The opening remarks included another great cartoon from Atsec, a tribute to the new ACVP (Automated Certificate Validation Program) - very funny!
Matt Keller gave us an update on the CMUF (Crypto Module User Forum). They have several working groups that are contributing to new implementation guidance from NIST. Their goals are to share information and help move the standards forward. NIST also comes and gives updates, and the forum provides a way to share ideas and suggestions on navigating a validation.
Mary Ann Davidson, Chief Security Officer, Oracle Corp., "Keeping Up with the Joneses". When Ms. Davidson started in security, nobody cared (except PTLGA - Paranoid Three Letter Government Agencies). There was hardly any 3rd party software, except for crypto. Nobody cared, so it was a quiet job - like the Maytag repair man....
But things are changing. SW and HW are ubiquitous - you can even have an Internet connected fridge. 66% of applications code is now open source... need to keep up and understand the landscape.
We need to keep up with new threats, market expectations, latest regulatory FDJ (framework du jour) and changes in the industry.
Hackers are moving towards hardware, so her ethical hacking team is focusing now on HW in addition to their SW work. HW hacking combined with IoT has greatly increased our area of attack.
Regulatory frameworks should not be tied to a specific technology or vendor. ("regulatory capture" - not a good thing).
Looking at market expectations - 3rd party code enables scarce resources to be used on innovation, not "building blocks" (ie cutting down trees to build your own house...). But, this creates a target for a hacker. Everyone loves free code, but nobody wants to invest in making it better.
Vendors need to know what is in their code - beware of 3rd party code that pulls in other code... need to understand it all. Should have fewer instances of 3rd party libraries in their code to minimize attack surfaces and simplify and lower cost of upgrade. That is, don't have 48 copies of one 3rd party library - have a central copy.
Department of Commerce (DoC) is working on a Software Bill of Materials - you will have to know, as a vendor, what is in your SW. But what does that buy you? Customers typically cannot replace third party libraries in code - they have a binary, or license forbids. Also, just having the vulnerable code doesn't mean you are using it in a vulnerable way. Lots of resources spent upgrading, even though it is irrelevant. Veracode noted that 95% of Java vulns in 3rd party code are NOT exploitable in the context of the application...
What could we do instead? Be honest with your customers. Describe how we use the code. fix the worst issues the fastest. Need to have a way to teach the scanners about usage - ie - not vulnerable as being used.
Changes in industry can be distracting: "On prem/waterfall is so last year...". Need to keep the meaningful aspects as we move on, timelines still matter. We have to think about how long things like validations take - can't do all SW at the same time. Need to do the most relevant and do it as efficiently as possible.
We need cloud agility in certifications. NIST has 2 working groups looking at doing FIPS for crypto in the cloud, but we need to do it faster.
Perfect storm of increased regulatory scrutiny and increased use of technology has led to greater risk management inquiries. Need to asses relevant risk management concerns. You wouldn't want or need to inspect a day care provider's vacation home... not relevant.
People have asked Ms Davidson for things like: "we have the right to pen test any system in your network" "need patching status of every system in your network" ... etc.
This is problematic because it's not germane to her particular risk management concerns. For example, she's often asked about "3 day patching" - even though the person asking knows it's not possible, but they still want it in a contract...
Mary Ann apparently makes a really good rhubarb crisp, but she's not going to force it as a standard... so don't ask her to do a non-standard certification, either. (though you may want to have some of her rhubarb crisp....)
Vendors need to be more public with what they are doing, otherwise customers will assume you're not doing something. Set up clear rules of engagement - makes the questions more relevant and the discussions more fruitful. Keep in mind that anything vague will be misinterpreted - needs to be challenged.
Remember - change is inevitable, embrace it and OWN it. Don't let others own the change agenda, or you won't like the result. Use only globally accepted standards where feasible instead of one-off "wants". Economics rule the world - know it, use it, own it!
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