doc format

Awareness Program on Compliance in the Era of

Technology

ICAI, MumbaiOctober 19, 2008

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Agenda

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1. Compliance Today

2. Business Risks

3. Evolving Security and Compliance landscape

4. Technology and IT value for business

5. Incidents and Security related industry information

6. Snapshot of Global Compliance requirements over time

7. Extracting Compliance ROI

8. Suggested Safeguards (unified framework)

9. Common regulatory reqmts (standards, etc)

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10. The technology solution

11. Compliance spotlight – PCI-DSS

12. Leverage the technology solution

13. VA/PT

14. Continuous VA and Monitoring

15. List of Tools

16. Why VA/PT

17. Web App Security, Secure Coding

Compliance Today


• Technology is constantly evolving providing new tools and methods to tackle the increasing information and compliance overload

Much of the increase in cost is due to duplication of regulation and ambiguous or inconsistent rules

-Securities Industry Association, 2006

• Organizations have numerous Compliance requirements which keep growing by the day / hour / minute !– Regulatory– Standards / Best Practice Frameworks – Industrial, Contractual, etc.

Compliance Today


• Compliance with Compliance requirements takes up too much resources

• Compliance initiatives are considered “Projects” (e.g. SOX / PCI project) but these are continuous processes (benefits are not realized)

• Technology solutions will leverage Compliance efforts to enable Governance and Risk Management leading to Business gains (productivity, cost-savings)Compliance must be part of your organization DNA

Regulatory Compliance is not just a legal requirement but a critical business function.

Business Risks Operational risk

Physical damage/theft Services not available

Market risk Lost customers Global partners

Legal risk SLAs Lawsuits

Regulatory Compliance

Financial Risk Claims and losses Quantification of information

assets/impact


Information on your network

Databases Intellectual Property Financial Information Personally Identifiable

Information Reputation & Market

Value

What is at Risk

Technology and Information Made People Smarter

Google

Luhn’s algorithm (to validate any credit card)

VB based basic key loggers

Web based IP tools, DNS network tools, traceroute etc

Network tools

Nmap

Nessus etc…. All available online

Password cracking tools


Incidents (2000-2007)

According to Attrition Data Loss Archive and Database and FlowingData, following are the 10 largest data breaches since 2000 (http://flowingdata.com/2008/03/14/10-largest-data-breaches-since-2000-millions-affected/)

Is there a trend? Yes, numbers are growing!


Are we safe in 2008? UK Government Depts. reported loss of 29 million records in

last one year (August 2008) Countrywide Financial Corp. – possible all 2 million records were

sold (August 2008) If sensitive data only includes SSNs and financial account data

and not date of birth and email ids then should we decide Facebook’s 80 million records as a data breach? (July 2008)

Bank of New York Mellon, PA – as many as 4.5 million customer records are thought to be compromised (March 2008)

Compass Bank – 1 million (March 2008) Hannaford Bros. supermarket chain – 4.2 million (March 2008)

Trend – Numbers are still growing!


Some Facts Who are behind these breaches:

External sources including past employees Insiders Business partners Multiple parties

How these breaches are caused Business process errors or no policy/procedural controls Hacking and intrusions including malicious code System/Application vulnerabilities including for those patches already

exist Physical threats

Mostly……… Victims don’t know that breach has occurred or more often aware of the

criticality of the data/information Mostly breaches are opportunistic in nature

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Some Insights – drivers for security spend


By 2008, more than 75% of large and midsize companies will purchase new compliance management, monitoring, and automation solutions.

By 2009, compliance will grow to 14.2% of IT budget from 12% in 2006.

Source: Gartner 2007

Common Regulatory Reqmts /Standards / Frameworks / Guidelines


Clause 49 (SEBI Guideline, Government of India)

CTCL ISO:27001 – 2005

133 Control objectives PCI-DSS

12 requirements CobiT NERC-CIP BS:25999 ITIL Data Protection Act IT Act and applicable

Criminal / Civil legislation

HIPAA/GLBA Sarbanes Oxley Basel II PCAOB SAS 70 Privacy Laws (e.g.PIPEDA) … many more…..

Extracting Compliance ROI


Organizations must plan beyond Compliance Better Security means reduced / managed risk Managed (reduced) risk means better business Operational efficiencies result from compliance efforts Approach Compliance as a as a business process, not as

requirement / overhead Use learning to shorten future compliance cycles Identify opportunities to build unified compliance ecosystem Lead the organization to Industry certifications resulting in higher

brand value

Eliminate the risk of penalties for non-compliance Address multiple compliance requirements in a unified

approach


Suggested Safeguards

Technology Solution


Systems must be developed providing a risk based approach that is aligned with Business, Regulatory and Contractual requirements

Leverage technology and co-ordinate Security spend with Compliance with the overall objective achieve Governance (automation)

Technology practices to enable proactive security Risk management Vulnerability Assessment / Penetration Testing (VA/PT) Web Application Security (AppSec) Code Review Continuous Vulnerability Management Managed Security Services

Compliance Spotlight :PCI – Data Security Standard


Requirement 5 and 6 (Maintain Vulnerability Management Program) Stay Current on versions (Anti Virus, Patches, Systems,

Configuration) Monitor Custom Web applications SDLC (do we practice secure coding) Invest in automated tools Secure Audit Logs

Requirement 10 and 11 (Regularly Monitor & Test Networks) Monitor Systems for Intrusions and Anomalies Implement Reporting and Analysis Tools Centralize and Secure Data


Compliance Spotlight :PCI-DSS

ISO:27001 – A.12.6 Technical Vulnerability Management

ISO:27001 – A.15 Compliance-Compliance with Legal Requirements-Compliance with Security Policies, and standards and technical compliance


Leverage the Technology Solution



Vulnerability Assessment

(VA)

Penetration Testing

(PT)

Results allow the organization to compare findings against known vulnerabilities and prioritize remediation by implementing controls. Provides a health report on the organization security posture. All Standards, Regulations, Frameworks recommend (or require) Network Assessments as an essential practice. Helps determine whether the controls are in fact preventing the vulnerability from actually endangering the network. A well-executed penetration test can identify the most critical holes in an organization’s defensive net; including the holes exploited by social engineering. pen tests are best used as a way to get an extra set of eyes on a network after major system upgrades.



Continuous Vulnerability Monitoring

and Assessment

Provides a 24 x 7 x 365 watch on network traffic and is available as a Managed Security Service. Traffic is monitored and events (incidents) are correlated against updated industry Common Vulnerability & Exposure (CVE) database.

Reports are available online to client via a web interface which will provide information about the threat(s) and remediation plans.


VA/PT

Undertaken by qualified professionals Methodology includes use of automated tools augmented with manual skillsMeet regulatory requirements (PCI-DSS, HIPAA, GLBA, PIPEDA, etc.) Organizations can realize their true security level Measure IT security effectiveness Identify and remediate potential breach points reducing security risk and liability Benchmark / baseline security posture

Certifications Certified Vulnerability Assessor (CVA) (Secure Matrix -

DNV)CEH (EC Council)CISSP (ISC2)certifications in Forensics, Fraud (Secure Matrix)

Commonly used Tools for VA/PT (commercial / open source)Nessus, GFI Languard (c), Nmap; Metasploit, Canvas (c),

etc.


Vulnerability Assessment

Nessus Nessus is one of the most popular and widely used vulnerability assessment scanner with nearly 14,000 plugins.

GFI Languard GFI Languard is a commercial vulnerability assessment scanner with neat reporting capabilities.

Netcat Netcat is a network debugging and exploration tool

Hping This tool is particularly useful when trying to traceroute/ping/probe hosts behind a firewall that blocks attempts using the standard utilities. This is to map out firewall rulesets.

Nikto A comprehensive webserver scanner

Sam Spade Windows network query tool

Web Inspect Web Application Scanner

Firewalk An Advanced traceroute tool

Penetration Testing

Metasploit Framework This is a framework to deploy vulnerability exploits and payloads. Securematrix has created a database of nearly 100 exploits in this framework

Canvas A Commercial Penetration Testing tool

Core Impact A Commercial Penetration Testing tool

SAINT A commercial Penetration Testing tool

CenZic A Commercial Web application testing tool

John the ripper powerful, flexible, and fast multi-platform password hash cracker

THC Hydra A Fast network authentication cracker which support many different services

Dsniff A suite of powerful network auditing and penetration-testing tools

Solarwinds Network discovery/monitoring/attack tools

List of Tools (indicative)


Why VA/PT

To catch a thief….. You have to think like one. You hack into your network to do a Vulnerability

Assessment (VA), identifying “vulnerabilities” in the same manner as they may be visible to an intruder like open ports.

Following up a VA is the Penetration Test – you are taking advantage of the ‘vulnerabilities’ by “penetrating” the network.

When you test all IP addresses that are visible to the outside world you can get answers to sticky questions like:

Can an intruder hop on to the conference room network ?

Is it possible for the intruder to connect to the database server ?

What can you do (that which no one wants an intruder to do!) ??

Presented by


Dinesh BarejaCISA, CISM, ITIL, IPR, ERM, BS: 7799 (Imp &

LA)

- Senior Vice President

Email: [email protected] Security professional, having more than 11 years of experience in technology in commercial, operational, functional and Project Management roles on multiple large and small projects in global and domestic markets. Experienced in establishing ISMS (Information Security Management System), planning and implementation of large scale CobiT® implementation, ISO: 27001, Risk Management,

BCP/DR, BIA, Asset Management, Incident Mgt, Governance and Compliance among others. He is also member of ISACA, OCEG, iTSMF and co-founder of Canadian Honeynet Project and Open Security Alliance among others.

Contact Information

Registered OfficeMumbai:

12 Oricon House, 14, K. Dubash MargFort, Mumbai 400 001

Tel: +91 22 3253 7579; Fax:+91 22 2288 6152; Email: [email protected]

Technology CentrePune:

Trident Towers2nd Floor, Pashan RoadBavdhan, Pune - 411021

Email: [email protected]

Technology CentreChennai:

Plot No. 1, Door No. 5, Venkateshwara Street, Dhanalakshmi Colony, Vadapalani,

Chennai – 600026Email: [email protected]

Dubai:P O Box 5207

DubaiEmail: [email protected]

London:16-20 Ealing Road

Wembley Middlesex Hao 4TLEmail: [email protected]


Bahrain * Atlanta

mailto:[email protected]


Thank You

ICAI, Mumbai