Category Archives: Policy and Process

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.

A Quick Expert Conversation About Gap Assessment

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Gap Assessment Interview with John Davis

What follows is a quick interview session with John Davis, who leads the risk assessment/policy/process team at MicroSolved. We completed the interview in January of 2020, and below are the relevant parts of our conversation.

Brent Huston: “Thanks for joining me today, John. Let’s start with what a gap assessment is in terms of HIPAA or other regulatory guidance.”

John Davis: “Thanks for the chance to talk about gap assessment. I have run into several HIPAA concerns such as hospitals and health systems who do HIPAA gap analysis / gap assessment in lieu of HIPAA risk assessment. Admittedly, gap assessment is the bulk of risk assessment, however, a gap assessment does not go to the point of assigning a risk rating to the gaps found. It also doesn’t go to the extent of addressing other risks to PHI that aren’t covered in HIPAA/HITECH guidance.”

BH: “So, in some ways, the gap assessment is more of an exploratory exercise – certainly providing guidance on existing gaps, but faster and more affordable than a full risk assessment? Like the 80/20 approach to a risk assessment?”

John Davis: “I suppose so, yes. The price is likely less than a full blown risk assessment, given that there is less analysis and reporting work for the assessment team. It’s also a bit faster of an engagement, since the deep details of performing risk analysis aren’t a part of it.”

BH: “Should folks interested in a gap assessment consider adding any technical components to the work plan? Does that combination ever occur?”

JD: “I can envision a gap assessment that also includes vulnerability assessment of their networks / applications. Don’t get me wrong, I think there is immense value in this approach. I think that to be more effective, you can always add a vulnerability assessment to gauge how well the policies and processes they have in place are working in the context of the day-to-day real-world operations.”

BH: “Can you tie this back up with what a full risk assessment contains, in addition to the gap assessment portion of the work plan?”

JD: “Sure! Real risk assessment includes controls and vulnerability analysis as regular parts of the engagement. But more than that, a complete risk assessment also examines threats and possibilities of occurrence. So, in addition to the statement of the gaps and a roadmap for improvement, you also get a much more significant and accurate view of the data you need to prioritize and scope many of the changes and control improvements needed. In my mind, it also gets you a much greater view of potential issues and threats against PHI than what may be directly referenced in the guidance.” 

BH: “Thanks for clarifying that, John. As always, we appreciate your expert insights and experience.”

JD: “Anytime, always happy to help.”

If you’d like to learn more about a gap assessment, vulnerability assessment or a full blown risk assessment against HIPAA, HITECH or any other regulatory guidance or framework, please just give us a call at (614) 351-1237 or you can click here to contact us via a webform. We look forward to hearing from you. Get in touch today! 

MicroSolved vCISO for Credit Unions

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I recently asked MicroSolved COO, Dave Rose, to share his thoughts with all of us about the vCISO program. He has been leading the effort this last year across several credit unions and regional banks around the US. I asked him for the 3 biggest benefits an organization can expect and here is what he said:

“MicroSolved has been providing vCISO services to Credit Unions for over 20 years. Whether you are a corporate or a natural person CU, hiring MSI for vCISO Services will allow you to:

  • Obtain CISO expertise without having to incur the expense of finding and hiring a CISO. This is an affordable solution that will help keep the risk budget under control.
  • MSI vCISO program comes with the benefit of a focus towards financial expertise and compliance. MSI has had extensive experience working with banks and credit unions on their risk programs, and have spent time educating regulators on risk events and controls.
  • MSI is in the business of mitigating risk. We live it everyday and our clients benefit from that experience. Our clients get to pick the risk work they want resolved and the issues they want remediated. 

You will be hard pressed to find a more efficient and cost effective way to address risk issues and move the regulatory needle. Don’t bear the burden of mitigating risk alone, let MSI be a partner to help you solve your risk needs!”

—Dave Rose

For more information, give us a call at 614-351-1237 or email us at info@microsolved.com. 

Zelle…quick, easy, and…problematic?

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Measuring risk

With the increasing adoption of PayPal, Venmo, and other instant payment services…it’s no surprise that the financial services industry entered the arena. The concept is simple – P2P payments via phone or email. At least one entity – sender or recipient – needs to have a bank account with a bank that supports Zelle. The other entity can simply link a supported debit card to enable the exchange.

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How do you Identify? Business Email Compromise #1

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Business Email Compromise

business email compromise

Recently, we posted the Business Email Compromise (BEC) checklist. We’ve gotten a lot of great feedback on the checklist…as well as a few questions. What if you’re new to security? What if your organization’s security program is newer, and still maturing? How can you leverage this list?

Since the checklist is based on the NIST model, there’s a lot of information here to help your security program mature, as well as to help you mature as a security practitioner. MSI’s engineers have discussed a few ways to leverage the checklist as a growth mechanism.

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Prescription pharmacy bags – do you just trash them?

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When you get your prescription filled at a pharmacy, the medication is usually dispensed in amber colored pill bottles packaged in a pharmacy paper or plastic bag. Once the medication has been consumed, many discard or recycle the bottles.

There have been several articles on how to remove the sensitive information contained in the medication labels on the bottles. The information include the patient’s name and address, name of doctor and medication details. Recommended methods of removing the information include striking them out with a marker pen or removing the label. Some locations will accept the bottles and remove the labels and information for you, and recycle the bottles.

However, nothing is said of the pharmacy paper or plastic bag that the pill bottles come in when you get them from the pharmacist. When I get my meds from the pharmacist – from a big name national grocery store – I am asked for identification to receive them. I am asked of my name and phone or birthdate, and they verify with the information printed on the bag.

Most people are not aware of or don’t consider the information on the front of these bags. The information can be much more sensitive than what’s on the pill bottle labels. These bags are thrown in with the trash, never shredded. That leaves the information vulnerable to dumpster divers and identity theft.

The pharmacy bags the big grocery store dispenses the prescriptions in are sealed plastic bags. I can’t shred them so I stretch and tear the plastic to destroy the information. Most people will not take the trouble to do that. I have spoken with the pharmacist at the location I pick up my medications at with my concerns. Their process is obviously not up to him but perhaps he could pass on the concerns.

Take note of the label information your medications come in, not just the pill bottles but the pharmacy bag. Your private information is not only on the pill bottles but on the bag when they hand you your meds. Dispose of these packaging appropriately.

 

Resources:

Education Understanding Prescription Medication Labels

https://www.popsci.com/old-medications-prescriptions-disposal

There’s Still Treasure in the Trash

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Most businesses have processes and policies for handling sensitive data on paper, whether thats selectively shredding papers or shredding everything, along with training about what goes in trash bins and what goes in shredding bins. However, how many are ensuring that these policies and processes are being followed? Brent asked

Which got me thinking about this. I couldn’t remember the last time an organization actually asked us about it beyond reviewing policies. I know this problem didn’t disappear, even as we move more and more away from paper. Paper still gets used, people write stuff down, things get printed, and no solution completely ensures that that paper doesn’t end up in the wrong bin. I know from doing it. I found something useful in almost every engagement that we’ve done in the past, whether it was an administrative password, or contact information that I can use for phishing.

Recently, some researchers performed a trash inspection of some hospitals in Toronto. What they found didn’t surprise me. They found PII and PHI, a good bit of it.  A resident in Palolo Hawaii found these too. A nuclear security complex was found to be dumping trash that had classified documents in it. None of these were reported breaches, just there for the taking. Who knows if anyone malicious found them too?

Let’s keep working on the most prevalent topics of the day, such as phishing defense and training, but we can’t forget all of the things that were an issue in the past, because they’re still an issue now even if they’re not making the big headlines in the current moment.

Introducing AirWasp from MSI!

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For over a decade, HoneyPoint has been proving that passive detection works like a charm. Our users have successfully identified millions of scans, probes and malware infections by simply putting “fake stuff” in their networks, industrial control environments and other strategic locations. 

 

Attackers have taken the bait too; giving HoneyPoint users rapid detection of malicious activity AND the threat intelligence they need to shut down the attacker and isolate them from other network assets.

 

HoneyPoint users have been asking us about manageable ways to detect and monitor for new WiFi networks and we’ve come up with a solution. They wanted something distributed and effective, yet easy to use and affordable. They wanted a tool that would follow the same high signal, low noise detection approach that they brag about from their HoneyPoint deployments. That’s exactly what AirWasp does.

 

We created AirWasp to answer these WiFi detection needs. AirWasp scans for and profiles WiFi access points from affordable deck-of-cards-sized appliances. It alerts on any detected access points through the same HoneyPoint Console in use today, minimizing new cost and management overhead. It also includes traditional HoneyPoints on the same hardware to help secure the wired network too!

 

Plus, our self-tuning white list approach means you are only alerted once a new access point is detected – virtually eliminating the noise of ongoing monitoring. 

 

Just drop the appliance into your network and forget about it. It’ll be silent, passive and vigilant until the day comes when it has something urgent for you to act upon. No noise, just detection when you need it most.

 

Use Cases:

 

  • Monitor multiple remote sites and even employee home networks for new Wifi access points, especially those configured to trick users
  • Inventory site WiFi footprints from a central location by rotating the appliance between sites periodically
  • Detect scans, probes and worms targeting your systems using our acclaimed HoneyPoint detection and black hole techniques
  • Eliminate monitoring hassles with our integration capabilities to open tickets, send data to the SIEM, disable switch ports or blacklist hosts using your existing enterprise products and workflows

More Information

 

To learn how to bring the power and flexibility of HoneyPoint and AirWasp to your network, simply contact us via email (info@microsolved.com) or phone (614) 351-1237.


 

We can’t wait to help you protect your network, data and users!


Hurricane Matthew Should Remind You to Check Your DR/BC Plans

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The news is full of tragedy from Hurricane Matthew at the moment, and our heart goes out to those being impacted by the storm and its aftermath.

This storm is a powerful hit on much of the South East US, and should serve as a poignant reminder to practice, review and triple check your organization’s DR and BC plans. You should have a process and procedure review yearly, with an update at least quarterly and anytime major changes to your operations or environment occur. Most organization’s seem to practice these events on a quarterly or at least 2x per year cycle. They often use a full test once a year, and table top exercises for the others. 

This seems to be an effective cycle and approach. 

We hope that everyone stays safe from the hurricane and we are hoping for minimal impacts, but we also hope that organizations take a look at their plans and give them a once over. You never know when you just might need to be better prepared.

Brands Being Used in Pornography Search Engine Poisoning

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Recently, during one of our TigerTrax™Targeted Threat Intelligence engagements, we were performing passive threat assessments for a popular consumer brand. In the engagement, we not only gathered targeted threat intelligence about their IT environments, applications and hosting partners, but also around the use of their brand on a global scale. The client had selected to take advantage of our dark net intelligence capabilities as well, and were keenly interested in how the dark net, deep web and underground portions of the Internet were engaged with their brand. This is a pretty common type of engagement for us, and we often find a wide variety of security, operational and reputational issues.

This particular time around, we ran into a rather interesting and new concern, at least on the dark net. In this case, a dark net pornography site was using the consumer brand embedded as an HTML comment in the porn site’s main pages. Overall, there were several hundred name brands in the comments. This seems to have been performed so that the search engines that index the site on the dark net, associate the site with the brands. That means when a user searches for the brand name, they get the porn site returned as being associated. In this case, it was actually the first link on several of the dark net search sites we tested. The porn site appears to be using the brand names to lure eyeballs to the site – essentially to up the chance of finding a subscriber base for their particularly nasty set of pornography offerings. Search engine poisoning has been an issue on the public web for some time, and it is a commonly understood tactic to try and link your content to brands, basically serving as “click bait” for users. However, on the dark net, this was the first time we had observed this tactic being used so overtly.

The brand owner was, of course, concerned about this illicit use of their brand. However, there is little they could do to respond, other than reporting the site to the authorities. Instead, after discussing various options, we worked with them to identify an action and response plan for how they would handle the problem if it became a public concern. We also worked with them to identify a standard process that they could follow to bring their existing legal, marketing, management and other parts of their incident response team up to date on threats like these as they emerged.

The client was very pleased to have the discussion and with the findings we identified. While any misuse of their brand is a concern, having their brand associated with pornography or other illicit material is certainly unnerving. In the end, there is little that organizations can do, other than work with authorities or work on take down efforts if the brand is misused on the public web. However, having the knowledge that the issue is out there, and working to develop the threat into existing response plans certainly goes a long way to help them minimize these kinds of risks.

To learn more about dark net brand issues, targeted threat intelligence or passive assessments, drop us a line (info@microsolved dot com) or get in touch on Twitter (@lbhuston) for a discussion.