Brewing Cybersecurity Insights

Month: June 2023

The Rising Stakes for Cybersecurity Accountability

An Analysis of the SEC notice to SolarWinds CISO and CFO

The Rising Stakes for Cybersecurity Accountability
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The cybersecurity landscape is witnessing an unprecedented shift. The recent move by the U.S. Securities and Exchange Commission (SEC) to issue Wells Notices to the CFO and CISO of SolarWinds is a bellwether of this change.

A Wells Notice is a communication from the SEC indicating that it has made a preliminary decision to recommend enforcement action against the recipient, although it is not a formal charge of wrongdoing or a final determination of violation​.

The SEC’s decision suggests a new emphasis on individual accountability within organizations for cybersecurity management and incident disclosure. However, this development also shines a light on a complex challenge: the multifaceted and collective nature of cybersecurity.

Why is this significant?

Firstly, it demonstrates an increased scrutiny of companies’ responses to cyberattacks. In this case, the SEC alleges that SolarWinds violated certain provisions of U.S. federal securities laws in its cybersecurity disclosures, public statements, and internal controls following the cyberattack in 2020, which affected thousands of customers globally​.

Secondly, this is unusual because a Wells Notice is typically sent to a company itself, not individuals within the company. Wells Notice are usually reserved for CEOs or CFOs in cases of Ponzi schemes, accounting fraud, or market manipulation.

This development suggests that the SEC might be moving towards holding individuals, particularly CISOs, more accountable for managing cybersecurity and disclosing cyber incidents. One possible violation that a CISO might commit is a failure to disclose material information, such as failing to disclose the gravity of an incident or failing to do so in a timely manner. This is a trend confirmed by the the previous conviction of Uber’s CISO and his sentence.

However, some cybersecurity professionals argue that attributing blame solely to the CISO or CFO might not always be fair or accurate, because…

… Cybersecurity management typically involves various stakeholders

In today’s digitized world, a Chief Information Security Officer (CISO) plays an essential role far beyond just implementing and managing security measures. The CISO’s duty also involves making other CXOs accountable for their part in cybersecurity. This includes ensuring that for instance that:

  • HR make sure that the resources completes the necessary security training,
  • Risk Management keeps cyber risks within defined thresholds,
  • Finance aligns the security budget with mitigation strategies (that in turn are based on the organization strategies and risks),
  • IT oversees the secure development and maintenance of applications.

But what happens when risk acceptance is chosen as the path forward?

If a CXO or the CEO decides to accept a risk, they should be accountable for that decision. It is crucial that such risk acceptance is well-documented and tracked.

I assume that in SolarWind and Uber incidents top management might have wanted to take a risk acceptance decision but didn’t want it to be documented (I assume because I personally saw this happening).

Conversely, a too accommodating CISO who fails to enforce necessary security measures might find themselves, and put their organization, in the firing line.

The Challenge of Execution

An important yet often overlooked aspect of cybersecurity is the actual execution of security measures. Even when a CISO or security leader gives orders for security actions, the implementation may not always follow through, especially if the person responsible isn’t part of the cybersecurity team. These orders may go unfulfilled due to conflicting priorities, and performance objectives that do not include security are not helping.

This state of affairs points to the need for organizations to align their objectives across departments and ensure that security is a shared priority. Without this alignment, the cybersecurity of the organization remains fractured and vulnerable.

No matter how robust the cybersecurity measures are, it’s impossible to prevent all cyberattacks. I think that the sophistication of the SolarWind attack is a great example of that.

Risk mitigation doesn’t aim for 100% security—residual risks are inevitable. Therefore, managing risks effectively within acceptable thresholds becomes the primary goal. This goal underlines the need for comprehensive risk management strategies that involve all stakeholders in an organization. Let’s not forget that security is just one of many goals of an organization, which also has to do business, and too much security might make the company non-competitive.

The Road Ahead

The SEC’s move towards increased individual accountability in cybersecurity could have profound implications for how organizations manage cybersecurity risks. However, it’s essential for organizations (and governments) to remember that cybersecurity is a collective responsibility. It requires coordinated efforts across departments and roles.

This reality makes the role of the CISO even more critical. They need to bridge the gap between different stakeholders and ensure a holistic approach to cybersecurity. While the SEC’s move might bring with it new challenges and pressures, it also presents an opportunity: to reaffirm the collective responsibility of cybersecurity, reinforcing that it is a task that falls on everyone’s shoulders within an organization.

A persisting question I have is: what should a CISO do if the CEO orders them not to disclose material information and to avoid documenting this decision?

A CISO who blindly follows such orders risks becoming a Scapegoat Officer, serving as a convenient fall guy in the aftermath of a cyber incident rather than actively improving the security posture of their organization. And he/she might not be inclined to do so if they will be put behind bars for that.

That’s a real pickle, so a second question arise: what a government should do to avoid it?

Maybe foresee a sort of Whistle-blowing channel for CISOs that would guarantee a criminal shield in case of situations like the SolarWind and Uber ones?

Last question, what would happen if the company uses a vCISO or a CISO-as-a-Service?

Navigating this new landscape will be challenging, but with clear communication, well-defined roles, and a shared commitment to security, organizations can rise to the occasion. It’s not just about preventing the next big cyberattack—it’s about fostering a culture of shared responsibility and vigilance that permeates every level of the organization. In this era of increasing cyber threats, there is no other way forward.

The Human Element in Cybersecurity

Moving Beyond Technology

Human Element
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The Human Element – Introduction:

When it comes to cybersecurity, most people tend to think it’s all about technology. But guess what? It’s time to break that misconception. In today’s world, cyber threats the weakest link in the security chain is the human element.

You see, we may have fancy technologies, but there’s no magic bullet (despite what many vendors promise). No matter how much we invest in technology, we can still fall prey to cybercriminals who know just how to exploit our human nature.

The Conti ransomware gang hit the nail on the head last year when they said, “we also need to focus on the human part of our attacks. Our targets invest millions of dollars in security technologies, but they often overlook the human element. We will continue to exploit this weakness to our advantage.”” It’s a wake-up call to understand that in the traditional triad of People, Processes, and Technology, People are (and have been in probably the last 10 years) the center stage in cybersecurity.

So, buckle up and keep reading as we dive into the role of the human factor in cyber attacks.

The Exploitation of Human Vulnerabilities:

Cybercriminals are crafty. They know that humans are easier to manipulate than sophisticated security technologies. They also look for a ROI on their investments, so they will use whatever is the cheaper approach to reach their goal. So, they use psychological tricks like phishing and social engineering to exploit our weaknesses and gain unauthorized access to sensitive information. They send convincing email scams, impersonate trusted entities, and even dig up personal details from social media to trick us into revealing confidential data or compromising system security.

Still think that cybersecurity is all about fancy technology?

You took a look at the latest latest ENISA Threat Landscape. You saw that the top threats include ransomware and malware—definitely techie stuff. But guess who unwittingly lets those threats in? Yep, it’s people.

Now let me tell you, the Ponemon Institute’s Cost of Data Breach report is an eye-opener. In their “Initial attack vectors” section, they highlight the prevalence and cost of human-related attack vectors. Stolen or compromised credentials accounted for 19% of breaches, costing an average of $4.50 million. Phishing, at 16% of breaches, topped the list as the costliest initial attack vector, with an average cost of $4.91 million. Business email compromise was another initial vector among cyber attackers.

If you look closely, you’ll notice that every issue, even seemingly technical ones like “Vulnerability in third-party software,” ultimately comes down to human error. After all, who coded the software with the vulnerability or who didn’t define or apply a patching process? That’s right, a human.

Moving Towards a People-Centric Approach:

So, what can we do about it? Well, it’s time for organizations to start adopting a people-centric approach to cybersecurity. My recipe consist in building a “Cyber Culture”! This means understand what are the Cyber behaviors we want to influence, providing comprehensive training programs to raise cybersecurity awareness among employees and promoting a culture of vigilance and responsible behavior. We gotta teach everyday users about common cyber threats, show them how to spot suspicious activities, and encourage good practices like creating strong passwords and keeping software up to date.

But it’s not just about training. Organizations need to share real-world examples of cyber attacks, so people can see the real risks out there. By making everyone feel responsible for cybersecurity, we turn our workforce into a first line of defense against cyber threats.

And here’s a secret: investing in the human factor is not only cheaper, but it’s also way more effective than splurging on fancy technology. I mean, sure, we still need the right tools, but without a strong Cyber Culture, we’re like a castle with a moat but no guards. It just doesn’t work! I will write an article on this topic in the future.

So why isn’t a a People-Centric approach that widespread?

Many people still think that cybersecurity is all about technology. They believe it’s a technical issue that only (nerdy) IT folks (with glasses and a hoodie) can handle. The problem is that cybersecurity specialists often are really technical to start with so they neglect the crucial human elements.

And here’s another kicker: reporting lines within organizations often make things worse. Cybersecurity teams end up aligned with IT departments, who are mainly focused only on technical risks!

I know I’m digressing this is another topic: the need of having an effective, diverse and multidisciplinary Cyber team.

But the truth is, investing in Cyber Culture, in our people, is the key to success. It’s not only more cost-effective, but it’s also more impactful in preventing and mitigating cyber threats. So I think it’s time to break the cycle!

Conclusion:

it’s time we realized that cybersecurity is not just about technology. People play a crucial role, and cybercriminals know it. By adopting a people-centric approach, building a strong Cyber Culture, and empowering employees to be active defenders, organizations can level up their defense against cyber threats.

So, let’s remember that we’re not alone in this fight. It’s not just about fancy tech; it’s about us, the people. Together, we can create a safer digital world. Let’s do this!

Unveiling the Risk Landscape of LLMs

A Comprehensive approach proposal

Risk Landscape of LLM
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Greetings, readers! Welcome back to our exploration of LLM (Large Language Models) security risks. In my previous posts (here and here), I discussed the significance of understanding these risks. That’s why I am excited to share my participation in the creation of the OWASP Top 10 Risk for Large Language Model Applications 😊.

In this article, we will delve into the challenges involved in defining an approach to create the Top 10 LLM security risk list and propose a holistic approach to address them.

The Challenges in Defining a Top 10 LLM Security Risk List

As we embark on this endeavor, we encounter several challenges that need to be overcome:

  1. Evolving Landscape: LLMs are rapidly evolving, with new models (including Open ones with no restrictions) and attack techniques emerging. Keeping the evaluation comprehensive to address emerging risks is challenging but necessary.
  2. Complexity and Interdependencies: LLMs involve various components, including training data, algorithms, infrastructure, and user interactions. Understanding their interdependencies and how risks propagate across them requires careful analysis. Some components are already covered by other Top 10s but they might be so relevant that we might want to include them
  3. Lack of Standardization: Inconsistencies in terminology and definitions related to LLM security risks can lead to inconsistencies in risk assessment and mitigation. Establishing standardized language and frameworks is vital and luckily OWASP will help a lot in this. A couple of examples below:
    • I had a discussion about Intellectual Property Theft. I wrongly assumed that we were speaking only the theft of the LLM model itself, but if we think about it there are other king of IP theft, e.g., the weights are intellectual property, or if some users provide IP to the LLM, the LLM will learn from that and might provide the IP to the next users. As I said I didn’t consider those as for me those were privacy risks… but these are also ML risks
    • We had discussions on how we should call the “hallucination” risk (e.g., is this term humanizing LLMs? Shuldn’t something as “Confabulation” be better? Maybe, but hallucination is already LLM Jargon).
  4. Multidimensional Risks: LLM risks encompass technical, ethical, legal, and societal aspects. Incorporating these perspectives and achieving a holistic understanding is essential.
  5. Risk Prioritization: Determining the significance of each risk and prioritizing them within the Top 10 list is complex. Professional judgment and a thorough assessment are needed.
  6. Balance of Granularity: Striking the right balance between granularity and practicality is crucial. The Top 10 list should be concise, understandable, and actionable, while capturing the breadth and depth of LLM security risks.

Addressing the Challenges with TARA

“Necessity makes the method” used to say one of my old bosses, and to tackle these challenges, I propose adopting a TARA (Threat Analysis and Risk Assessment) method, which involves identifying potential threats, analyzing their likelihood and impact, and evaluating associated risks.

First Step: Threat Modeling

We start conducting a comprehensive threat modelling exercise, defining threat categories specific to LLMs and documenting potential threats within each category.

Below you will find my proposal of threat list, it is not supposed to be 100% correct, just to give an idea on how it would look like. To do so I used OWASP v0.1, Adam AI centered Top 10 some of the Cybersec risks and ML risks from this super insightful article.

Category Threats Sub-Threat 
LLM-specific Prompt Injection Direct Prompt Injection 
Second Order Injection 
Cross-content injections 
Machine Learning Training-Time Attacks Training Data Poisoning 
Byzantine attacks 
Decision-Time Attacks Inference 
Evasion Attacks  ???
Oracle Attacks Extraction 
Inversion 
Membership Inference 
Model Theft Model Theft
Surrogate Model
Statistical Attack Vectors Bias  Drift 
Model Hijacking Attacks Backdoors 
Trojanized models 
User specific Overreliance on LLM-generated ContentHallucination
Bias
Inexplicability
Operational  ???Inadequate AI Alignment
Application /  
Infrastructure 
Insecure development Inadequate Sandboxing 
Improper Error Handling
Insecure deploymentUnauthorized Code Execution 
SSRF Vulnerabilities
Insufficient Access Controls
Personal Data /  
Intellectual Property 
 ???Data Leakage
IP Theft
A proposal of LLM Threats

To be more accurate, this exercise leans more towards threat identification rather than threat modelling.

Please note that I’m not sure where all the sub-threats should be. For instance an ML threat might be the root cause of the existence of some User specific or Personal Data/IP threats…

The following TARA Steps

The next steps would be:

  1. Risk Evaluation: Estimate the likelihood and impact of each identified threat, considering various perspectives and dimensions. Combine these factors to calculate the overall risk level associated with each threat.
  2. Risk Prioritization: Prioritize risks based on their significance and impact, using professional judgment and a holistic perspective to choose the Top 10.
  3. Mitigation Strategies: Define appropriate mitigation and prevention strategies to address the identified risks effectively.

Those phases are all straightforward, the only difficult part could be understanding the impact. What angle do we need to consider? For an organization of course many of those threats could result in data breaches, financial losses, reputational damage, legal implications, etc. What if we consider a non-enterprise end-user? And the LLM owner? E.g., the latter would be the only one that wants to avoid model theft…

Conclusion

LLMs are at the forefront of technological advancement, and understanding their risks is paramount for secure adoption. By adopting a comprehensive approach like TARA, we can identify, assess, and mitigate these risks more effectively.

Collaboration, standardization, and a multidisciplinary perspective are key to success in this endeavor. Let’s work together to create a safer LLM landscape and pave the way for responsible and secure deployment.

Join me for future articles as we explore LLM security risks and discuss practical mitigation strategies.

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