With the release this week of President Obama’s executive order on Improving Critical Infrastructure Cybersecurity and the accompanying detail in Presidential Policy Directive 21, lots of people have commented on the implications. Jack Whitsitt appears to have some solid commentary coming.
However, a piece by Richard Stiennon on Forbes caught my eye, not because of the information in it, but because of the FUD it contains.
First, he attacks the concept of risk management:
But risk management does not work in unpredictable environments. Risk management is the framework that most banks, hedge funds and trading desks use when addressing financial risks like those present in the real estate, commodities or derivatives markets. We know how well that worked. Management consultants and bureaucrats love risk management. It foists responsibility away from individuals and onto a process.
Here’s a hint: yes, it does work in “unpredictable environments”, when performed properly by responsible managers. (Whether the DHS can provide this is a separate question, and one on which I suspect Stiennon and I would likely agree.) This stems from the concept of uncertainty from statistics and related sciences. And simply saying ‘risk management is bad because bankers’ (obviously a paraphrase) isn’t wry sniping, as Stiennon later commented, but FUD.
How will an uber-map of critical infrastructure be kept out of the hands of the very threat actors that are targeting these systems? PPD 21 will, in effect, create yet another critical information asset that will end up at the top of the list of critical vulnerable assets.
I don’t know what this means. By this logic, we shouldn’t ever create an inventory of our assets. Does he not keep financial records? Would he have counseled the government during the Cold War not to keep track of nuclear launch sites? Yes, of course the documents detailing these things require appropriate controls, but to conclude that the government should not analyze and sort critical infrastructure because adversaries would love to have this information doesn’t make any sense.
Centralized information collection and dissemination is a natural requirement for risk management. It is akin to the economic data collection and analysis that command economies resort to in place of free markets.
Yes, he basically just said that centralized databases are communism. I have nothing to add here because it speaks for itself.
Stiennon concludes this way:
PPD 21 makes previous unfunded mandates seem simple by comparison. Its breath and scope is a giant overlay on top of the existing system of Federal agencies that, if executed as directed, will turn what was a of collection of connected puddles of government regulatory bodies into a single giant quagmire. It is a top down solution that expresses the frustration of good intentions to “do something.” Even if all the hurdles of implementing an over arching risk management framework were overcome there would still be the errant tree branch or targeted malware that could shut down the power grid.
Yes, bad things will still happen. That is not an excuse to do nothing. Stiennon proposes no alternatives here, other than the implied idea of leaving a “collection of connected puddles of government regulatory bodies” as they are. The current system doesn’t work that well, and whereas I’m not convinced right now that PDD 21 will actually do anything, I also believe that we as professionals and citizens should find ways to improve things rather than simply shoot down anything that isn’t perfect ‘because reasons’.








Comments on Comment Crew
Everyone paying any attention to security this week noted Mandiant’s report on the Comment Crew. If you haven’t, go read it first. I’ll wait.
Instead, this means the adversary can’t dictate the pace and terms of the conflict, whether or not they completely retool. By driving up the cost to the attacker over time, you start to make headway. That works both ways, of course, and at the moment that balance leans decidedly in their favor. Releasing the IOCs will also allow defenders to discover additional compromises. Remember that opponents make mistakes, and so we can capitalize on the opportunity for ongoing intel gathering as they transition to new infrastructure (assuming they even bother).
Sharing information has more than just tactical value. In my view (obviously not one shared by Congress), this points out that we don’t need the government to get in the way with CISPA or other information-sharing that stays behind walls of overclassification or possibly creates additional privacy and civil rights issues. We can do this the right way and improve things. Partisan politics lies way outside the scope of this blog, but I certainly see this as “we’re from the government and we’re here to help” territory.
[1]: As usual, these represent my opinions only. And that’s only good for today anyway because I may change my mind as new facts come to light or I think about topics more thoroughly.
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Tagged Advanced Persistent Threat, China, CISPA, Comment Crew, Cybersecurity, Indicators of Compromise, Jeffrey Carr, Krypt3ia, Mandiant, Threat Intelligence