated across business units, departments and subsidiaries in other countries.

What if you are now testing new ideas to save lives or reduce potential harm to a small team or even the public at large.  What if you will be introducing your solution to a highly regulated market with a long process for government approvals?  What if the current bureaucratic overhead to accelerate your ideas prevents you from achieving the trust you require with your beneficiaries?  Answer:  You pivot to this 5 Step Process:
  • Map
  • Sketch
  • Decide
  • Prototype
  • Test
Five simple steps accomplished over the course of five days may seem easy.  It isn't.  The process for solving big problems and getting to a place where a financier is going to fund your project, is really difficult.  It requires perseverance and an insatiable desire to achieve outcomes that you and your team know can work.  That will improve the odds of survival.  Here is just one example, of a Map for a "Universal Communication Service" device problem-set:

TrustDecisions | Digital Reasoning | All Rights Reserved.
When you start the process with the Strategy, Voice of the Beneficiary, Subject Matter Experts and pieces of previous efforts by creating a "Map",  your overall risk factors start to become more apparent.  By stimulating the visual elements of the human brains capacity for creative inspiration, you begin to see all the possibilities and also the challenges ahead.

Next, you start with the target beneficiaries perspective, by starting with the end (outcomes) in mind.  A "Backwards from Perfect" process or variation that seeks to understand and answers the question, Will the beneficiaries of the solution, trust our expertise?  Will they utilize this solution?

The human imagination is endless.  Rarely does it flourish when you want it to.  So be careful to plan for the fact, that the best ideas and new breakthrough thinking will not happen in the same room with all of the stakeholders, looking at a Map or a Sketch.  It just might happen as one of the participants is in the shower on Day 3, or taking an evening walk after dinner, with a colleague on Day 4.

So what?

The questions asked and process delivered, is vital to any organization who is solving big problems.  Solving problems are only finally accomplished, when the beneficiary says so.  When the market accepts the solution or the human using the tool achieves enough trust in it, to use it again and again.  When the point in time arrives that the solution is verified and desired by enough people, then perhaps the problem has been sufficiently solved.

Until the next human decides to improve on it.  Or the next human believes there is a better way.  Or the environment that the solution was designed for, changes dramatically.  Now it may be time to get back into that room down the hall, with all the White Boards, Post-it Notes, Markers, Timers and some Healthy Snacks.

What does the unknown future look like?  At dawn, just early enough to know it is time to move forward faster than your opposition...

Begin Morning Nautical Twilight


The start of that period where, in good conditions and in the absence of other illumination, enough light is available to identify the general outlines of ground objects and conduct limited military operations. Light intensification devices are still effective and may have enhanced capabilities. At this time, the sun is 12 degrees below the eastern horizon. Also called BMNT...

09 April 2016

Trade Secrets: Gearing up for DTSA...

The Fortune Global 500 and the smallest research and development organizations in the U.S. have another ruleset to keep their eye on this week.  It is named DTSA or S.1890 - Defend Trade Secrets Act of 2016 has passed the Senate.  Operational Risk Management (ORM) is preparing for the next addition to national laws.

The attribution of cyberespionage adversaries has been gearing up since the Sony Pictures hack.  The private sector has been hunting and identifying those shadow individuals and nation state special units for years.  Now the lawyers can get more aggressive with civil actions.

The question remains, will another law deter the actions by global organized crime and the intelligence community of some significant nations?  How will attribution and more aggressive civil actions in foreign jurisdictions make a difference?

As a global organization, can you access your database of confidential trade secrets?  No different than the task of the identification of information assets that you are going to protect, you need an inventory.  What are they and where are they?  Everyone knows the formula for "Coca-cola" is written on a single piece of paper that is locked up in a vault in Atlanta, GA right?  Or is it?

There are trade secrets across America that have been stolen by operatives working inside organizations.  They may be preparing to leave the U.S. for another country outside the reach of law enforcement and the legal process for seizing the stolen property.  That is going to change soon.
The EX-Parte Seizure Order is part of the Trade Secrets bill that allows a trade secret owner to obtain an order from a judge for U.S. marshals to seize back the trade secret from the alleged bad actor without prior warning. This is to protect the trade secret owner from having the alleged bad actor skip the country or destroy the evidence before it is recaptured.
Now that Trade Secrets are in the same legal and enforcement category with patents and trademarks, you can predict that your legal budgets will need to be adjusted, upwards.  In general, what is a Trade Secret?
The subject matter of trade secrets is usually defined in broad terms and includes sales methods, distribution methods, consumer profiles, advertising strategies, lists of suppliers and clients, and manufacturing processes. While a final determination of what information constitutes a trade secret will depend on the circumstances of each individual case, clearly unfair practices in respect of secret information include industrial or commercial espionage, breach of contract and breach of confidence.
The effort to make intellectual property a "Trade Secret" is another strategy in itself. The determinations to designate something a trade secret is going to depend on the invention or the data itself. We understand. So what?
A Chinese businessman pleaded guilty Wednesday (March 23) in federal court in Los Angeles to helping two Chinese military hackers carry out a damaging series of thefts of sensitive military secrets from U.S. contractors.

The plea by Su Bin, a Chinese citizen who ran a company in Canada, marks the first time the U.S. government has won a guilty plea from someone involved with a Chinese government campaign of economic cyberespionage.

The resolution of the case comes as the Justice Department seeks the extradition from Germany of a Syrian hacker — a member of the group calling itself the Syrian Electronic Army — on charges of conspiracy to hack U.S. government agencies and U.S. media outlets.
Our adversaries are determined. They are already here. It has been documented for years. Let the next wave of legal indictments and seizures begin. One thing is certain. The "Insider Threat" is still present and your organization can do better. The ability to effectively utilize the correct combination of controls, monitoring, technology and internal corporate culture shifts will make all the difference. What are you waiting for?

23 August 2015

Legal Risk: The Insider Threat from Outside Counsel...

What will the "New Normal" be for the United States in the era of increased scrutiny on privacy law, civil liberties and the continuous quest for the security of the Homeland?  Operational Risk Management (ORM) professionals are ever more focused on "Information Operations" and counterintelligence functions while simultaneously working side-by-side, with their own General Counsel.  The laws in each state are changing and being updated as the Federal legislation stalemate continues:
Connecticut Updates its Data Security Laws, Imposing Stringent New Requirements By Ellen Moskowitz on July 15th, 2015 Posted in Legislation

On June 30, 2015, the Governor of Connecticut signed into law S.B. 949, “An Act Improving Data Security and Agency Effectiveness.”[1] The new law updates Connecticut’s data security laws, including by adding a 90-day hard deadline for data breach reporting, requiring companies in some cases to offer data breach victims a year of free identify theft prevention services, imposing new and specific data security program requirements on health insurance companies and other entities subject to Insurance Department regulation, and requiring state agencies to impose certain detailed security requirements on state contractors that maintain personal information. With a near constant stream of data breaches affecting entities from health insurers to retail giants to the government, the law responds to growing fears of data security.

Under the new law, beginning October 1, 2015, a data breach will require any person or entity conducting business in Connecticut to give notice “without unreasonable delay,” but now no later than 90 days after discovery of the breach, to state residents whose personal information was breached or reasonably believed to have been breached. The Connecticut Attorney General stated in a press release that 90 days is an “outside limit” that does not diminish his discretion to take action against entities who “unduly delay” notification.[2] Importantly, the law also requires the provision of at least twelve months of free identity theft prevention and mitigation services, but only in cases where Social Security numbers are breached or reasonably believed to have been breached.
If you happen to be concerned about the "Insider Threat" within your enterprise, then you realize the importance of creating the foundations for a sound legal framework.  One that addresses the rules that must be followed and the protocols for building trust with key corporate partners.  This includes the outside counsel that your enterprise engages with on an annual basis.

So what legal duty of care do your retained outside counsel have to secure your information?  What do they have in the environments that they operate in that may cause additional legal risks for your enterprise?  Do they understand the difference between information security and confidentiality?

First tier supply chain partners such as outside counsel are no different than the cloud provider or the HVAC contractor that may have access to the corporate network.  So what is the root cause of substantial intellectual property theft and industrial espionage targeted on law firms?  Failing to understand the vast landscape of "Operational Risk."  This includes negligent conduct and intentional misconduct.  So what can you do now to improve the outcomes of managing the legal risks of "Outside Counsel"?

Start a Dialogue:  Request a commitment to review the privacy vs. security environment of the key retained firms who provide the outside legal work for the enterprise.  Provide a case example of your corporate information security structure and priorities.

Ask Questions:  The whole spectrum of information security deserves a deep dive in the dialogue on managing digital information, making effective "Trust Decisions" and addressing eDiscovery and Records Management questions.

Team Together:  What if you worked with your outside firm to create a solution that included a collaborative design, prioritized execution, insisted upon cooperative feedback and insured continuous improvement?  Get your legal teams to train together with your CISO and CIO security teams.

Revise the Engagement Letter:  The contracting language must include the nuances of information security, privacy controls and an informative strategic plan for the inevitable point in time when there is a data breach at your outside counsel.  More here:
As Willie Sutton supposedly said, he robbed banks “because that’s where the money is.”  That also explains why law firms and lawyers are increasingly the targets of cyber-intrusion, particularly phishing scams.  Apparently, phishing in legal waters can yield a full net of stolen information.

“Most likely” to take the bait
Verizon’s 2015 Data Breach Investigations Report has found that a company’s legal department is among the ones that are “far more likely to actually open [a phishing] e-mail than all other departments.”

In case you’ve been living under a rock, “phishing” is the attempt to obtain sensitive information fraudulently by means of a deceptive electronic communication that appears to come from a trustworthy source.  (Some link the term to the indie rock group Phish, but according to Computerworld magazine, the term was coined round 1996, with the obvious analogy to the sport of angling using a lure.  Under that view, the “ph” is a nod to an old form of telephone hacking known as “phone phreaking.”)

Shockingly, Verizon found that 23 percent of recipients open phishing messages, and 11 percent click on the fatal attachments.

14 December 2014

Intellectual Property: Material Risks Disclosure- Assumption of Breach...

The rules of the game may have changed across the corporate landscape.  Corporations that have been proactive in the management of Operational Risks, are making headlines in the published press. There is a race to build new 100,000 Sq. Ft. data centers around the globe, in order to satisfy the insatiable competitive appetite of bandwidth hungry enterprises:
Sony Pictures Entertainment is fighting back. 
The studio behind the “Spider-Man” franchise and “The Social Network” has taken technological countermeasures to disrupt downloads of its most sensitive information, which was exposed when a hacking attack crippled its systems in late November.

The company is using hundreds of computers in Asia to execute what’s known as a denial of service attack on sites where its pilfered data is available, according to two people with direct knowledge of the matter. 
Sony is using Amazon Web Services, the Internet retailer’s cloud computing unit, which operates data centers in Tokyo and Singapore, to carry out the counterattack, one of the sources said. The tactic was once commonly employed by media companies to combat Internet movie and music piracy. 
In one of the most devastating cyber security breaches in recent memory, a hacking group calling itself Guardians of Peace claimed to have stolen just under 100 terabytes of Sony Pictures’ financial information, budgets, payroll data, internal emails and feature films and has slowly leaked portions of it to public file-sharing sites such as PasteBin.
The cyber war has been facilitated by the rise of substantial new digital weapons and the cloud-based compute power to make it all happen.  The question is not who is behind the latest DoS of "PasteBin" as much as when the next Stuxnet-like design will gain favor, by a private sector organization.  You see, the use of sophisticated offensive cyber malware is not new.  No different than conventional chemical weapons that are developed by nation states, the variants and new "Zero Days" ultimately could end up in the hands of militias and clandestine dark sites on the net for sale.

In the recent book "Countdown to Zero Day" by Kim Zetter, the point is made:
Before Stuxnet, most of America’s military and intelligence cyber-operations focused on stealing or distorting data, or used cyber-tools to help direct U.S. weapons. Stuxnet was envisioned by U.S. officials as a replacement for a conventional weapon. Using a computer virus or worm to gum up the works of something from within would provide an alternative to, say, destroying a nuclear facility from the air. Stuxnet appears to have done that. “Stuxnet stands alone as the only known cyberattack to have caused physical destruction to a system,” Zetter writes.
The physical digital copying, erasure or even encryption of corporate data, that then becomes the focus of an extortion plot, is the Operational Risk Management (ORM) business problem that remains on your Board Room doorstep. The Sony Board of Directors now understand the liability of dealing with a $100 million plus incident, as an adverse material event, spawned from the cyber domain.  The rules of the digital game have changed.  Now what can be done about this particular wake up call?

Besides getting your outside counsel ramping up for a tremendous cache of billable hours and your Information Governance Teams burning the midnight oil, the future strategy is now evolving.  How many digital files in your corporation contain proprietary Intellectual Property (IP)?  If you don't know the answer, then we recommend that you start counting.  You need to figure out what the value is, of all this data and for good reason.  At the other end of the Operational Risk spectrum are the SEC regulatory issues in the U.S..  Jeffrey Carr explains here:
“Consistent with the Regulation S-K Item 503(c) requirements for risk factor disclosures generally, cybersecurity risk disclosure provided must adequately describe the nature of the material risks and specify how each risk affects the registrant. Registrants should not present risks that could apply to any issuer or any offering and should avoid generic risk factor disclosure.” 
The value of your particular organizations Intellectual Property can then be compared against the requirements for your IP, on a global basis.  What countries or companies are spinning up Research & Development operations in the same IP space that your organization is operating in?  What U.S. companies are encouraged to relocate a manufacturing plant overseas?  Why is this significant? The correlation is that if there are a rising number of foreign R&D labs focused on your particular category of IP, then you can guess that your company is going to be a substantial target for sustained industrial espionage.  Regulatory burdens exist and yet may not be the greatest risk.

When there is not enough time or money to infiltrate your organization with insider human assets, then the outsourcing of digital theft campaigns will begin, or a combination of insider theft operations in cooperation with outsourcing.  The hackers-for-hire trade, is larger than you may know.  How much do you think a nation state would pay for a "Stuxnet" Zero Day on the open market in todays U.S. dollars?  Mid to high six figures.  Not likely.  7 or 8 figures is getting closer.

While the malware designed for the exfiltration of data from Sony Pictures is different than Stuxnet's design to disrupt a specific type of Siemens Controller for a certain IR-1 centrifuge, the intent and motive may be quite similar.  To disrupt and destroy the capabilities of your adversary.  Now the question for Sony is whether this was a nation state or simply a "disgruntled insider," or possibly both that can be attributed to the sabotage attack.

The complexity and the longevity of the risk is evident.  The magnitude and the impact of the destruction is apparent.  Are you sure you don't have an Insider Threat?  See appendix C here:
This fourth edition of the Common Sense Guide to Mitigating Insider Threats provides the most current recommendations of the CERT® Program (part of Carnegie Mellon University's Software Engineering Institute), based on an expanded database of more than 700 insider threat cases and continued research and analysis. It introduces the topic of insider threats, explains its intended audience and how this guide differs from previous editions, defines insider threats, and outlines current patterns and trends. The guide then describes 19 practices that organizations should implement across the enterprise to prevent and detect insider threats, as well as case studies of organizations that failed to do so. Each practice includes features new to this edition: challenges to implementation, quick wins and high-impact solutions for small and large organizations, and relevant security standards. This edition also focuses on six groups within an organization-human resources, legal, physical security, data owners, information technology, and software engineering-and maps the relevant groups to each practice. The appendices provide a revised list of information security best practices, a new mapping of the guide's practices to established security standards, a new breakdown of the practices by organizational group, and new checklists of activities for each practice.

01 October 2009

Remote Digital Forensics: Complacency Risk...

Operational Risk Management commands a spectrum of disciplines within the global corporate enterprise. While convergence of responsibility, accountability and resources is taking place the internal threats continue to flourish. Why? How could a Chief Security Officer (CSO) not be aware of a specific threat to the institution by unknown subjects half way around the world? The transnational organized crime syndicates that target our weakest organizations know that they don't share information between departments, business units or even shared services within the enterprise. Does your CSO get a briefing from the CISO or CIO / INFOSEC staff on what the latest threats mean to you, such as cyber heists using ACH fraud?

This complacency is an internal threat that continues to amaze many and reinforces what few people truly understand about risk management. The adversaries utilize asymmetric strategy against unsophisticated targets to perpetuate their crimes and overall threats to people, processes, systems and deposit accounts. They are the modern day equivalents of "Bonnie & Clyde", Al Capone with a dash of Al Gonzales all rolled up into a massive threat that is increasing exponentially:

Two Romanian Citizens Extradited to the United States to Face Charges Related to Alleged Phishing Scheme

A phishing scheme uses the Internet to target large numbers of unwary individuals, using fraud and deceit to obtain private personal and financial information such as names, addresses, bank account numbers, credit card numbers, and Social Security numbers. Phishing schemes often work by sending out large numbers of counterfeit e-mail messages, which are made to appear as if they originated from legitimate banks, financial institutions, or other companies.

The investigation leading to the indictment stemmed from a citizen’s complaint concerning a fraudulent e-mail message made to appear as if it originated from Connecticut-based People’s Bank. In fact, the e-mail message directed victims to a computer in Minnesota that had been compromised, or “hacked,” and used to host a counterfeit People’s Bank Internet site. During the course of the investigation, it was determined that the defendants had allegedly engaged in similar phishing schemes against many other financial institutions and companies, including Citibank, Capital One, JPMorgan Chase & Co., Comerica Bank, Wells Fargo & Co., eBay, and PayPal.


Risk Management 101 talks to the X and Y axis with X representing the frequency of risk and Y representing the severity (impact) of the risk. So using the four quadrant model, the lower right box is where low risk times high frequency incidents occur. In the upper left box is where high risk times low frequency incidents occur. Got it.

As a CSO in your organization, where do you spend your time, resources and personnel in terms of their training, awareness and work efforts? Think about it for a minute. Most of you would probably say, "Well we focus on the High Frequency times High Risk incidents, the upper right box of the Risk Management model." Practice and prepare for the incidents that happen often and you will have employees who have no clue on what to do the day that something from that upper left box impacts your organization. The HIGH RISK x LOW FREQUENCY incidents are where you remain most vulnerable.

Arlington Man Sentenced 36 Months for $40 Million Ponzi Scheme

ALEXANDRIA, VA—Preston David Pinkett II, age 70, of Arlington, Va., was sentenced to 36 months in prison for engaging in a massive Ponzi scheme that raised more than $40 million in fraudulent payments from investors. Pinkett was also sentenced to three years of supervised release and ordered to pay $18,774,989 in restitution.


The two years that most frauds are conducted before they are discovered tells most risk managers that even effective accounting and audit controls can't catch these white collar criminals before it's too late. The high risk low frequency incidents are the greatest impact on your institution and yet little or no resources, training or attention is paid to these threats to your reputation and economic livelihood.

Now let's take this step further into what practices you have with exiting employees from your business. Are you conducting exit interviews? Are you examining all of the employee's digital assets for the presence of anti-forensics or the ex-filtration or theft of sensitive, proprietary trade secrets or intellectual property from the corporation? Both of these steps are necessary regardless of the person leaving and the circumstances why they are leaving your institution.

The utilization of "Remote Digital Forensics" and other centralized shared services such as this can provide your Business Units and even suppliers with capabilities that they don't need to staff internally. The technologies and resources exist today to address the stealth of fraud, the crisis stemming from industrial espionage or the disgruntled employee stalking those who they perceive as the reason for their dismissal.

An effective internal approach to high tech and advanced Operational Risk Management as it pertains to the rapidly changing landscape of smart, educated and daring people shall include a robust intelligence and audit capacity. Without it, the transnational eCrime syndicates or the internal employee threat will prey on your vulnerabilities of complacency, lack of training and apathetic approach to the design, configuration or implementation of your systems.

17 January 2008

IPR Risk: Beijing Olympics 2008 & Beyond...

The global corporate security directors have been planning for the 2008 Olympic Games in China for well over a year now. Company employees of Fortune 500 institutions who are in the intellectual property and branding departments have been working feverishly for even longer. What do the two have in common?

Safety, Security and Intellectual Property Rights (IPR) Protection to name a few. The stakes are tremendous and the world's stage for sports and marketing is coming soon to a web site, cell phone and e-mail in your control. These Operational Risks are growing especially to Corporate Travelers and other Executive Management who have engaged in negotiations and business deals for the past 24 months. Let's put some of this into context:

China Customs is committed to providing Beijing Olympic Games with good service in all respects and is entitled to conduct control over Olympic materials entering or leaving China Customs territory (hereafter referred to as the territory) in accordance with relevant laws and regulations. This notice applies to the completion of Customs formalities and the payment of Customs duties and the taxes collected by Customs on behalf of other government departments for importation of all materials entering or leaving the territory (hereafter referred to as the inward and outward materials) for the Olympic Games, Paralympics, testing-games, torch relay and other related activities during Beijing Olympic Games and its preparation period. The time for Beijing Olympic Games and its preparation period refer to the time starting from January 1st,, 2007 to October 17th,, 2008.


This is a facet of the puzzle that corporate marketing and operations management have ironed out for the most part. However, what is being addressed from another Intellectual Property perspective is another question. The Digital Age is certainly upon us and this brings a heightened sensitivity to the strategy for employees who plan on visiting China, before, during and after the Olympic Games in 2008.


Companies often have negotiated contractual obligations to protect confidential and trade secret information of customers, vendors, and business partners. Companies aggressively guard against theft or loss of intellectual property, however, the loss of sensitive employee and customer information can be just as damaging. Lose trust with your customer and you may lose the customer. Additionally, the media and public are paying increased attention to privacy breaches. Companies risk significant public embarrassment—not to mention potential litigation—if they fail to appropriately safeguard private and confidential information. Courts nationwide are also taking an increasingly intolerant view of companies that fail to take reasonable efforts to protect sensitive employee and customer data. The digital age has significantly increased the risk of data losses.


Security Advisory and OPS Risk Consulting firms have been gearing up for challenges global corporations face in the next six months. Increasing awareness, educating and training employees while testing the soundness of legal and security policies is just the beginning:


“The next wave of global coordinated attacks blends physical, logical and cyber exploits – specifically targeting high-value intellectual property and customer information around the world,” said Watters, iSIGHT Partners’ Founder, Chairman & CEO. “This trend will dominate the future threat landscape.”


John Watters knows the stakes and understands the magnitude of the digital challenges faced by corporate entities across the globe. In the wake of the speeding boat towards brand presence and intellectual property rights management, lies another common and misunderstood threat. It's called "guanxi".


Understanding this threat in the context and relevance to corporate stakeholders is vital. The focus on developing a vigilant strategy for interacting with business partners in China is imperative. Prudent CSO's and GC's are well on their way to rolling out the legal programs and security management training to mitigate the risks to their employees and their precious corporate secrets. This is the result of some very well known cases involving counterfeiting and enforcement of trademarks and intellectual property.

What might be less well known, is how digital information is being removed without your knowledge from devices such as laptops, cell phones and PDAs such as a Blackberry while you walk through the hotel lobby or the airport waiting area. Here is some easy advice and a simple strategy as you contemplate your intineary for the Olympic Games. Leave it at home, locked up in your corporate office.