Category Archives: Risk Management

How Do I Know If My Company Needs a Risk Management Policy?

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Risk management policies protect companies against financial losses due to various risks. These risks include legal issues, employee misconduct, environmental hazards, etc.

A company may implement a risk management policy to minimize these risks. However, several questions should be asked before implementing such a policy.

What Are the Risks That Could Lead to Financial Losses?

Many types of risks can lead to financial losses. Some examples include:

• Legal issues

• Employee misconduct

• Environmental hazards

• Product liability

• Cybersecurity threats

• Data breaches

• Other

It is important to understand what type of risk your company faces. For example, if your company sells products online, you will face cyber security risks.

Are There Any Existing Policies?

Before deciding whether or not to adopt a risk management policy, it is important to determine whether any existing policies cover the risks your company faces.

For example, if your company has an insurance policy, then you may not need to implement a separate risk management policy.

However, if your company does not have an insurance policy, then it is necessary to consider implementing a risk management policy.

Is Implementing a New Policy Worth It?

Once you know what type of risks your company faces, it is time to decide whether or not to implement a risk management plan.

Some companies feel that they do not need a risk management plan because their current policies already address their risks. However, this decision should be made carefully.

If your company does not have a formal risk management policy, then it is possible that some of the risks your company faces could go unaddressed. This means that the risks could become more significant problems down the line.

In addition, if your company decides to implement a risk management program, it is crucial to ensure that the program covers all the risks your company faces, including those currently unaddressed.

Do Your Employees Understand What Is Being Done?

When implementing a risk management plan, it is vital to ensure employees understand what is being done.

This includes explaining why the risk management plan was implemented, how the plan works, and what steps must be taken to comply.

The goal here is to ensure that employees understand your company’s risks and how the risk management plan helps mitigate them.

Will the Plan Be Cost-Effective?

Finally, it is essential to evaluate whether or not the risk management plan will be cost-effective.

Cost-effectiveness refers to the amount of money saved compared to the costs incurred.

For example, suppose your company spends $1 million per year to insure its assets. In addition, suppose that the risk management plan saves $500,000 per year. Then, the risk management plan would be considered cost-effective if it saves $500,000 annually.

In this case, the risk management plan is cost-effective because it saves $500,00 annually.

However, if the risk management plan only saves $100,000 per year, then the plan is not cost-effective.

In Conclusion

As discussed above, there are many reasons to implement a risk management strategy.

These strategies can help your company avoid potential financial losses caused by certain risks.

In addition, implementing a risk management plan can make your company more efficient and productive.

 

A Cynefin Risk Management Use Case

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Lately, I have been working on using the Cynefin framework to help a client with supply chain risk management. I’m not going to dig into the specifics here, but I wanted to share a quick workflow that we used during this process that has been very useful for us.

Risk Matrix

First, we built a risk matrix for supply chain risk. Basically, there are a number of these available via the various search engines. We took some of the most common ones and tore them down to commonalities, then built them into our matrix. We turned this into a simple spreadsheet.

Heat Mapping

Next, once we had our risk matrix, we did an exercise where we heat mapped the various risks, scoring them high/medium/low subjectively. This gave us an excellent tool to monitor our situation and communicate it with our stakeholders.

Applying Cynefin

Next, we mapped all of the high risks into the cynefin framework by researching the present state of each, whether best practices were available and relevant, being developed, or still in the experimental stage. This gave us a good idea of which problems we could simply focus on using known techniques and skills against, which ones we needed to take existing decent practices and optimize them, and which problems we needed to experiment with solutions for.

Sharing and Feedback

Overall, the exercise took around an hour to complete once we compiled the basic templates and completed the risk matrix research. For those of you facing complex risk management problems, this workflow might assist. Let me know on social media (@lbhuston) if it provides any help or if you have suggestions and feedback. Thanks for reading!

Preparing for the End of SMS Authentication

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Over the last several years, wealth management/asset management firms have been integrating their systems with banking, trading and other financial platforms. One of the largest challenges wealth management firms face, from a technology standpoint, is managing multi-factor authentication when connecting to the accounts of their clients. In the coming year to eighteen months, this is likely to get even more challenging as SMS-based authentication is phased out. 

Today, many financial web sites, applications and phone apps require the use of SMS one-time security verification codes to be sent via text to the user. This usually happens once the user has entered their login and password to the system, after which it triggers the credential to be sent to their mobile phone number on record. The user then inputs this code into a form on the system and it is verified, and if correct, allows the user to proceed to access the application. This is called two factor authentication/multi-factor authentication (“MFA”) and is one of the most common mechanisms for performing this type of user authorization.

The problem with this mechanism for regulating sign ins to applications is that the method of sending the code is insecure. Attackers have a variety of means of intercepting SMS text messages and thus defeating this type of authentication. Just do some quick Google searches and you’ll find plenty of examples of this attack being successful. You’ll also find regulatory guidance about ending SMS authentication from a variety of sources like NIST and various financial regulators around the world. 

The likely successor to SMS text message authentication is the authenticator app on user mobile devices and smartphones. These authenticator apps reside in encrypted storage on the user’s phone and when prompted, provide a one-time password (“OTP”) just like the code sent in the text message. The difference is, through a variety of cryptographic techniques, once the application is setup and  the settings configured, it doesn’t need to communicate with the financial platform, and thus is significantly more difficult for attackers to compromise. Indeed, they must actually have the user’s device, or at the very least, access to the data that resides on it. This greatly reduces the risk of interception and mis-use of the codes in question, and increases the security of the user’s account with the financial institution.

This presents a significant problem, and opportunity, for wealth management firms. Transitioning their business processes from integrating with SMS-based authentication to authenticator apps can be a challenge on the technical level. Updates to the user interaction processes, for those firms that handle it manually, usually by calling the user and asking for the code, are also going to be needed. It is especially important, for these manual interactions, that some passphrase or the like is used, as banks, trading platforms and other financial institutions will be training their users to NEVER provide an authenticator app secret to anyone over the phone. Attackers leveraging social engineering are going to be the most prevalent form of danger to this authentication model, so wealth management firms must create controls to help assure their clients that they are who they say they are and train them to resist attackers pretending to be the wealth management firm. 

Technical and manual implementations of this form of authentication will prove to be an ongoing challenge for wealth management firms. We are already working with a variety of our clients, helping them update their processes, policies and controls for these changes. If your organization has been traditionally using SMS message authentication with your own clients, there is even more impetus to get moving on changes to your own processes. 

Let us know if we can be of service. You can reach out and have a no stress, no hassle discussion with our team by completing this web form. You can also give us a call anytime at 614-351-1237. We’d love to help! 

Getting ROI with ClawBack, our Data Leak Detection Platform

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So, by now, you have likely heard about MicroSolved’s ClawBack™ data leakage detection engine. We launched it back in October of 2019, and it has been very successful among many of our clients that have in-house development teams. They are using it heavily to identify leaks of source code that could expose their intellectual property or cause a data breach at the application level.

While source code leaks remain a signficant concern, it is really only the beginning of how to take advantage of ClawBack. I’m going to discuss a few additional ways to get extreme return on investment with ClawBack’s capabilities, even if you don’t have in-house developers.

One of the most valuable solutions that you can create with ClawBack is to identify leaked credentials (user names and passwords). Hackers and cyber-criminals love to use stolen passwords for credential-stuffing attacks. ClawBack can give you a heads up when stolen credentials show up on the common pastebin sites or get leaked inadvertantly through a variety of common ways. Knowing about stolen credentials makes sense and gives you a chance to change them before they can be used against you. 

We’ve also talked a lot about sensitive data contained in device configurations. Many potentially sensitive details are often in configuration files that end up getting posted in support forums, as parts of resumes or even in GITHub repositories. A variety of identifiable information is often found in these files and evidence suggests that attackers, hackers and cybercriminals have developed several techniques for exploiting them. Our data leak detection platform specializes in hunting down these leaks, which are often missed by most traditional data loss prevention/data leakage prevention (DLP)/data protection tools. With ClawBack watching for configurations exposures, you’ve got a great return on investment.

But, what about other types of data theft? Many clients have gotten clever with adding watermarks, unique identity theft controls, specific security measures and honing in on techniques to watch for leaked API keys (especially by customers and business partners). These techniques have had high payoffs in finding compromised data and other exposures, often in near real time. Clients use this information to declare security incidents, issue take down orders for data leaks and prevent social engineering attackers from making use of leaked data. It often becomes a key part of their intrusion detection and threat intelligence processes, and can be a key differentiator in being able to track down and avoid suspicious activity.

ClawBack is a powerful SaaS Platform to help organizations reduce data leaks, minimize reputational risk, discover unusual and often unintentional insider threats and help prevent unauthorized access stemming from exposed data. To learn more about it, check out https://microsolved.com/clawback today.

All About Credit Union Credential Stuffing Attacks

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Credential stuffing attacks continue to be a grave concern for all organizations worldwide. However, for many Credit Unions and other financial institutions, they represent one of the most significant threats. They are a common cause of data breaches and are involved in some 76% of all security incidents. On average, our honey nets pretending to be Credit Union and other financial services experience targeted credential stuffing attacks several times per week. 

What Is Credential Stuffing?

“Credential stuffing occurs when hackers use stolen information, such as usernames and passwords from database breaches or phishing software from one account, and attempt to gain access to another. The hackers prey on people’s habit of using the same usernames and passwords for multiple sites. Using automated tools, they run large amounts of stolen information across multiple sites looking to find the same usernames and passwords being used elsewhere. Once they find a match, they can monetize the personal and financial information they gather.” (ardentcu.org)

How Common is Credential Stuffing?

Beyond our honey nets, which are completely fake environments used to study attackers, credential stuffing and the damage it causes is quite starteling. Here are some quick facts:

  • It is estimated that automated credential-stuffing attempts makes up 90% of enterprise login traffic in the US. (securityboulevard.com)

  • It’s estimated that credential stuffing costs companies more than $5 billion a year and creates havoc with consumers. (ardentcu.org)

  • According to Akamai’s latest State of the Internet report on credential stuffing, its customers alone were deluged by 30 billion malicious login attempts between November 2017 and June this year, an average of 3.75 billion per month. (theregister.com)

  • Significant credential stuffing attacks are a favorite of professional hacking groups from Russia, India, Asia and Africa. They often gather extensive lists of stolen and leaked credentials through advanced Google hacking techniques, by combing social media for password dumps (so called “credential spills”) and by purchasing lists of exposed credentials from other criminals on the dark web. Lists of member information from compromised online banking, online retailers and business association sites are common. This information often includes names, addresses, bank account numbers/credit card numbers, social security numbers, phone numbers and other sensitive data – enabling credential stuffing and social engineering attacks against victims around the world.

What Can Credit Unions Do About Credential Stuffing?

The key to handling this threat is to be able to prevent, or at the very least, identify illicit login attempts and automate actions in response to failed logins. Cybercriminals use a variety of tools, rented botnets (including specifically built credential stuffing bots) and brute force attacks to pick off less than strong passwords all around the Internet. Then, as we discussed above, they use that stolen information to probe your credit union for the same login credentials. 

The first, and easiest step, in reducing these cybercriminals’ success rate is to teach all of your legitimate users not to use the same password across multiple systems, and NEVER use passwords from public sites like Facebook, LinkedIn, Instagram, Pinterest or Twitter for example, as account credentials at work or on other important sites. Instead, suggest that they use a password manager application to make it simple to have different passwords for every site. Not only does this help make their passwords stronger, but it can even reduce support costs by reducing password reset requests. Ongoing security awareness is the key to helping them understand this issue and the significance their password choices have on the security of their own personal information and that of the company.

Next, the Credit Union should have a complete inventory of every remote login service, across their Internet presence. Every web application, email service, VPN or remote access portal and every single place that a cybercriminal could try or use their stolen credentials to gain an account takeover. Once, the Credit Union knows where login credentials can be used, they should go about preventing abuse and cyberattacks against those attack surfaces. 

The key to prevention should start with eliminating any Internet login capability that is not required. It should then progress to reducing the scope of each login surface by restricting the source IP addresses that can access that service, if possible. Often Credit Unions are able to restrict this access down to specific countries or geographic areas. While this is not an absolute defense, it does help to reduce the impacts of brute force attacks and botnet scans on the login surfaces. 

The single best control for any authentication mechanism, however, is multi factor authentication (MFA) (basically a form of secure access code provided to the user). Wheverever possible, this control should be used. While multi factor authentication can be difficult to implement on some services, it is widely available and a variety of products exist to support nearly every application and platform. Financial services should already be aware of MFA, since it has been widely regulated by FFIEC, NCUA and FDIC guidance for some time.

More and more, however, credential stuffing is being used against web mail, Office 365 and other email systems. This has become so common, that a subset of data breaches called Business Email Compromise now exists and is tracked separately by law enforcement. This form of unauthorized access has been wildly popular across the world and especially against the financial services of the United States. Compromised email addresses and the resulting wire transfer fraud and ACH fraud that stems from this form of credential theft/identity theft are among some of the highest financial impacts today. Additionally, they commonly lead to malware spread and ransomware infections, if the attacker can’t find a way to steal money or has already managed to do so.

No matter what login mechanism is being abused, even when MFA is in place, logging of both legitimate access and unauthorized access attempts is needed. In the event that a security breach does occur, this data is nearly invaluable to the forensics and investigation processes. Do keep in mind, that many default configurations of web services and cloud-based environments (like Office 365) have much of this logging disabled by default. 

While Credit Unions remain prime targets, having good prevention and detection are a key part of strong risk management against credential stuffing. Practicing incident response skills and business recovery via tabletop exercises and the like also go a long way to stengthening your security team’s capabilities.

How Can MicroSolved Help?

Our team (the oldest security firm in the midwest) has extensive experience with a variety of risk management and security controls, including helping Credit Unions inventory their attack surfaces, identify the best multi factor authentication system for their environment, create policies and processes for ensuring safe operations and performing assessments, configuration audits of devices/applications/cloud environments. 

We also scope and run custom tabletop exercises and help Credit Unions build better information security programs. Our team has extensive experience with business email compromise, wire/ACH/credit card fraud prevention, cybercriminal tactics and incident response, in the event that you discover that credential theft has occurred. 

Lastly, our ClawBack data leak detection platform, can help you watch for leaked credentials, find source code and scripts that might contain reuseable account credentials and even hunt down device configurations that can expose the entire network to easy compromise. 

You can learn more about all of our services, and our 28 years of information security thought leadership here.

Lastly, just reach out to us and get in touch here. We’d love to talk with your Credit Union and help you with any and all of these controls for protecting against credential stuffing attacks or any other cybersecurity issue.

3 Quick Thoughts for Small Utilities and Co-Ops

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Recently I was asked to help some very small utilities and co-ops come up with some low cost/free ideas around detection. The group was very nice about explaining their issues, and here is a quick summary of some of the ideas we discussed.

1) Dump external router, firewall, AD and any remote access logs weekly to text and use simple parsers in python/perl or shell script to identify any high risk issues. Sure, this isn’t the same as having robust log monitoring tools (which none of these folks had), but even if you detect something really awful a week after it happens, you will still be ahead of the average curve of attackers having access for a month or more. You can build your scripts using some basis analytics, they will get better over time, and here are some ideas to get you started. You don’t need a lot of money to quickly handle dumped logs. Do the basics and improve.

2) Take advantage of cheap hardware, like the Raspberry Pi for easy to learn/use Linux boxes for scripting, log parsing or setting up cron jobs to automate tasks. For less than 50 bucks, you can have a powerful machine to do a lot of work for you and serve as a monitoring platform for a variety of tools. The group was all tied up in getting budget to buy server and workstation hardware – but had never taken the Pi seriously as a work platform. It’s mature enough to do a lot of non-mission critical (and some very important) work. It’s fantastic if you’re looking for a quick and dirty way to gain some Linux capabilities in confined Windows world.

3) One of the best bang for the buck services we have at MSI is device configuration reviews. For significantly less money than a penetration test, we can review your external routers, firewall and VPN for configuration issues, improper rules/ACLs and insecure settings. If you combine this with an exercise like attack surface mapping and threat modeling, you can get a significant amount of insight without resorting to (and paying for) vulnerability assessments and penetration testing. Sure, the data might not be as granular, and we still have to do some level of port scanning and service ID, but we have a variety of safe ways to do that work – and you get some great information. You can then make risk-based decisions about the data and decide what you want to act on and pay attention to. If your budget is tight – get in touch and discuss this approach with us.

I love to talk with utilities and especially smaller organizations that want to do the right thing, but might face budget constraints. If they’re willing to have an open, honest conversation, I am more than willing to get creative and engage to help them solve problems within their needs. We’d rather get creative and solve an issue to protect the infrastructure than have them get compromised by threat actors looking to do harm.

If you want to discuss this or any security or risk management issue, get in touch here.  

Utility Tabletop Cybersecurity Exercises

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Recently, a group of federal partners, comprised of the Federal Energy Regulatory Commission (FERC), North American Reliability Corporation (NERC) and it’s regional entities released their Cyber Planning for Response and Recovery Study (CYPRES). The report was based on a review and analysis of the incident response and recovery capabilities of a set of their member’s cyber security units, and is a great example of some of the information sharing that is increasing in the industry. The report included reviews of eight utility companies’ incident response plans for critical infrastructure environments, and the programs reviewed varied in their size, complexity and maturity, though all were public utilities.

Though the specific tactics suggested in the report’s findings have come under fire and criticism, a few items emerged that were of broad agreement. The first is that most successful programs are based on NIST 800-61, which is a fantastic framework for incident response plans. Secondly, the report discusses how useful tabletop exercises are for practicing responses to cybersecurity threats and re-enforcing the lessons learned feedback loop to improve capabilities. As a result, each public utility should strongly consider implementing periodic tabletop exercises as a part of their cyber security and risk management programs.

Tabletop Exercises from MSI

At MicroSolved, we have been running cyber security tabletop exercises for our clients for more than a decade. We have a proprietary methodology for building out the role playing scenarios and using real-world threat intelligence and results from the client’s vulnerability management tools in the simulation. Our scenarios are developed into simulation modules, pre-approved by the client, and also include a variety of randomized events and nuances to more precisely simulate real life. During the tabletop exercise, we also leverage a custom written gaming management system to handle all event details, track game time and handle the randomization nuances.

Our tabletop exercise process is performed by two MSI team members. The first acts as the simulation moderator and “game master”, presenting the scenarios and tracking the various open threads as the simulation progresses. The second team member is an “observer” and they are skilled risk management team members who pre-review your incident response policies, procedures and documentation so that they can then prepare a gap analysis after the simulation. The gap analysis compares your performance during the game to the process and procedure requirements described and notes any differences, weaknesses or suggestions for improvement.

Target scenarios can be created to test any division of the organization, wide scale attacks or deeply nuanced compromises of specific lines of business. Various utility systems can be impacted in the simulation, including business networks, payment processing, EDI/supply chain, metering/AMI/smart grid, ICS/SCADA or other mission critical systems.Combination and cascading failures, disaster recovery and business continuity can also be modeled. In short, just about any cyber risks can be a part of the exercise.

Tabletop Exercise Outcomes and Deliverables

Our tabletop exercises result in a variety of detailed reports and a knowledge transfer session, if desired. The reports include the results of the policy/procedure review and gap analysis, a description of the simulated incident and an action plan for future improvements. If desired, a board level executive summary can also be included, suitable for presentation to boards, management teams, direct oversight groups, Public Utility Commission and Homeland Security auditors as well.

These reports will discuss the security measures tested, and provide advice on proactive controls that can be implemented, enhanced, matured or practiced in order to display capabilities in future incidents that reflect the ability to perform more rapid and efficient recovery.

The knowledge transfer session is your team’s chance to ask questions about the process, learn more about the gaps observed in their performance and discuss the lessons learned, suggestions and controls that call for improvement. Of course the session can include discussions of related initiatives and provide for contact information exchange with our team members, in the event that they can assist your team in the future. The knowledge transfer session can also be performed after your team has a chance to perform a major review of the reports and findings.

How to Get Started on Tabletop Exercises from MSI

Tabletop exercises are available from our team for cyber security incidents, disaster preparedness and response or business continuity functions. Exercises are available on an ad-hoc, 1 year, 2 year or 3 year subscription packages with frequencies ranging from quarterly to twice per year or yearly. Our team’s experience is applicable to all utility cyber programs and can include any required government partners, government agencies or regulators as appropriate.

Our team can help develop the scope of threats, cyber attacks or emergency events to be simulated. Common current examples include ransomware, phishing-based account compromises, cyber attacks that coincide with catastrophic events or service disruptions, physical attacks against substations or natural gas pipelines, data breach and compromise of various parts of the ICS/SCADA infrastructure. Our team will work with you to ensure that the scenario meets all of your important points and concerns.

Once the scenario is approved, we will schedule the simulation (which can be easily performed via web-conference to reduce travel costs and facilitate easy team attendance) and build the nuances to create the effects of a real event. Once completed, the reporting and knowledge transfer sessions can follow each instance.

Tabletop exercises can go a long way to increasing cybersecurity preparedness and re-enforcing the cybersecurity mindset of your team. It can also be a great opportunity for increasing IT/OT cooperation and strengthening relationships between those team members.

To get started, simply contact us via this web form or give us a call at (614) 351-1237. We would love to discuss tabletop exercises with you and help you leverage them to increase your security posture.

 

All About FINRA Risk Assessments

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FINRA (Financial Industry Regulatory Authority) requires an enterprise risk assessment once per year for all member firms. This risk assessment should be completed using the NIST Cyber-Security Framework, if appropriate for the size of the organization. At MSI, we fully embrace the NIST framework and use it routinely for our approach to information security and risk management.

Who Performs the FINRA Risk Assessment?

The FINRA requirements for risk assessment include that it be completed by independent third-party assessors, if possible, or otherwise by internal information security experts (if qualified and available). MSI’s approach is to work WITH our client’s internal team members, including them in the process, and leveraging their deep knowledge of the firm’s operations, while still maintaining our independence. In our experience, this provides the best return on investment for the risk assessment, and allows granular analysis without draining critical internal client resources.

What Analysis Does the FINRA Risk Assessment Require?

Each FINRA risk assessment should include an inventory of all critical data, PII and other sensitive information. Then, each asset should be reviewed for its impact on the business and identification of relevant controls, risks, mitigations and residual risks should occur. This process requires deeper knowledge of cyber security than most firms are comfortable with, and the experience and attention to detail of the assessor can make or break the value of the assessment.

Is the FINRA Risk Assessment Affordable?

Since the workload of a risk assessment varies greatly based on the size and complexity of the organization being assessed, smaller firms are naturally more affordable than larger firms. Risk assessments are affordable for nearly every firm today, and the work plans can be easily customized to fit even the tightest of budgets. In addition, when working with experienced and knowledgable assessors, the cost can be even lower and the results even more valuable. At MSI, our assessment team has more than 15 years of experience, across a wide variety of size, type and operational styles of client firms. You won’t find any “on the job training” here, our experts are among the best and most recognized in the world. We are excellent at what we do, and we can help your firm get the best ROI on a risk assessment in the industry.

How Do I Get Started on a FINRA Risk Assessment from MSI?

Simply drop us a line via this web form, or give us a call at (614) 351-1237 to arrange for a free, no hassle call with our team. We’ll explain how our process works, gather some basic information and provide you with a proposal. We’d love the chance to talk with you, and be of service to your firm. At MSI, we build long-term client relationships and we truly want to partner to help your firm be more successful, safer and manage the risks of the online world more easily. Give us a call today! 

ClawBack For Credit Unions

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I got a question recently from one of our Credit Union clients about ClawBack™. They explained that they don’t really do any internal development, so leaking source code was not a concern for them. Based on that, they wondered, would ClawBack still be a useful tool for them?

I pointed out that most larger Credit Unions do some form of development, or at the very least, that their systems admin folks often write (and potentially expose) scripts and other management tools that would be of use to an attacker. However, even if they didn’t do any development at all, leveraging something like the Professional level of ClawBack as a DIY tool ($149.00 per month) is still a good idea.

Further, I explained that source code leaks are only one third of the focus of the ClawBack tool. It also searches for leaked device/application configurations and leaked credentials. Every Credit Union with a network needs to think about leaked device and application configurations. These are the most commonly found items in ClawBack’s history. Whether by accident, or misunderstanding or malicious intent, thousands of leaked configuration files wind up on the Internet in repositories, support forums, answer sites, social media and paste bins. When found, they can provide significant amounts of damaging information to attackers, ranging from logins and passwords to sensitive cryptography and API keys. In some cases, they can be a nearly complete map of the internal network.

Thirdly, ClawBack also focuses on leaked credentials. It can help identify stolen and compromised passwords belonging to members of your organization. Many times, these credentials contain the same or similar passwords as Internet exposed applications, webmail or email access and potentially even weakly secured VPN instances. Stolen and leaked credentials are among the most significant root causes of breaches, business email compromise and a variety of other fraud.

Your CU Security team can add ClawBack to their toolkit for less than $150 per month. It’s simple to use, flexible and an incredibly powerful capability to minimize the damage from data leaks. Check out this less than 8 minute video for more information. If you’d like to discuss ClawBack or our ClawBack Managed and Professional Services, please drop us a line, or give us a call at (614) 351-1237 today. 

Closing the CUSO Security Loop Hole

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The CUSO Security Loop Hole

The NCUA Inspector General (IG) suggested this week that the agency have regulatory oversight of Credit Union Service Organizations (CUSOs) to reduce the overall risk to the system. CUSOs have long been seen as a separate firm from the credit unions, though they may have an ownership stake in them. To date, many of these organizations have been outside the regulatory and oversight controls that are applied to the very credit unions they serve. In terms of information security, that often means they aren’t held to the same level of security and risk management controls as required by NCUA 748 and other guidance.

DigitalMoneyCUSO Security Oversight Challenges

The NCUA IG suggests that NCUA guidance and regulatory oversight be directly applied to CUSOs, instead of through vendor or partner risk management programs of the CUSO customers. This would provide for more direct regulation of the security controls and risk management processes in use at the CUSOs themselves. However, this introduces several challenges for some CUSOs, who may be more focused on agility, market speeds and innovation – areas where regulatory guidance can be especially impactful and can create significant budgetary challenges. This gets even more complicated when regulatory guidance is vague, or can be inflexible – the very opposite of the needs of organizations focused on innovation and market speed adaptation. An excellent example of this is CUSOs working on financial technologies, crypto currencies, blockchain and other exciting new areas. Regulatory guidance lags or lacks in most of those areas and hasn’t caught up to these new, and in some cases, experimental technologies.

One Approach – Best Practices CUSO Security and Third Party Attestation

One approach that might work, is for CUSOs to work with independent third-party assessors who could then measure the CUSO against industry standard best practices that apply to their specific lines of business, research or innovation. These vendors could then help the CUSO build a relevant and respectable CUSO security and risk management program – which they could attest to the NCUA. If this attestation were required on a yearly basis, along with some basic guidance, like ongoing risk management reviews, ongoing vulnerability management, etc – this could go a long way to mitigating the risks that concern the NCUA IG, while still maintaining independence and control by the CUSOs – thus, empowering their mission. Programs like these have been very successful in other industries and don’t have to add the overhead and bureaucracy of full regulatory compliance or programs like PCI-DSS. 

If you’d like to build such a program for your CUSO, please get in touch with us. We’d love to work on creating this process with a handful of CUSOs around the US, and are more than capable of applying our 30 years of experience in information security to each organization’s independent needs. Drop us a line or give us a call at (614) 351-1237 and let’s work together to close the CUSO Security loop hole in a way that reduces risk but doesn’t destroy the power and flexibility of the CUSO ecosystem.