Ransomware-Proof Your Credit Union: A Checklist of NCUA Guidance

In today’s digital landscape, credit unions face numerous cybersecurity threats, including the rising risk of ransomware attacks and vulnerabilities in their information and communications technology supply chain. To help credit unions protect themselves against these risks, the National Credit Union Administration (NCUA) has compiled an FAQ. This checklist covers the essential steps to safeguard against ransomware attacks, additional resources for cybersecurity, understanding supply chain risk management, developing effective practices, mitigating risks associated with using a Managed Service Provider (MSP), and other insights based on their FAQ. By following this checklist, credit unions can enhance their overall security posture and minimize the potential impact of cyber threats.

1. Protect against ransomware attacks:
– Update software and operating systems regularly with the latest patches.
– Avoid clicking on links or opening attachments in unsolicited emails.
– Follow safe browsing practices.
– Replace equipment running older unsupported operating systems.
– Verify the security practices of vendors and third-party service providers.
– Maintain complete and tested backups of critical systems and data.

2. Additional resources for cybersecurity:
– Use the Ransomware Self-Assessment Tool (R-SAT) from the Conference of State Bank Supervisors.
– Read the Center for Internet Security white paper on ransomware.
– Visit the cybersecurity pages of the National Security Agency Central Security Service and the Cybersecurity & Infrastructure Security Agency. (CISA)
– Refer to the Treasury Department’s advisory on potential sanctions risks for facilitating ransomware payments.

3. Understand Technology Supply Chain Risk Management (SCRM):
– Recognize that technology supply chain vulnerabilities can pose risks to the entire institution.
– Consider the risks associated with third-party vendors and the entire technology supply chain.
– Identify vulnerabilities in all phases of the product life cycle.

4. Develop an effective Technology Supply Chain Risk Management Practice:
– Build a team with representatives from various roles and functions.
– Document policies and procedures based on industry standards and best practices.
– Create a list of technology components and understand their criticality and remote access capability.
– Identify suppliers and verify their security practices.
– Assess and evaluate the SCRM program regularly.

5. Risks associated with using a Managed Service Provider (MSP):
– APT actors actively attempt to infiltrate IT service provider networks.
– Conduct proper due diligence and ongoing monitoring of MSPs.
– Understand the risks of centralizing information with an MSP.
– Recognize that compromises in an MSP’s network can have cascading effects.

6. Mitigate the risk of using an MSP:
– Manage supply chain risk by working with the MSP to address security concerns.
– Implement architecture measures to restrict access and protect networks.
– Use dedicated VPNs for MSP connections and restrict VPN traffic.
– Ensure proper authentication, authorization, and accounting practices.
– Implement operational controls, such as continuous monitoring and software updates.

7. Additional references for Information and Communications Technology Supply Chain Risk Management:
– Refer to guidance from the NCUA, NIST, and CISA.
– Evaluate third-party relationships and outsourcing technology services.
– Learn about supply chain threats and cyber supply chain risk management.

Note: This checklist is a summary of the information provided. For more detailed guidance, refer to the full content on the NCUA website.

 

* We used some AI tools to gather the information for this article.

First Step After Breach

Discovering an information security breach can be a shock! Picture it: you are enjoying a regular work day and WHAM! Suddenly you are at the center of an incident that could possibly affect the future of the company and perhaps your own future as well. It’s easy to panic. You know if you don’t do the right thing, right now, bad things are sure to rain down on you. So, what is the very first thing that you should do?

Go immediately to your incident response plan, of course! After all, that is the reason your company has put together an IR plan and team in the first place; to plan for contingencies so that personnel don’t go off half-cocked and lose vital data and evidence. 

But is your plan clear enough that regular system users or even help desk personnel know what to do first without having to thumb through a hundred pages of plan? If not, perhaps a simple little trick we use in our incident response plans will work for you. 

The very first thing you see when you open one of our incident response plans are employee and incident response team Quick Response Guides (see the example of an employee guide below-the IRT guide is similar, but more complex). 

I know from my military experience that having checklists such as the Quick Response Guides in place truly cuts down on mistakes and helps calm personnel during difficult situations. Why not see if they can also improve your response quality?

 

Chart

 













You can download the pocket guide here

Thanks to John Davis for this post.

State Of Security Podcast Episode 4

We are proud to announce the release of State Of Security, the podcast, Episode 4. This time around I am hosting John Davis, who riffs on policy development for modern users, crowdsourcing policy and process management, rational risk assessment and a bit of history.

Give it a listen and let us know what you think!

Thanks for supporting the podcast!

Tips for Writing Good Security Policies

Almost all organizations dread writing security policies. When I ask people why this process is so intimidating, the answer I get most often is that the task just seems overwhelming and they don’t know where to start. But this chore does not have to be as onerous or difficult as most people think. The key is pre-planning and taking one step at a time.

First you should outline all the policies you are going to need for your particular organization. Now this step itself is what I think intimidates people most. How are they supposed to ensure that they have all the policies they should have without going overboard and burdening the organization with too many and too restrictive policies? There are a few steps you can take to answer these questions:

  • Examine existing information security policies used by other, similar organizations and open source information security policy templates such as those available at SANS. You can find these easily online. However, you should resist simply copying such policies and adopting them as your own. Just use them for ideas. Every organization is unique and security policies should always reflect the culture of the organization and be pertinent, usable and enforceable across the board.
  • In reality, you should have information security policies for all of the business processes, facilities and equipment used by the organization. A good way to find out what these are is to look at the organizations business impact analysis (BIA). This most valuable of risk management studies will include all essential business processes and equipment needed to maintain business continuity. If the organization does not have a current BIA, you may have to interview personnel from all of the different business departments to get this information. 
  • If the organization is subject to information security or privacy regulation, such as financial institutions or health care concerns, you can easily download all of the information security policies mandated by these regulations and ensure that you include them in the organization’s security policy. 
  • You should also familiarize yourself with the available information security guidance such as ISO 27002, NIST 800-35, the Critical Security Controls for Effective Cyber Defense, etc. This guidance will give you a pool of available security controls that you can apply to fit your particular security needs and organizational culture.

Once you have the outline of your security needs in front of you it is time to start writing. You should begin with broad brush stroke, high level policies first and then add detail as you go along. Remember information security “policy” really includes policies, standards, guidelines and procedures. I’ve found it a very good idea to write “policy” in just that order.

Remember to constantly refer back to your outline and to consult with the business departments and users as you go along. It will take some adjustments and rewrites to make your policy complete and useable. Once you reach that stage, however, it is just a matter of keeping your policy current. Review and amend your security policy regularly to ensure it remains useable and enforceable. That way you won’t have to go through the whole process again!

Thanks to John Davis for this post.

Touchdown Task for August – Change Management Audit

This month, we urge all infosec teams to engage in a quick 30 minute audit of your change management processes.

Here are some quick win questions to ask of the change management team:

  • How often does the change management team meet & what is the time frame for turning around a change order?
  • What percentage of actual changes to the environment went through the change process in the last 12 months?
  • Where can we locate the documents that specifically describe the change management process and when were they last revised?
  • Please describe how exceptions to the change management process are handled.
  • How are changes to the environment audited against what was provided to the change management team?
  • What happens if a change is identified that did NOT go through the change management process?

There are plenty of online guidance sources for additional questions and audit processes, but these quick wins will get you started. As always, thanks for reading and keep working on your monthly touchdown tasks. Be sure to touch base with us on Twitter (@microsolved) should you have any questions about the work plans.

The Big Three

Information security techniques certainly are improving. The SANS Top Twenty Critical Controls, for example, are constantly improving and are being adopted by more and more organizations. Also, security hardware devices and software applications are getting better at a steady rate. But the question we have to ask ourselves is: are these improvements outpacing or even keeping up with the competition? I think a strong argument can be made that the answer to that question is NO! Last year there were plenty of high profile data loss incidents such as the Target debacle. Over 800 million records were compromised that we know of, and who knows how many other unreported security breaches of various types occurred?

So how are we going to get on top of this situation? I think the starkly realistic answer to that question is that we arent going to get on top it. The problem is the age old dilemma of defense versus attack; attackers will always have the advantage over entrenched defenders. The attackers know where you are, what you have and how you defend it. All they have to do is figure out one way to get over, under or around your defenses and they are successful. We, on the other hand, dont know who the attackers are, where theyre at or exactly how they will come at us. We have to figure out a way to stop them each and every time a daunting task to say the least! Sure, we as defenders can turn the tables on the information thieves and go on the attack; that is one way we can actually win the fight. But I dont think the current ethical and legal environment will allow that strategy to be broadly implemented.

Despite this gloomy prognosis, I dont think we should just sit on our hands and keep going along as we have been. I think we should start looking at the situation more realistically and shift the focus of our efforts into strategies that have a real chance of improving the situation. And to me those security capabilities that are most likely to bear fruit are incident detection, incident response and user education and awareness; the Big Three. Over the next several months I intend to expand upon these ideas in a series of blog posts that will delve tactics and means, so stay tuned if this piques your interest! 

Thanks to John Davis for writing this entry.

September TouchDown Task: Policy Quick Review

This month’s touchdown task is to review your information security related policies and procedures. Whether you, your team, or human resources are responsible for updating and maintaining information security policies, we suggest you review these documents every quarter, or at least every six months to ensure your policies keep pace with legislation, pertinent guidance and ever-changing technology. Even if your organization utilizes a company wide revision process, we suggest you carve out a few hours this month to begin to review the infosec policies.

Start by reading all the policies related to information security. Note those that require significant updates.
Next, research changes in legislation or technology that might affect your policies. Note the pertinent changes.
Seek feedback from your colleagues and managers.
Using the information gained, revise the necessary policies or document your suggestions for the company-wide revision process.
Either obtain necessary approvals for your updates or provide your draft revisions to those responsible for maintaining updated policies and procedures.
Until next month, stay safe out there!

Special Thanks to Teresa West for the help on this one! — Brent

How Cloud Computing Will Leak Into Your Enterprise

“Consumer use of the cloud”; in a phrase, is how the cloud will leak into your enterprise, whether you like it or not. Already, IT is struggling with how to manage the consumer use of devices and services in the enterprise. Skype/VoIP and WIFI were the warning shots, but the BlackBerry, iPhone, iPad and other consumer devices are the death nail for centralized IT (and IS) control.

Consumer electronics, backed by a wide array of free or low cost cloud services, are a new frontier for your organization. Services like MobileMe, DropBox, various file sharing tools and remote access services like GoToMyPC, et al. have arrived. Likely, they are in use in your environment today. Consumers use and leverage these services as a part of their increasingly de-centralized online life. Even with sites like Twitter and FaceBook growing in capability and attention, consumers grow their use, both personally and professionally of services “in the cloud”. Make no mistake, despite your controls at the corporate firewalls, consumers are using their mobile and pocket devices and a variety of these services. Unless you are searching them at the door and blocking cell phone use in your business, they are there.

This might not be “the cloud” that your server admins are worrying about. It might not represent all of the off-site system, database and other hosting tools they are focused on right now, but make no mistake, this consumer version of the cloud has all, if not more, of the same issues and concerns. Questions about your data is managed, secured and maintained all abound.

Given the “gadget posture” of most organizations and their user communities, this is not likely to be something that technical controls can adequately respond to. The consumer cloud services are too dynamic and widespread for black listing approaches to contain them. Plus, they obviously lack centralized choke points like in the old days of “network perimeter security”. The new solution, however, is familiar. Organizations must embrace policies and processes to cover these technologies and their issues. They also have to embrace education and awareness training around these topics with their user base. Those who think that denial and black listing can solve this problem are gravely mistaken. The backdoor cloud consumer movement into your organization is already present, strong and embedded. Teaching users to be focused on safe use of these services will hopefully reduce your risk, and theirs.

Responding to a Compromised System Alert

Thanks to the data from the HITME, I interact with a lot of people and organizations that have compromised machines. Often, my email or phone call is the first they have heard of the problem. Reactions vary from shock and denial to acceptance and occasionally rage. Even worse, when they hear that their machines are attacking others or being used in active attacks, many have no idea how to handle the situation.

Should you ever get a call like this from me or someone else, here are a few tips that you might find helpful for proceeding.

1. Be polite. I am calling to help you. Even though my message may mean more work and possibly some pain for you and your staff, knowing about a compromise is MUCH better than not knowing. Usually, the more polite and nice you are, the more information I will help you understand. I can usually point you in the right direction to begin to understand the issue, but if you act like a jerk, I will likely leave you to it.

2. Begin an investigation as soon as possible. Invoke your incident response process. If you don’t have one, ask for help, or retain assistance. But, please, treat a caller who explains and demonstrates that you have a system compromise with immediate attention. I see hundreds of compromised systems a day and I don’t have time to beg and plead with you to reduce your risk and the risk your systems present to others. I am happy to substantiate my claims, but after I notify you, TAKE ACTION. The majority of compromised systems involved in notification remain under attacker control for extended periods. Often, weeks and months pass by before any apparent action (such as mitigation or clean up) takes place.

3. Do a thorough job of mitigation. I would say that more than 25% of the time (I just started formally tracking this to gather better metrics.) when a site goes through “clean up”, they end up compromised again and right back where they started from. Likely many of these machines are simply bot-infected and the bots just place their malware back on the system after “clean up” is done. Removing the basic tag files or malware, but not understanding how they got there in the first place and fixing that is pretty much meaningless. For example, I have been working with a site presently that has been used as a PHP RFI verification tag file host for weeks. They have “cleaned up” every day for several weeks to no avail. Every night, they get hit by another PHP RFI scanner and it exploits their system and drops a new tag or malware bot. I have tried explaining no less than 10 times how they need to identify the underlying PHP issue, harden the PHP environment (yeah, I sent them the settings) to no avail. This is an example of how to fail at risk, threat and vulnerability management. Don’t do it. Fix the real problems. If you don’t know how, ask and then follow the guidance provided. If you need more help, either retain it or get a scanner and start hardening.

4. Respect the law. Don’t beg me not to turn this over to law enforcement. I have to. I want to, if you are critical infrastructure or some other member of the high threat club. Fix your stuff and manage security appropriately if you’re a member of the club; or you deserve to explain to law enforcement why you declined. Either way, I am going to try and help you and everyone by making the report.

5. List a contact for security issues on your site. Please, when I do call, I need to know who to talk to. At the very least, let your reception folks know how to handle security calls. The last thing you want is for the attacker to continue to compromise your systems while I play in “Voicemail-Land” forever. Remember, help me help you.

Lastly, even if you don’t get this call, do your due diligence. Make sure that your systems are secure and that you have security processes in place. Retain someone to help you manage risk and perform validation. Work with them to create effective risk management techniques for your organization. Hopefully, you won’t be on the other end of the line tomorrow or the next day as I make my round of calls….

If you have any additional suggestions or comments on this approach, please feel free to drop a comment below. As always, thanks for reading and be careful out there.