Single Points of Failure: Interdependencies Unknown...

Organizations such as WashingtonDCFIRST exist in our Nations Capital to address the need for a coalition of private sector companies and people to work on being proactive, not reactive.

"Defend Forward."

This requires leadership to focus on the critical interdependencies you share with your large corporate neighbor down the street or around the corner.

Do you both share the same Central Office from Verizon? Do you have the same pumping station for DC Water? Do you have a shared sub-station for power from Pepco?

If you do, then you both know some of your Single-Points-of-Failure.

While you may never be able to establish walls, or fences high enough and virtual ICS locked gates to totally protect your single-points-of-failure, you can create an architecture that deters attacks and detects changes.

And if you do have an alert or alarm go off, then you must investigate the incident no matter how insignificant it may be. Those organizations who believe that they are not in the bulls eye of some worthy adversary, should pay attention:

• Shape behavior  - The United States must work with allies and partners to promote responsible behavior in cyberspace. 
• Deny benefits  - The United States must deny benefits to adversaries who have long exploited cyberspace to their advantage, to American disadvantage, and at little cost to themselves. This new approach requires securing critical networks in collaboration with the private sector to promote national resilience and increase the security of the cyber ecosystem.
• Impose costs  - The United States must maintain the capability, capacity, and credibility needed to retaliate against actors who target America in and through cyberspace.

Your competitors and even your neighbors realize that this game, is not always about eliminating threats to your own corporate assets. It's about making sure that the attackers choose a much more vulnerable target than your own...

Scenario Vs. Resource Planning: All Hazards...

"Strive not to be a success, but rather to be of value" --Albert Einstein

This article by Saul Midler on Scenario Planning Vs. Resource Planning recently caught our eye and for a good reason. The link between Corporate Risk Management and Operational Risk Management is Business Continuity Management. Brilliant!

More importantly as he indicates:

"The danger of undertaking an operational risk assessment before the BIA / RDA activity is that a business case may be built to remediate the biggest operational risk without realising that impact or the consequence is low. This is essentially defining a solution before identifying a problem.

Think about 9/11 where 320 companies FAILED to return to business, 2800 workers DIED and 135,000 workers lost their jobs. By contrast a number of organizations did recover and continued operations. These include:

• Cantor Fitzgerald who lost 658 staff and resumed operations two days later;
• Marsh & McLennan with 3,200 staff over 8 floors;
• Morgan Stanley with 3,500 staff over 17 floors;
• NY Port Authority with 2,000 staff over 23 floors.

New school thinking saved these organizations. No one could possibly have thought of the scenario that two airplanes could cause structural integrity failure of both World Trade Centre skyscrapers resulting in the collapse and complete destruction of the precinct. The businesses that did survive did so because they adopted a resource loss philosophy that included office facilities, technology systems and, of course, staff.

While the scenario of airplanes being used as weapons of mass destruction is not a new concept for planning purposes, (in fact it was hypothesized long before 9/11) the fact is that organizations today have adopted an "All-Hazards" mind set. As a result of the new worldview, "Business Continuity Management" as previously mentioned, has provided a much needed conduit between Corporate Risk and Ops Risk."

What does this "All-Hazards" mentality mean for the cure to unplanned disruptions or untested scenarios? It means that you move to the proactive side of the line and away from the reactive mode that so many organizations are still coping with. The old "It will never happen" to us syndrome.

Global 500 public organizations, small private businesses and non-governmental organizations have true stories and cases that are considered a security risk crisis. Confronting a crisis in one organization will be completely different at another, based upon the type of organization, number of employees, geographic locations and their senior executive process for dealing with a significant disrupting event.

The following question was asked at “Company A” and the top answers were:

What are the top five incidents/events that could cause a significant crisis within your organization?

• Fire or Flood
• Violent weather/damage to facility
• Workplace violence
• Industrial accident
• Terrorism 

"When the question was asked a different way, to a different group at the same company, the results were even more telling:"

What are five incidents/events that have caused your organization significant crisis in the last three years?

• Counterfeit products or major disruption in the supply chain
• Alleged ethics violation of Foreign Corrupt Pracctices Act (FCPA)
• Geopolitical unrest in key overseas markets
• Extended loss of electricity at a manufacturing plant
• Data Breach/intellectual property theft by a nation state

The company is a multinational manufacturer of communications components. Senior executives charged with a “Duty to Care” in todays global enterprise, require new thinking, enhanced skills and relevant solutions to improve crisis leadership.

What is your current readiness factor for the potential of environmental or natural disaster, supply chain disruption, economic espionage, ethics scandal, data breach, employee kidnapping, sabotage, terrorism, workplace violence and other legal risks?

Throughout the enterprise the functions of physical security, information security, legal and financial liability have all become specialized and these same security risk professionals, have become subjected to the potential for a blindside incident.

For example, the HR recruiter is more focused on the security risk of hiring a person with a criminal record of violence and substance abuse problems.

The Chief Security Officer (CSO) is more focused on the physical and information security of facilities and the Chief Operating Officer (COO) may be more focused on daily operations and securing the resilience of the supply chain.

How will you provide your senior executives with the knowledge, skills and strategic solutions that enables global enterprise business resilience for years to come?  Leadership of Security Risk Professionals...

Survival: Experiential Learning to the Rescue...

Change is in the wind.  You have heard this before and the truth is, that this is not anything new.  We have only started to understand however, how the accelerating pace of change, is impacting us.

The number of App's staring at you in the palm of your hand should be one indicator.  How many are you using on a daily basis now?  No longer are we spending a work day logged into an e-mail client, our word processor and maybe the spreadsheet or database application.

The pace of change and the number of places we access our valuable daily information is rapidly taking over our lives.  We have seen the growth of Fortnite now at exponential proportions and little did Potomac Computer Systems, now Epic Games know what was ahead of them upon their founding in 1992.

In the gaming industry they have genre(s) and Fortnite is a survival game:

Survival games are a subgenre of action video games set in a hostile, intense, open-world environment, where players generally begin with minimal equipment and are required to collect resources, craft tools, weapons, and shelter, and survive as long as possible. Many survival games are based on randomly or procedurally generated persistent environments; more-recently created games are often playable online, allowing multiple players to interact in a single persistent world. 

Wake up corporate management.  As you proceed to continue your growth in your particular industry over the next decade, think about the pace of change.  How fast will you be able to pivot, adapt and survive in your persistent environment?

Think about your latest strategic endeavors that you have launched in the past year.  Has the process and goals been achieved, without some level of challenge, disruption or even misdeeds?  The likelihood is, that somewhere along the way, the project, the business or the endgame was at risk.  Perhaps not a total failure, yet not the envisioned outcome.

It is this game of perceived survival and the new pace of change in our lives, that is the greatest Operational Risk before us.  How will we mitigate the risk of such rapid change?

Experiential business learning is a vital way forward.

"Experiential business learning is the process of learning and developing business skills through the medium of shared experience. The main point of difference between this and academic learning is more “real-life” experience for the recipient.[31][32][33]

This may include for example, learning gained from a network of business leaders sharing best practice, or individuals being mentored or coached by a person who has faced similar challenges and issues, or simply listening to an expert or thought leader in current business thinking.

Providers of this type of experiential business learning often include membership organisations who offer product offerings such as peer group learning, professional business networking, expert/speaker sessions, mentoring and/or coaching."
How are you capitalizing on the people in your organization who are part of an external group or other network of like-minded professionals?  It's difficult if you don't even understand who or where your own employees are interacting on a daily basis outside your company.

So what?

Perhaps the place to start is by asking people.  Ask them over coffee in the corporate food court or that new Open Space floor plan with the "Bistro" on every other floor.  What if they told you, that they were a member of an external or virtual organization because they could not find the information or the people with the expertise inside your own organization?

Your goal is to figure out how to capitalize on all of these external groups, organizations and "Experiential Business Learning," that is going on within your own company today.

 How might you capture that passion and the excitement this individual has for the network or "Virtuous Insurgency" they are learning from everyday?

The Operational Risks before you, spans the number of people in your team who are learning somewhere else X the number of other networks they are affiliated with.

Who on your team is gaining new insight somewhere else?  Who are building valuable relationships outside the perimeter.  Who are living in a new unpredictable world of survival...without you even knowing about it.

What could you be learning today?

Higher Purpose: A Mission of Trust...

As you walk into that next meeting with another co-worker or even a colleague for a coffee catch-up, pause and reflect.  Think about how you could (1) make this encounter not only productive and (2) simultaneously enhance the relationship of trust.

All too often we are focused on getting something of value from the meeting.  We are blinded by the purpose of the meeting or have preconceived ideas on how the time together will be of value, or a waste of time.  Now think differently.

A true professional in any business, unit, agency or organization is there to "Build Trust".  The day-to-day or hour-to-hour interactions you have with others is vital.  A true professional in any domain, industry or vocation, can aspire to a higher purpose than the normal roles of a stated job description.

One thing is certain when it comes to meeting with other people and the value or outcomes obtained, trust is a major factor in the future outcomes of the relationship.  Have you ever wondered why certain people you meet, take so long to trust you?  How are you going to accomplish your intended purpose working with this superior or subordinate if they don't trust you?  What about that new client or business partner?

At the most fundamental level, the trust gurus and authors have been writing about a spectrum of trust for eons:

Zero Trust >>>>>Trust Exists >>>>>Implicit Trust

From ground zero of your first encounters with another person, your goal is to move towards a point on the spectrum where "Trust Exists".  Then your goal is to keep moving to the right and towards a place of "Implicit Trust".  This is when you don't even think about it anymore.  How many people do you know where this is the case, even within your own family?

So what?

As an Operational Risk professional, velocity is everything.  Yet you already know that uncontrolled velocity alone can be fatal.  The risk factors associated with business, government or the manufacturing process of a highly engineered electronic component are always present.  Always changing.  Creating new obstacles or new harm.  In our current state, 24x7x365 pervasively connected society, the trust factors are even more important and vital to moving towards "Implicit Trust".

Here are a few examples in the news this past year, where Operational Risk Management (ORM) was a factor:

Samsung Galaxy Note 7

On 2 September 2016, Samsung suspended sales of the Galaxy Note 7 and announced an informal recall, after it was found that a manufacturing defect in the phones' batteries had caused some of them to generate excessive heat, resulting in fires and explosions. A formal U.S. recall was announced on 15 September 2016.

Yahoo

When Yahoo said on Thursday that data from at least 500 million user accounts had been hacked, it wasn't just admitting to a huge failing in data security -- it was admitting to the biggest hack the world has ever seen.

Until Thursday, the previous largest known hack was the 2008 breach that hit almost 360 million MySpace accounts, according to a ranking by the "Have I been pwned" website. Like the Yahoo breach, the hack was only publicly disclosed this year after data was offered on a hacker forum.

National Healthcare Fraud

Attorney General Loretta E. Lynch and Department of Health and Human Services (HHS) Secretary Sylvia Mathews Burwell announced today an unprecedented nationwide sweep led by the Medicare Fraud Strike Force in 36 federal districts, resulting in criminal and civil charges against 301 individuals, including 61 doctors, nurses and other licensed medical professionals, for their alleged participation in health care fraud schemes involving approximately $900 million in false billings.

National Security Agency

A federal contractor suspected in the leak of powerful National Security Agency hacking tools has been arrested and charged with stealing classified information from the U.S. government, according to court records and U.S. officials familiar with the case.

In each one of these few example cases, relationships between people started with a meeting encounter.  Over time, the product, service or personal relationship outcomes involved a failure of people, processes, systems or external events.  The core components of Operational Risk Management (ORM).

Raising the level of trust across personal, business or government encounters is only possible, with effective "TrustDecisions".  The Decisions to Trust another person, product or service have several elements.  These are vital for the mission to grow towards "Implicit Trust" and simultaneously with the safety and security necessary to reduce the risk of failure.

The Mission

The mission as a co-founder of a new startup or the CEO of a Global 500 is to ensure the survival of the organization. We all know the failure rate for new companies. Just ask Dun & Bradstreet for the statistics or even your local Venture Capitalist who is celebrating failures these days. So beyond just the survival of the organization, is the imperative to establish a cultural and operating environment where people feel encouraged, creative and unencumbered to fulfill their job requirements and goals.

The Take Away

Operational Risks are inherent in any new or established business endeavor. The earlier the Operational Risk Management (ORM) design begins in the trusted relationship evolution, the more resilient you will ultimately become. The framework of the system-of-systems, the look and feel of the cultural environment and the end state visions are all at stake. Take the time and include the expertise to work on the "TrustDecisions" foundation of your enterprise.

Ensure the survivability of the new products or service solutions, that are so valuable to our economy and our nation.  Embrace Operational Risk Management early in your relationships and allow it's presence while it preserves all that you have worked for and dreamed of...

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...

Scrutiny: The Noun Missing From Your Culture...

The culture of your business or organization will continue to be the root cause of many of your most substantial successes.  Simultaneously, it will be one of the most significant factors in your potential downfall as a company.  Operational Risk Management (ORM) professionals at Wells Fargo and Booz Allen Hamilton, are still dissecting all of the evidence of their respective events.

"Managing Risk to Ensure Intelligence Advantage" is a theme that you may not have heard before, unless you are in the Intelligence Community.  There is one key principle that is worth emphasizing again at this point in time:

Ensure all work is subject to scrutiny.  Require conflict of interest-free peer review for all programs, projects and strategies.

This principle, that shall become pervasive across the culture of the organization, is imperative for several reasons.  The first is, that a culture really is a manifestation of the people and the behaviors that are normal in the organization.  The second is, that the culture shall strive to be a true mosaic of the best thinking and ideas from all the key stakeholders in the enterprise.  Not just one or two people from the top or a singular department.

Putting scrutiny to your work by others to review, is the beginning of new found discovery and transparency insight.  It is the foundation for building a more trusted operating environment, with as little bias as you can possibly have in a culture.  When an organization spins of out of control and becomes the latest case study on an Operational Risk failure event, you must learn from it.  Wells Fargo is just one recent example:

Some consumers may be shying away from Wells Fargo after learning that employees used customers’ information to open sham accounts, according to new figures reported by the bank.

The nation’s largest retail bank beat expectations when it reported more than $5.6 billion in profit for the past three months. But the bank’s earnings report also hinted that the Wells Fargo may have some trouble convincing people to open new accounts in the wake of the scandal.

The number of checking accounts the bank opened in September fell by 25 percent from the same time last year, the company reported Friday. Credit card applications filed during the month dropped by 20 percent from a year ago. And the number of visits customers had with branch bankers also fell by 10 percent from last year.  Washington Post

Whether you are in the international banking and finance business, the defense industrial base or any other set of critical infrastructure institutions that public citizens are counting on, there is no room for a runaway culture.  Consider this definition:

scrutiny

noun, plural scrutinies.

1. a searching examination or investigation; minute inquiry.

2. surveillance; close and continuous watching or guarding.

3. a close and searching look.

You see, the integrity and longevity of your "Trust Decisions" begins with the sharing of relevant information.  Sharing that information with your most trusted and significant partners is the start. The beginning of a dialogue with people in your culture who continuously review the information, the new strategy. This begins the ongoing process. It is now time for others to look at your idea, your strategy, your policy rule, from their perspective. From their knowledge-base. To scrutinize it. To analyze it. To make sense of it for them and those affected by it.

The truth is, you don't have all the understanding and you don't have all of the ecosystem knowledge. You don't have the entire data set, to know if the specific work you have been doing is sound and correct. That the new work you have designed, is culturally and morally acceptable. That the outcomes of your project will produce the results imagined. That the strategy and the work, is the right thing to do at this point in time.

So how do you change? It begins with your next management meeting and beyond. If you are the leader, the manager, the director, the Vice-President or the CxO start now. Ask for scrutiny on your proposed strategy. Gain new insight and understanding. Ask for feedback and changes to make it better. Your power in the culture and its impact is your greatest weakness. Your people will follow you, unless you challenge them to think differently...

Velocity: Integrity of Enterprise Architecture...

Operational Risk Management (ORM) is a discipline that requires several elements to remain effective.  Whether you are working on the deck of the USS Gerald R. Ford (CVN-78) or analyzing data from the corporate Security Operations Center (SOC), your tasks continuously rely on achieving "Trust".

At the core of these decision-making roles, are the processing of rapidly changing data on a split second basis.  The sensors or tools we use day-by-day to assist our quest for greater levels of safety and security, are interdependent minute-by-minute, second-by-second, on the trust of data.  It is imperative at the early stages of process and product development, to effectively test and improve these tools and sensors.  Why?

The "Quality Assurance" phase of any process whether in design, assembly, manufacturing or implementation is based upon a foundation of the quality of trust.  You are reading this now on a device connected to an Internetwork, that has layers of business rules and technology rules that are executed according to industry standards.  The process and the rules have been implemented utilizing QFD and Mean-Time-Between-Failure (MTBF).

There are three vital components of building digital trust in this scenario, for the systems in play and the requirements of end users:

• Authentication
• Data Integrity
• Encryption

All three must be present to provide you with the highest level of assurance, that you are working with a trusted system.

1. How can you be sure that the party you are communicating with, on the other end of the line, is who they claim to be?
2. How can you be sure that the data has not been altered, deleted or changed in transit?
3. How can you be sure that no one can intercept and understand the information being transferred?

All three of these vital components must be present all the time, in order to build integrity and assure your level of trust.  They must be consistent and persistent from end-to-end.  In essence, we are protecting against our adversaries from listening in, tampering with the data and impersonating the destination.

Are you operating any vital component of your business operation, where any of these three components are absent?  Are any of the three not persistent, 100% of the time?  If so, then you are in jeopardy of an erosion of trust with your stakeholders and the increased likelihood of an adverse event.  With your customers, your reputation and probably both.

So what?  How does this translate to your role and the work that you are in charge of, within the operations of your enterprise?  The short answer is, "Velocity and Wealth".  You see, the business rules, technology rules and the legal rules are all connected.  Your job, is to make sure that you understand, your organizations unique "Operational Risk Enterprise Architecture" (OREA).

The velocity at which your business process can execute transactions with integrity, versus your competition or adversary, can mean the difference between victory or defeat.  The margin or profit that you are able to gain by successfully executing millions of your transactions, can mean the difference between prosperity or disadvantage.

Is your organization advertising on Internet web sites?  Is the business model for your company, based upon revenue from advertising?  The trustworthiness of your systems operating with the goal of generating ad revenue, are now at stake.  Informationweek DarkReading explains:

'Xindi' Online Ad Fraud Botnet ExposedBillions of dollars in ad revenue overall could be lost to botnet that exploits 'Amnesia' bug.

Online fraudsters have amassed a botnet of millions of infected machines that exploits a security flaw in a digital advertising technology in order to execute phony online ad impressions.

The so-called Xindi botnet was designed to exploit a known vulnerability called Amnesia (CVE-2015-7266) in implementations of the Open RTB Internet advertising protocol. Unlike most online ad fraud attacks, it doesn't use clickjacking-based click fraud, but rather, generates large numbers of phony ad impressions. According to researchers at Pixalate, which published a report today on the botnet, some 6- to 8 million machines at more than 5,000 enterprises are at risk of being used as bots in Xindi.

Jalal Nasir, CEO of Pixalate, says his firm has spotted traffic from the IP addresses of major Fortune 500 firms, government agencies, and universities, associated with Xindi. While it's unclear if the IP addresses are spoofed or legitimate, he says the IP addresses used by Xindi are owned by those organizations, which include Citigroup; General Motors; Lowe's; Marriott; Wells Fargo; California State University's Office of the Chancellor; Columbia University; the University of Maryland; and many other big-name corporations and colleges. 

The Quality Assurance of the Online Advertising enterprise is in jeopardy.  The trustworthiness of e-commerce and the digital business models executing the rules for producing revenue, are now in question.  How effective is your enterprise in understanding the true business problem and then solving it?

"Bob Liodice, president and CEO of the ANA, whose membership includes more than 640 companies with 10,000 different brands that spend more than $250 billion in marketing and advertising, says the more than $6 billion of losses to advertisers is actually on the low end of estimates. He estimates the number may be closer to $10 billion."

"Achieving Digital Trust" and the "Trust Decisions" to create wealth require that we begin with a sound architecture.  It continues with the widely adopted information governance processes and three factors.  Authentication, Data Integrity and Encryption.  The "Advertising Industry" is not the only business segment at risk.  The next time you open that piece of mail with a new credit card that utilizes the EMV chip, you will begin to understand the true business problem.

You are in control of the velocity of the process of change with your current state. The opportunity for the future state of "Trust Decisions" is now coming into the light.  In your country, industry, company and DevOps team.

Decision Advantage: Operational Risk Strategic Vision...

When the Board of Directors asks for a report on the Operational Risk Strategic Vision for the enterprise, will you have it ready?  The execution of strategy with the discipline of Operational Risk Management (ORM), requires a look "Over-the-Horizon" (OTH).  Why?

You have to realize the pace at which technologies are advancing.  You have to realize how your competitors are creating a decision advantage.  How will you apply the use of new data science, advanced hardware and software capabilities to augment your Human Capital, to replace Human Cognition?  So what are some of the categories that you should be researching, testing and implementing?   New strategic systems to secure, protect and improve the situational awareness or resilience of your organization?

Many of the places you will need to address, have to do with enhanced processing and management of data, from disparate places:

• Coping with Scale - Advanced Analytics
• Very Large Dataset - 4D Visualization
• Data Standards and Governance - Sensor Priority Processing, Optimized Data Movement

Bringing tools to the data, data trust and provenance tracking, are a subset of governance.  Machine translation and wire speed language recognition, are subsets of a Multi-lingual textual data processing platform.

So what?  Why is all of this innovation required in the modern Operational Risk domain and why is it so important?  The simple answer is, international competition, from your adversaries.  Dynamic, Smart Metadata, metadata relationships and data that finds the analyst, are challenging areas today.  Natural language processing techniques and wire speed data tagging are vital.

"Data Mining will bring us "Cyber Situational Awareness", "Human-Assisted Machine Learning" and "Pattern of Life modeling".  Decision and intelligence advantage, is the key to many of these strategic initiatives."

Again, from a business perspective, so what?  If your organization is in the Information Technology Sector, then of course you understand that the competition is tough and your new advanced VM and/or shiny systems "Box" does need to stand out, with it's unique features and differentiators in the marketplace.  It must have some value-proposition to the customers, that few or no one else can provide at the moment.  Otherwise, why would you spend the money on educating the market, writing a check to Gartner, advertising, sales and business development?  Right?

The Board of Directors today might just understand the concept of "Decision Advantage."  What if you went to the next meeting of the outside directors and provided a narrative and presentation on "Decision Advantage"?  You want them to authorize the substantial budget for your own Operational Risk R&D.  You are asking them to invest in the future risk mitigation of the enterprise, that they have a fiduciary responsibility to safeguard for the shareholders.

You see, you are way behind the international competition.  When you view this visual of the current state-of-play going on this hour, this minute and this second, you really don't have the time to waste on authorizing more resources, to address many of the areas previously discussed here.  The future of your enterprise and the livelihood of your country is at stake.

The Research & Development (R&D) budgets for Operational Risk Strategy execution are tremendous.  Add it all up.  The question is, how effective is it for the enterprise to spend risk management and mitigation funds in each individual department of IT, HR, Marketing, Sales, Finance and Facilities.  Without a complete understanding and vision of how the spectrum of risks, threats and mitigations, are all interconnected and what tools, processes or technology are actually interdependent.

When something such as Enterprise Risk Management or even National Security is so mutually dependent,  (depending on each other) you have to ask the Board of Directors to pause, and to require the Operational Risk Strategic Vision.  Once completed, you will see what new technologies to invest in for your total budget of Research & Development funds, and where to spend it.

Perhaps the most important reason for this vision, is also to ensure your "Intelligence Advantage"...

Trust Decisions: The Risk of a Digital Supply Chain...

Are you a business that is operating internationally?  What components of Operational Risk Management (ORM) currently intersect with your international business operations?  The safety and security of your employees who travel into countries with unstable political elements are no doubt of immediate concern.  There may even be a heightened sensitivity with whom your international business executives are meeting with and the tremendous U.S. rule-base associated with OFAC, as one example.

Fortune 500 organizations are all too familiar with these concerns, as major players in international business. The Chief Security Officers (CSO) and other key executives charged with the safety, security and integrity of employees, are focused on those who are traveling and meeting across the globe.  This is considered ORM 101.  This facet of ORM is quite mature and familiar to the Board of Directors who are charged with the Enterprise Risk Management (ERM) of the company.

What is growing more pervasive and continues to plague organizations doing business internationally is the risk of a Digital Supply Chain.  Trusted information and the confidentiality, integrity and assurance of data.  The "Genie" is out of the bottle and even the most mature and risk adverse global organizations, are continuously barraged by sudden incidents that interface with privacy and security of information.

Here is a recent example:

After a public comment period, the Federal Trade Commission has approved final orders that settle charges against 14 companies for falsely claiming to participate in the international privacy framework known as the U.S.-EU Safe Harbor. Three of the companies were also charged with similar violations related to the U.S.-Swiss Safe Harbor.
The FTC previously announced the settlements in January, February and May of 2014 with the following companies: 

• American Apparel
• Apperian, Inc.
• Atlanta Falcons Football Club, LLC
• Baker Tilly Virchow Krause, LLP
• BitTorrent, Inc.
• Charles River Laboratories International, Inc.
• DataMotion, Inc.
• DDC Laboratories, Inc.
• Fantage, Inc.
• Level 3 Communications, LLC
• PDB Sports, Ltd., d/b/a Denver Broncos Football Club
• Reynolds Consumer Products Inc.
• Receivable Management Services Corporation
• Tennessee Football, Inc

Under the settlements, the companies are prohibited from misrepresenting the extent to which they participate in any privacy or data security program sponsored by the government or any other self-regulatory or standard-setting organization.
Consumers who want to know whether a U.S. company is a participant in the U.S-EU or U.S.-Swiss Safe Harbor program may visit http://export.gov/safeharbor to see if the company holds a current self-certification.

Under the settlements, the companies are prohibited from misrepresenting the extent to which they participate in any privacy or data security program sponsored by the government or any other self-regulatory or standard-setting organization.

So what is the real underlying issue here?  It is about "Trust Decisions".

These organizations were representing themselves as compliant with a U.S.-EU framework designed and established to protect their constituents, under the jurisdiction of the Federal Trade Commission (FTC).  The decisions to trust these organizations by an individual or business, regarding the perception that they are in compliance with a framework for privacy and security, is what is true.

How often have you ever made a "Trust Decision," based upon your knowledge that a business is displaying an official seal, mark or a sign that your information is safe and secure?  There are dozens of high profile companies operating across the globe that are in the business of selling "Trust".  Symantec, TRUSTe and GeoTrust to name a few.  The reason that a business buys one of these trusted seals or marks is because it wants to increase it's perception of trust, to the consumer or business that it is engaged with to transact business.

The business wants to display that they are compliant with the particular laws or rules associated with their industry or country.  It wants to create a sense of business assurance or peace of mind for the buyer of their products or services.  When you use one of these seals to assist in making an affirmative "Trust Decision" based upon the display of one of these badges, marks, signs or even special symbols or colors; the consumer still assumes risk of the unknown risks.  So what?

So how many consumers on a daily basis do you think visit this web site to get their free annual credit report? Green Padlock https://www.annualcreditreport.com/index.action

This is the official web site advocated by the U.S. Federal Trade Commission (FTC) for consumers to get a free annual credit report in compliance with Fair Credit Reporting Act (FCRA).  When you visit this site, you see that the URL displays a green padlock and the https: designating that the site is using secure protocols to transmit your Personal Identifiable Information (PII).  Or is it?

When you test the Annual Credit Report web site with a SSL security test service, run online by Qualys SSL Labs, https://www.ssllabs.com/ssltest/ this is their rating, on the security of Annual Credit Report.com as of 6/28/14.

Overall Rating

F

0

20

40

60

80

100

Certificate

100

Protocol Support

0

Key Exchange

80

Cipher Strength

90

Documentation: SSL/TLS Deployment Best Practices, SSL Server Rating Guide, and OpenSSL Cookbook.

This server supports SSL 2, which is obsolete and insecure. Grade set to F.

Experimental: This server is vulnerable to the OpenSSL CCS vulnerability (CVE-2014-0224), but probably not exploitable.

The server supports only older protocols, but not the current best TLS 1.2. Grade capped to B.

The server does not support Forward Secrecy with the reference browsers.  MORE INFO »

This server is not vulnerable to the Heartbleed attack.

Q: What information do I need to provide to get my free report? 

A: You need to provide your name, address, Social Security number, and date of birth. If you have moved in the last two years, you may have to provide your previous address. To maintain the security of your file, each nationwide credit reporting company may ask you for some information that only you would know, like the amount of your monthly mortgage payment. Each company may ask you for different information because the information each has in your file may come from different sources.

On a daily basis, humans are subjected to signs, marks, badges and other indicators that help them make more informed affirmative "Trust Decisions".  Whether it is the "Green Light" at the local intersection or the "Green Padlock" on the web site where we are being asked to give up our Personal Identifiable Information (PII).  The regulatory and private entities that are tasked to ensure that the signs, marks, badges and even colors are in compliance, must also look to their own level of trust of their Digital Supply Chain.

This is just one glaring example of why "Trust Decisions" are so vital to online global e-commerce.  It is also a wake-up call for any organization that is advocating trust by using a digital third party that the consumer relies on every day.  However, the FTC and other government agencies rely on private sector companies to assist them in outsourced services such as hosting Annual Credit Report. com.  The site is hosted by:

IP Location

- Massachusetts - Cambridge - Akamai Technologies Inc.

How confident are you, that your organizations digital supply chain is ensuring safe and secure "Trust Decisions" for your customers?

RSA Conference 2014: The Aftermath and the Consequences...

The 2014 RSA Conference USA is complete and yet what have we learned?  Operational Risk Management (ORM) is still top of mind from the "Board Room" to the back office.  The mitigation strategies are permeating the 3rd Party supply chain, as management realizes that operational risks really do exist with partners and suppliers.  By now the RSA attendees are reviewing their notes, connecting with people on LinkedIn and sorting the stack of business cards on their desk.  Now what.

• Have some of the largest retailers been the victims of massive data breach hacks?  Yes.  Have those attendees of the RSA Conference who downloaded the mobile app been exposed to a potential data leak of their information.  Yes.
• Meanwhile, Operational Risks exist far beyond Moscone and San Francisco.  Have financial institutions been fined by government regulators over alleged violations of the sale of mortgage securities, that lead to the 2008 financial crash?  Yes.  
• Have the age old competitive intelligence tactics evolved into full blown "Industrial Espionage" funded and supported by nation states?  Yes.
• Has the polar vortex created a vast economic risk for millions of businesses due to adverse weather? Yes.

And the Operational Risks to your organization will continue, that is for certain.  How after a week of RSA can you return to your enterprise and know where to begin?  What to change.  What new initiative to begin.  What new vulnerability to remediate.  Don't worry, the list will not be getting any shorter.  The priorities however may be changing.

So maybe it is time for a new "Consequence Assessment."  Here are the key variables for the rows of your matrix:

1. Loss of life:  Likely fatality count.
2. Economic damage:  Estimated costs of the attack or hazard.
3. Psychological impact:  Considerations of change in population behavior toward social functions.

Now, the consequence levels become your columns of the matrix:

• 0 - None or Negligible
• 1 - Minor
• 2 - Moderate
• 3 - Significant
• 4 - Catastrophic or Severe

In order to make the consequence assessment relevant and applicable to your business size, industry sector and geographic location, you now need to define each of the cells of the matrix.  So as an example, if we go to the matrix cell of Economic Damage / Moderate (2), what is your definition?  In the range of $1 billion to $10 billion.

If you are JPMorgan Chase then this may be the case for a consequence of legal liabilities, due to adverse litigation by the U.S. government in the Madoff case:

JPMorgan Chase has been fined more than $2 billion for violations of the Bank Secrecy Act tied to failure to report suspicious activity related to Bernie Madoff's decades-long, multi-billion dollar Ponzi scheme. Madoff was sentenced in 2009 to 150 years in prison for his deception. 

The fines against Chase were the result of three settlements. A settlement with the U.S. Attorney's Office for the Southern District of New York included a $1.7 billion penalty; a separate settlement with the Office of the Comptroller of the Currency included a $350 million penalty. Additionally, the Treasury Department's Financial Crimes Enforcement Network fined Chase $461 million for BSA-related violations. But FinCEN determined that its fine was satisfied by Chase's payment to the U.S. Attorney of New York.

If you are a mid-level business enterprise in the software industry that develops an "App" for consumers to file their income taxes online, then the metrics will be different for a moderate consequence of "Economic Damage." Your matrix will be entirely different and fine tuned to what is relevant in your industry sector.

The Loss of Life category will be an interesting exercise.  None or Negligible will be zero fatalities. Yet how do you define the difference between minor (1) and moderate (2).

The Psychological Impact category will span:

0 - None or Negligible = No major change in population behavior; no effects on social functioning
to
4 - Catastrophic or Severe = Loss of belief in government and institutions; widespread disregard for official instructions; widespread looting and civil unrest

Once you have designed your particular matrix for your size and type of business, the real work begins. You must now begin developing the "Use Cases."  What are the scenarios that you will apply to the exercise that will take place next with the effected stakeholders?

In a generic fashion, you will design specific and customized scenarios that address the major business revenue components of your particular enterprise.  You are imagining an attack or hazard outcome, that impacts that component of your business.  Such as these typical cases:

• Earthquake destroys data centers
• Tsunami overcomes nuclear reactors
• Data hack exposes millions of customers PII
• Infectious disease outbreak across work force
• Government prosecutes for violations of regulatory laws
• Employee sues company for management harassment
• New Customer Order Management system launch encounters substantial bugs/failures

After you have cleaned off your desk from a week away at RSA, the work really begins.  Start your new "Consequence Assessment" soon.  Gather senior executives for an off-site for two days to review the new scenarios you have designed.  Get their independent feedback and perception of the variables of your matrix.  Ask your Board of Directors for the resources and budgets to address the outcomes and insights from the exercise.

“ Man must be arched and buttressed from within, else the temple will crumble to dust. ”
— Marcus Aurelius Antoninius

Black Swan: Strategy Execution for the "Outlier"...

The Black Swan is a surprise event and the idea that a catastrophe can strike without warning. What does your organization plan for? The low consequence high frequency incident or the high consequence low frequency incident? The ratio can tell you what your "Resilience" factor is to Operational Risk loss events. Key Performance Indicators (KPI's) can give you some forward looking view into the risk portfolio yet what about the resilience to the Black Swan?

A black swan is a highly improbable event with three principal characteristics: It is unpredictable; it carries a massive impact; and, after the fact, we concoct an explanation that makes it appear less random, and more predictable, than it was. The astonishing success of Google was a black swan; so was 9/11. For Nassim Nicholas Taleb, black swans underlie almost everything about our world, from the rise of religions to events in our own personal lives.

Why do we not acknowledge the phenomenon of black swans until after they occur? Part of the answer, according to Taleb, is that humans are hardwired to learn specifics when they should be focused on generalities. We concentrate on things we already know and time and time again fail to take into consideration what we don’t know. We are, therefore, unable to truly estimate opportunities, too vulnerable to the impulse to simplify, narrate, and categorize, and not open enough to rewarding those who can imagine the “impossible.”

Your organization is no doubt spending time on the Operational Risk Management (ORM) events that consistently are in the high frequency "In Your Face" category. In a highly regulated industry sector such as finance, health care or energy the oversight mechanisms require a continuous analysis of risk based upon the criticality of these sectors to the overall resilience of the economy. Yet it is the "Outlier" incident that comes at the most unexpected time that is the real threat and the incident catalyst, that could be your "Black Swan". You never know when it is going to be coming, so you must plan, prepare and imagine that someday it will happen.

Enabling Global Operational Risk Management (ORM) requires thinking beyond models and outside the box analysis of the "Resilience Factor," should an outlier impact the organization, the state or the country. The resources, personnel and systems focused on these areas of risk are small today. But not for long. Just ask those people who had been working 24/7 since the "Fukushima" or "Lehman Brothers" crisis. Or more importantly, the plaintiff lawyers preparing their briefs for the inevitable aftermath of litigation over, who knew what, when.

One prediction into the future could be that litigation will follow all "Black Swan" incidents. If you are in a highly vulnerable industry sector because it's part of the critical infrastructure of the global grid, then you already know you are in the middle of the target zone. What is amazing to many in the after-action reporting is how much we continue to under estimate the magnitude of a lack of planning and resources devoted to these low frequency high consequence events.  Enter Target Corporation:

Is Target to Blame for Its Data Breach? Let the Lawsuits Begin 

By Joshua Brustein December 26, 2013 

The lawsuits started almost immediately after Target’s (TGT) admission that hackers had stolen information related to the credit-card accounts of 40 million shoppers. At least 11 customers are now pursuing class-action suits against the retailer, claiming it was negligent in protecting their data. 

Losing control of sensitive customer data is a fact of life for American companies. They’re collecting more of it, and they are often outgunned by hackers, who are highly motivated to get at it. It’s not even clear how much legal responsibility they have to protect it. “There is limited judicial guidance on what constitutes negligence in the cybersecurity area,” says Craig Newman, a partner at Richard Kibbe & Orbe who follows legal issues related to security.

Deepwater Energy Risk: Protecting Business Performance...

The Operational Risk professionals are applying the use of effective software tools in the Energy Sector. After all, the core disciplines of OPS Risk lie with safety and security and the current reality of deepwater drilling beyond 8,000 feet of ocean is here now.

There are few organizations that understand the risks associated with drilling and capturing precious natural resources under these demanding conditions more than the Marine Well Containment Company, (MWCC) based in Houston, TX USA. This new and quickly expanding consortium of ten energy exploration companies have banded together to address the "All Hazards" requirements as a result of the Deepwater Horizon catastrophe. Never before, have so few private sector energy companies converged to take on readiness, and managing operational risks with so much capital and mission focus.

Simultaneously, others close to the maritime risk management industry such as Lloyds Register Group have embarked on the bold mission to assist organizations like MWCC in the future quest for our insatiable thirst for energy. They too, understand the necessity for mitigation and prevention of another Macondo incident where a blowout preventer failed:

ModuSpec BV and Scandpower AS, members of the Lloyd’s Register Group, are developing a new tool with origins from the nuclear power industry that may prove highly useful to subsea engineers, offshore drilling managers, and regulators.

Operational Risk Management (ORM) is the process that evaluates the likelihood of a casualty occurring while comparing it to its associated consequences. BOP Monitor, a new tool under development by Scandpower applies ORM principles in a highly specific manner to one of the most important, and highly complex systems on board a drilling rig, the blow out preventer.

Last year’s Deepwater Horizon disaster cast an enormous spotlight on blow out preventer technology because the one sitting atop the Macondo Well failed to accomplish its mission, and millions of gallons of oil spilled into the sea. A one-in-a-million chance? Perhaps. In the decades since subsea blowout preventers have been used, countless have worked as-designed mitigating the disastrous consequences we all saw last summer. As the industry moves toward the arctic however, failure of these systems is absolutely not an option and risk management is of utmost importance to operators and coastal states.

The combination of MWCC and Lloyds Register to address the challenges ahead in deepwater drilling is a natural, in the Gulf of Mexico and beyond. Perhaps even more so, is the division Lloyds Register Quality Assurance (LRQA) who are experts in Business Assurance and protecting business performance. They are the people who go beyond the words in a regulation or international standard to apply a holistic and multi-faceted approach to your business achieving higher performance. MWCC will need that business assurance and performance management going forward if they are to work in concert with the United States regulatory agencies such as Bureau of Ocean Energy Management, Regulation Enforcement (BOEMRE).

All of the plans and processes will not be enough for those operators who are drilling in deepwater. This is exactly why exercising and testing those people, plans and processes will be a verified requirement:

Tracking and verification of exercise requirements for spill responders is an BOEMRE function that ensures that all responders have the required experience and expertise to respond to an offshore facility spill. Operators are required to conduct annual Spill Management Team “table top” exercises. These drills are required to test the Spill Management Team’s organization, communication, and decision-making in managing a response. The operator is also required to conduct an annual deployment exercise of the equipment staged at onshore locations identified in their plan. Each type of equipment staged onshore must be deployed and operated every 3 years. The operator is required to exercise their entire response plan every 3 years. Another exercise that tests the ability of the operator to communicate information in a timely manner is the required annual notification exercise required for every facility that is manned on a 24-hour basis. The operator must notify BOEMRE at least 30 days prior to these drills occurring. This notice provides an opportunity for BOEMRE to witness the exercise or to request changes in the frequency or location of the exercise, equipment to be deployed and operated, or deployment procedures or strategies. BOEMRE can also evaluate the results of these exercises and advise the owner/operator of any needed changes in response equipment, procedures or strategies.

The operational risk readiness factor is at the core of all of the exploration companies as it pertains to the Safety and Environmental Management Systems (SEMS). All of the MWCC consortium companies will already be well versed in "Operating Integrity Management Systems" yet, as all ten come together to work on a combined solution, a baseline of standards and guidelines will be paramount to their inevitable success.

Remember, all of this focus is on the prevention of another "All Hazards" incident. Much of which stems from the lack of confidence in equipment or procedures being replicated by humans, at just the right moment and if an emergency condition presents itself. That is why testing and exercising the multi-facets of the entire spectrum of threats is necessary, beyond those related just to the equipment integrity or failure:

More specifically, the goal of an offshore energy exploration and production safety regime must ensure that:

• Life, environment and property are protected in an effective, consistent, transparent and predictable way; both for those directly affected and involved in offshore operations.

• Risks are properly evaluated and all prevention and mitigation measures are identified;

• Control measures are implemented and maintained by all parties in accordance with mandatory risk assessments as well as what is prescribed by regulation;

• Conditions of safeguards, facilities, procedures, personnel and organizations are continuously monitored throughout the lifetime for proper functioning and compliance with all regulatory requirements and to assure that risks do not increase;

• Technical innovation and efficiency improvements can be implemented safely and responsibly.

And then there is the kind of risk, that many are still not thinking about in the Gulf of Mexico. The risk that exists in other offshore drilling regions of the globe today:

Gunmen attack ExxonMobil supply vessel kidnapping one, wounding another

September 30, 2011

By Dorothy Davis

Industry sources have reported that gunmen have attacked a ship supplying an ExxonMobil (NYSE:XOM) oil rig off the coast of Nigeria, kidnapping one crew member and injuring another.

Nigel Cookey-Gam, a spokesman for the ExxonMobil subsidiary Mobil Producing Nigeria (MPN) told The Associated Press that the kidnapping happened early Friday (09/30) off the coast of Nigeria's Akwa Ibom state.

"Mobil Producing Nigeria, operator of the joint venture with the Nigerian National Petroleum Corporation, confirms that in the early hours of Friday, some armed men attacked a supply vessel near one of our platforms, offshore Akwa Ibom State," Cookey-Gam offered in the official statement. “The incident has been reported to security and relevant government agencies”

According to ExxonMobil, MPN is the second largest oil producer in Nigeria having begun production of crude oil in February 1970 from the Idoho field, located off the coast of Akwa Ibom State.

Violence and extortion driven kidnappings have been prevalent in Nigeria’s oil and gas -rich southern delta since 2006 when militants kicked-off a series of attacks targeting oil companies. In 2009 a government amnesty program offering Niger Delta rebels an unconditional pardon and cash payments brought about a short period of reprieve, but has not been successful in quelling the targeted violence in mostly impoverished the region.

Deepwater Energy Risk in the next decade will be expanding off the coast of Brazil and in the Arctic:

In a warming and changing Arctic, China is stepping up its activities in the Arctic Ocean Basin. While China’s interests and policy objectives in the Arctic Ocean Basin remain unclear, Beijing is increasingly active and vocal on the international stage on issues that concern the region. To that end, China is actively seeking to develop relationships with Arctic states and participate in Arctic multilateral organizations such as the Arctic Council. The region includes a rich basket of natural resources: The U.S. Geological Survey estimates that 25 percent of the world’s undiscovered hydrocarbon resources are found in the Arctic region along with 9 percent of the world's coal along with other economically critical minerals. There is presently scarce open source information on China's Arctic policy and very few public pronouncements on the Arctic by Chinese officials.