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Financial Services Law Insights and Observations

Buckley Insights: Leveraging open source intelligence for cyber threat modeling

Privacy/Cyber Risk & Data Security Data Breach FTC OCC FFIEC

Privacy, Cyber Risk & Data Security

The FTC Safeguards Rule, FFIEC Cybersecurity and IT Guidance, and other OCC guidelines (here and here) emphasize the need for cyber threat intelligence (CIT) and threat identification to inform an organization’s overall cyber risk identification, assessment, and mitigation program. Indeed, to successfully implement a risk-based information security program, an organization must be aware of both general cybersecurity risks across all industries, as well as both business-sector risks and organizational risks unique to the organization. Furthermore, proposed revisions to the FTC Safeguards Rule (previously covered by InfoBytes here) emphasize the need for a “through and complete risk assessment” that is informed by “possible vectors through which the security, confidentiality, and integrity of that information could be threatened.”

Threat modeling is generally understood as a formal process by which an organization identifies specific cyber threats to an organization’s information systems and sensitive information, which provides the management insight regarding the defenses needed; the critical risk areas within and across an information system, network, or business process; and the best allocation of scarce resources to address the critical risks. Even today, generally an accepted threat modeling process involves comprehensive system, application, and network mapping and data flow diagrams. Many threat modeling tools are available free to the public, such as Microsoft’s Threat Modeling Tool, which provides diagramming and analytical resources for network and data flow diagrams, utilizing the STRIDE model (spoofing, tampering, repudiation, information disclosure, denial of service, and escalation of privilege) to inform the user of general cyber-attack vectors that each organization should consider. Generally, between cybersecurity frameworks, such as the NIST Cybersecurity Framework (for risk-based analytical approaches), and threat modeling tools identifying generic cyber threats such as STRIDE (for general or sector-specific cyber risks), an organization can achieve a risk-informed information security program.

However, with the increasing amount of large-scale data breaches occurring and with the evolving complexity of cybersecurity threats, many regulatory agencies and other industry-based standards institutions have called for a need to go one step further and understand the techniques, tactics, and procedures (TTPs) utilized by hackers using CIT. By using CIT and other threat-based models, organizations can gain insight into potential attack vectors through red-teaming and penetration testing by simulating each phase of a hypothetical attack into the organization’s information system and determine potential countermeasures that can be employed at each step of the kill chain. For instance, Lockheed Martin’s formal kill chain model involves seven steps (reconnaissance, weaponization, delivery, exploitation, installation, command and control, and actions on objective) and proposes six potential defensive measures at each step (detect, deny, disrupt, degrade, deceive, and contain). Consequently, an organization can layer its defenses along each step in the kill chain to increase the probability of detection or prevention of the attack. Kill Chain was used as part of a U.S. Senate investigation into the data breach of a major corporation in 2013, identifying several stages along the chain where the attack could have been prevented or detected.

This threat identification process requires greater detail on adversarial TTPs. Fortunately, MITRE has provided for public consumption its ATT&CK (adversarial tactics, techniques, and common knowledge) platform. ATT&CK collects and streamlines adversarial TTPs in specific detail and provides information on each technique and potential mitigating procedures, including commonly used attack patterns for each. For instance, one tactic identified by ATT&CK is to encrypt data being exfiltrated to avoid detection by data loss prevention (DLP) tools or other network anomaly detection tools and identifies more than forty known techniques and tools that have been used to achieve encrypted transmission. ATT&CK also identifies potential detection and mitigation options, such as scanning unencrypted channels for encrypted files using DLP or intrusion detection software. Thus, instead of a generic data breach risk analysis, organizations can understand specific TTPs that may make data breach detection and analysis more difficult, and possibly take measures to prevent it.

By leveraging open-source CIT from tools such as ATT&CK and other reports from third-party sources such as government and industry alerts, organizations can begin the process of designing proactive defenses against cyber threats. It is important to note, however, that ATT&CK can only inform an organization’s threat modeling, and is not a threat model itself; additionally, ATT&CK focuses on penetration and hacking TTPs and, therefore, does not examine other threats that organizations may face, including distributed denial of services (DDoS) attacks that threaten the availability of its systems. Such threats will still need to be accounted for in any financial organization’s risk assessment, particularly if such DDoS prevent its clients from accessing their financial accounts and ultimately, their money.

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