Warnings About Financial Institutions and Derivatives

Risks of Financial Institutions
The nature of a financial institution is that there are a lot of ways to go to hell in a bucket. You can push credit too far, do a dumb acquisition, leverage yourself excessively---its not just derivatives [that can bring about your downfall].

Maybe it's unique to us, but we're quite sensitive to financial risks. Financial institutions make us nervous when they're trying to do well.

We're exceptionally goosey of leveraged financial institutions. If they start talking about how good their risk management is, it makes us nervous.

We fret way earlier than other people. We've left a lot of money on the table through early fretting. It's the way we are -- you'll just have to live with it.

Derivatives
The system is almost insanely irresponsible. and what people think are fixes aren't realy fixes. It's so complicated I can't do it justice here - but you can't believe the trillions of dollars involved. You can't believe the complexity. You can't believe how difficult it is to do the accounting. You can't believe how big the incentives are to have wishful thinking about values and wishful thinking about ability to clear.

People don't think about the consequences of the consequences. People start by trying to hedge against interest rate changes, which is very difficult and complicated. Then, the hedges make the [reported profits] lumpy. So they use the new derivatives to smooth this. Well, now you've morphed into lying. This turns into a Mad Hatter's Tea Party. This happens to vast, sophisticated corporations.

Somebody has to step in and say, "We're not going to do it - it's just too hard."

I think a good litmus test of the mental and moral quality at any large institutions [with significant derivative exposure] would be to ask them, "Do you really understand your derivatives book?" Anyone who says yes is either crazy or lying.

It's easy to see [the dangers] when you talk about [what happened with] the energy derivatives - they went kerflooey. When [the companies] reached for the assets that were on their books, the money wasn't there. When it comes to financial assets, we haven't had any such denouement and the accountings hasn't changed so the denouement is ahead of us.

Derivatives are full of clauses that say if one party's credit gets downgraded then it has to put up collateral. It's like margin - you can go broke [just putting up more margin]. In an attempt to protect themselves, they've introduced instability. Nobody seems to recognize what a disaster of a system they've created. It's a demented system. 

In engineering people have a big margin of safety. But in the financial world, people don't give a damn about safety. They let it balloon and balloon and balloon. It's aided by false accounting. I'm more pessimistic about this than Warren is.

Accounting for Derivatives
I hate with a passion GAAP [Generally Accepted Accounting Principles] as applied to derivatives and swaps. JP Morgan sold out to this type of accounting to front-end revenues. I think it's a disgrace.

It's bonkers, and the accountants sold out. Everyone caved, adopted loose [accounting] standards, and created exotic derivatives linked to theoretical models. As a result, all kinds of earnings, blessed by accountants, are not really being earned. When you reach for the money, it melts away. It was never there.

It [accounting for derivatives] is just disgusting. It is a sewer, and if I'm right, there will be hell to pay in due course. All of you will have to prepare to deal with a blowup of derivative books.

Likelihood of a Derivatives Blowup
We tried to sell Gen Re's derivatives operations and couldn't, so we started liquidating it. We had to take big markdowns. I would confidently predict that most of the derivatives books of [this country's] major banks cannot be liquidated for anything like what they're carried on the books at. When the denouement will happen and how severe it will be, I don't know. But I fear the consequences could be fearsome. I think there are major problems, worse than in the energy field, and look at the destruction there.

I'll be amazed if we don't have some kind of significant [derivatives-related] blowup in the next five to ten years.

I think we're he only big corporation in America to be running off its derivative book.

It's a crazy idea for people who are already rich -  like Berkshire - to be in this business. It's a crazy business for big banks to be in.

Yo would be disgusted if you had a fair mind and spent a month really delving into a big derivative operation. You would think it was Lewis Carroll. You would think it was the Mad Hatter's Tea Party. And the false precision of these people is just unbelievable. They make the worst economics professors look like gods. Moreover, there is depravity augmenting the folly. Read the book F.I.A.S.C.O., by law professor and former derivative trader Frank Partnoy, an insider account of the depravity of derivative trading at one of the biggest and best-regarded Wall Street firms. This book will turn your stomach.

Skein is our submission (myself and seven others: Niels Ferguson, Stefan Lucks, Doug Whiting, Mihir Bellare, Tadayoshi Kohno, Jon Callas, and Jesse Walker). Here's the paper:

Executive Summary

Skein is a new family of cryptographic hash functions. Its design combines speed, security, simplicity, and a great deal of flexibility in a modular package that is easy to analyze.

Skein is fast. Skein-512 -- our primary proposal -- hashes data at 6.1 clock cycles per byte on a 64-bit CPU. This means that on a 3.1 GHz x64 Core 2 Duo CPU, Skein hashes data at 500 MBytes/second per core -- almost twice as fast as SHA-512 and three times faster than SHA-256. An optional hash-tree mode speeds up parallelizable implementations even more. Skein is fast for short messages, too; Skein-512 hashes short messages in about 1000 clock cycles.

Skein is secure. Its conservative design is based on the Threefish block cipher. Our current best attack on Threefish-512 is on 25 of 72 rounds, for a safety factor of 2.9. For comparison, at a similar stage in the standardization process, the AES encryption algorithm had an attack on 6 of 10 rounds, for a safety factor of only 1.7. Additionally, Skein has a number of provably secure properties, greatly increasing confidence in the algorithm.

Skein is simple. Using only three primitive operations, the Skein compression function can be easily understood and remembered. The rest of the algorithm is a straightforward iteration of this function.

Skein is flexible. Skein is defined for three different internal state sizes -- 256 bits, 512 bits, and 1024 bits -- and any output size. This allows Skein to be a drop-in replacement for the entire SHA family of hash functions. A completely optional and extendable argument system makes Skein an efficient tool to use for a very large number of functions: a PRNG, a stream cipher, a key derivation function, authentication without the overhead of HMAC, and a personalization capability. All these features can be implemented with very low overhead. Together with the Threefish large-block cipher at Skein core, this design provides a full set of symmetric cryptographic primitives suitable for most modern applications.

Skein is efficient on a variety of platforms, both hardware and software. Skein-512 can be implemented in about 200 bytes of state. Small devices, such as 8-bit smart cards, can implement Skein-256 using about 100 bytes of memory. Larger devices can implement the larger versions of Skein to achieve faster speeds.

Skein was designed by a team of highly experienced cryptographic experts from academia and industry, with expertise in cryptography, security analysis, software, chip design, and implementation of real-world cryptographic systems. This breadth of knowledge allowed them to create a balanced design that works well in all environments.

Here's source code, text vectors, and the like for Skein. Watch the Skein website for any updates -- new code, new results, new implementations, the proofs.

NIST's deadline is Friday. It seems as if everyone -- including many amateurs -- is working on a hash function, and I predict that NIST will receive at least 80 submissions. (Compare this to the 21 submissions NIST received -- five were rejected as not being complete -- for the AES competition in 1998.) I expect people to start posting their submissions over the weekend. (Ron Rivest already presented MD6 at Crypto in August.) Probably the best place to watch for new hash functions is here; I'll try to keep a listing of the submissions myself.

The selection process will take around four years. I've previously called this sort of thing a cryptographic demolition derby -- last one left standing wins -- but that's only half true. Certainly all the groups will spend the next couple of years trying to cryptanalyze each other, but in the end there will be a bunch of unbroken algorithms; NIST will select one based on performance and features.

NIST has stated that the goal of this process is not to choose the best standard but to choose a good standard. I think that's smart of them; in this process, "best" is the enemy of "good." My advice is this: immediately sort them based on performance and features. Ask the cryptographic community to focus its attention on the top dozen, rather than spread its attention across all 80 -- although I also expect that most of the amateur submissions will be rejected by NIST for not being "complete and proper." Otherwise, people will break the easy ones and the better ones will go unanalyzed.

I find that legacy code poses a unique challenge for organizations rolling out a new security process.  Often, the resources dedicated to maintaining older code are a small fraction of those devoted to new features or products.  Furthermore, the original developers for such features have often moved on, leaving no subject matter experts to drive reviews.  The astute reader will ask “How do I apply the principles of the Microsoft SDL to legacy code when I have no development resources and nobody knows how it works?”

The answer is “Start small, and build expertise over time.”

A Rising Tide Lifts All Boats

The best thing a security engineering team can do to improve security in the short term is to drive code quality, and the first step in this process is to define and enforce a secure coding standard.  This helps on two fronts: 

1.       It will improve code quality and reduce implementation flaws across the entire code base.  Unlike other security processes, driving a secure coding standard is relatively easy to accomplish across an entire code base, regardless of the code’s age, by a focused security team.  That is not to say that it is easy without qualification – a large batch of spaghetti code will require a lot of work to untangle!  Such an effort can only be called “easy” when compared to, say, comprehensive identification and remediation of design flaws across legacy features.  Even so, improving code quality through the use of secure coding standards offers a unique combination of high impact, applicability to features, and ability to be carried out by a core team that makes it a sensible first step.

2.       The security team might notice that some sections of code have more standards violations or outright flaws than others.  This is an instance of vulnerability clustering, a concept that has been used to predict vulnerability rates and improve quality in the functional realm.  The evidence is anecdotal, but it stands to reason that portions of code that consistently violate secure coding standards are good places to start looking for other classes of security flaw.  These are security hotspots, and should be high on the prioritized list for further review.

Security testing may also be applied to legacy code, but initial activities should be considered on a case-by-case basis based on the expected return on investment.  Such testing ranges from using inexpensive off-the-shelf tools to exercise common interfaces to rather expensive custom testing and formal analysis.  It is worthwhile to begin with off-the-shelf tools, such as those that target file parsers or web applications, and tools created as part of your greater secure development efforts.  These can help identify easily-found flaws and suggest improvements to the coding standards.  Comprehensive security testing, on the other hand, is best tackled after the Legacy Security Push.

The Legacy Security Push

Coding standards and basic testing provide bang for the buck, but formal security processes seek to provide security assurance.  The challenge for legacy code is that it needs to play catch-up.  Security processes that occur early in the development cycle, such as requirements analysis, design review, and threat modeling, are particularly difficult to achieve years after the fact.  The main goal of the Legacy Security Push is to create the deliverables from these efforts, the most important of which are security requirements and a full risk analysis.

It may sound trivial, but security requirements are essential.  Not only do they define proper operation for the system in question, they also define assumptions that are suitable for relying systems.   It is very common to find security flaws in legacy systems that arise from well-intentioned but incorrect assumptions such as “I assume that the Foo authenticates server Bar when initiating a bank transfer.”  It stands to reason that Foo would do so for such an important activity, but this assumption must be validated.  It is very common for older features to have been deployed in and written for different environments where the security assumptions that are "obvious" today just didn't apply at the time.

When reviewing legacy systems, the first step is to identify such requirements.  If the original architects, developers or managers are available, they can provide valuable insight at this stage.  More often than not this is not the case, and analysis must instead rely on what documentation is present and interaction between the software and its consumers.  The goal is the same as in requirements analysis during project inception, except that in this case one must turn the process on its head and reverse engineer requirements from system behavior.  At the conclusion of this effort, requirements can be theorized – “Foo must authenticate its server Bar before initiating a bank transfer.” 

Risk analysis can be performed once a plausible set of requirements have been identified.  Threat modeling is a more structured means of performing such an analysis, with the eventual goal of identifying means by which requirements can be violated by an attacker. 

As with requirements analysis, original developers would be a valuable resource to consult.  With or without such help, the first step is to identify how the software works.  In many cases, help is not available and performing this task requires a great deal of effort.  For features of moderate size, this author has spent upwards of a month reading code, using process profiling tools, and walking through the software with a debugger to identify program flow and security-sensitive functionality.

Once completed, actual system behavior should be documented and compared against the requirements theorized.   It might be that the requirements should be re-evaluated (New requirement:  Do not assume that Foo requires server authentication) or the system may need to be changed (New bug:   Foo does not verify the CN for Bar).  At the end, this information should be sufficient to support a comprehensive threat modeling exercise where security requirements, risks, and their mitigations can be documented.

Next Steps

Bringing a legacy feature up to par with its newer kin requires a relatively small number of items:  improved code quality, clear security requirements, and a thorough threat model.  As we have seen, performing even these tasks is quite the effort!  I am sure that it is little comfort to be reminded that accomplishing these tasks has simply laid the foundation, and that the true benefit is that the newly-reviewed legacy feature is able to participate fully in the security processes that remain: reviewing cross-component security requirements and assumptions, comprehensive testing, and incident planning, to name a few.

Unfortunately, there is no silver bullet in security assurance.  The soundness of the design and implementation of legacy software is just as important as in newer software, which is why any complete secure software development process will look backwards as well as forwards.  Feature by feature, from higher priority to lower, the overall security of the software improves as legacy code receives the full security treatment it deserves.

Sounds like the beginning of a joke, right?  So these two guys walk into a bar…

“The” Bruce Schneier and Marcus Ranum have an article up on TechTarget/Information Security Magazine called, creatively enough, “Bruce Schenier, Marcus Ranum debate risk management“.

Unfortunately, to get to the article, you’ll have to either already be a subscriber to IT Security, a subscriber to TechTarget, or go through the 20 minute process of signing up by giving TechTarget all sorts of “market information” about how you’re really Brandon Walsh, CSO of “The Peach Pit” Industries in Beverly Hills, CA 90210 (phone 714-867-5309).

For those of you who are already a TechTarget person, the link is above.  For those who aren’t, or those who just don’t have the time, I’ll summarize.  The “debate” is kind of awkward because both authors seem come to the same conclusion:

Risk Management, it’s something our profession should do, something humans do naturally, it’s necessary in business, but gosh - we don’t have enough data.

I’m not a cryptographer.  I don’t *nearly* have the insight on privacy and politics that Bruce has.  I’m not deep in IP communications.  I haven’t got a proven track record of innovation in IP Security products like Marcus has.  But here’s the thing, I hope you’ll never hear me pretend that I have the skill set to speak authoritatively on those subjects.  Heck, I wouldn’t claim to be a “risk” expert because I have a some insight into my shortcomings and what is needed to tackle such a complex problem.  But such a tepid article on something that (at least I think) is so important kind of, well, confuses me.

Why is it such a boring article?  I’m not sure.  Maybe because they’re just two guys who would rather debate the merits of specific controls or control activities (after all, their penetration testing debate was a huge success), but there’s no new information in the “debate”.  It’s the same old “insurance companies know risk because they have scads of data and we don’t have that” complaint. You know what?  I’m tired of hearing that line, so let’s talk about it.

HOW DO YOU KNOW WE DON’T HAVE THE AMOUNT OF DATA WE NEED TO DO RISK MANAGEMENT WELL?

Not particularly picking on Marcus, but in the article he uses the common complaint, “We lack the data to do risk management well.”  This mantra is repeated to the point where I’m blase’ about it.  But for some reason, this sentence really jumped out at me this time for two reasons.  It made me ask:

1.)  How do you know we don’t have the proper amount of data?

2.)  Can we even define “well” (i.e. what “good” risk management is) yet?

I really don’t know that the industry, especially concerning IT risk, is mature enough to really conclude that we don’t know (in the case of the former), nor that we can define (latter), conclusively.

PLAYING THE CONTRARIAN

Just because I’m feeling kind of zany this morning, let me suggest something.  Maybe there actually is lots of evidence out there for us to use.  Maybe:

1.)  It’s just that we don’t have particularly good models that provide context.

2.)  When that evidence isn’t an obvious phenomena that lends itself to easy measurement, we throw our hands up in disgust and fall back on “lack of data”, “can’t quantify risk”, “best practices work just fine” or any other number of arguments, no, excuses we use to justify our inability to be precise about the past (more or less the present or future - apologies to Niels Bohr).

IT’S IN THE WAY THAT YOU USE IT

Now I actually am happy to acknowledge that we don’t have enough data to be precise.  You, me, even smart guys like Marcus and Bruce - we’ll never be able to “engineer” risk management.  But you know what?  Neither can Insurance companies.  Sure, there are plenty of places where they have enough data to apply a traditional frequentist approach to risk valuations.   But there are plenty of times Insurers actually insure and they don’t have centuries or decades of data.  There are plenty of times when they rely on the “estimates” of subject matter experts.  There are many times they have enough information to be accurate rather than precise, and that’s good enough for them.

For that matter, it’s worth noting that there are plenty of scientific disciplines that have to deal in imprecise prior information, or evidence that’s fraught with uncertainty (what Ranum calls “squishy”, and what I’ve heard real honest to goodness physicists call “noisy”).  Unfortunately, we’re going to be like them.  Until we can read minds and predict the future, there will always be uncertainty in our measurements and posterior conclusions.  The trick is in how you deal with it and express it.  And while I really don’t know how much time Marcus or Bruce have really spent in the deep end on the subject of risk and its management - I have seen people doing brilliant things around risk (though they just aren’t mainstream).  Whether the tools are Bayesian methods, Monte Carlo engines, reductionist models of complex problems, there are risk analysts trying to deal with the problem.  These analysts are applying scientific method(s) and developing reasonable approaches to a very complex problem.  There are people trying, and our body of knowledge is growing, growing well beyond “gee, I haven’t got an obvious solution so I’ll blame it on lack of data”.  Heck, I’ve seen readers of this blog suggest Douglas Hubbard’s book in other security forums!*

I’VE GOT YOUR DATA RIGHT HERE…

But we don’t have enough data?  I have to ask, how much more do we need?  I mean crikey, JPMC just visited our ISSA chapter claiming, like, a bajillion events an hour.  There’s not one, but several companies out there that will want to tell you about how they have deep “insight” into the attacker community.  The boundaries of IT Risk losses are pretty well established by events that happen to public companies.  We have pretty mature testing/assessment tools and methodologies now that help us test our ability to resist the force an attacker can apply to us.  So what part of the Threat Landscape, Asset (Controls) Landscape, or Loss Magnitude landscape is too incomplete (and what are you doing to find the information you need)?

SO WHY DO WE FAIL?

Which brings me to a final, somewhat depressing conclusion.  Maybe there’s data, and maybe we’re starting to see the means to use it.  But in the end I do have to agree with Marcus that the vast majority of the infosec world *is* doing a really, really bad job with regards to “risk” and “risk management”.  The majority of people I know consider GRC to be a cruel, expensive joke.  Risk Assessment Methodologies tend to be built on the faulty premise that if we create a repeatable process, our measurements and conclusions will magically become accurate and wise.  Risk models tend to be factors loosely measured by ordinal scales and then somehow “multiplied” together to create a relatively meaningless qualitative value.  The State of the Union here is not good.  But after reading such a superficial treatment of an important and complex subject, I am left wondering if Bruce and Marcus were the right people to write about risk management in a mainstream publication.  As Inspector Callahan says, “A man’s got to know his limitations.”

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* Speaking of which, if you want to do one cost effective thing to address your uncertainty - go find Douglas Hubbard’s book. It’s even got a nice recommendation from Peter Tippett.  The book is called “How To Measure Anything” - the title sounds rather hyperbolic, but there are good techniques in it we can use to identify useful information and refine our ability to frame that qualitative information into quantitative values. The key is how Hubbard has you deal with your uncertainty.  For those of you who are more scientific minded and want to dig deep into the subject, I have on good authority that E.T. Jaynes “Probability Theory, The Logic of Science” is a rather under appreciated work.

Yesterday, they posted a terrific blog post about what they saw at Interop. Fortunately, ScienceLogic was one of the technologies that they highlighted from the show. I have written earlier posts about how difficult it has been to gain smart, insightful coverage for our solutions with technology media.

I have to say that they really got it! And it feels so good. We know that we have a bit of a hidden gem of a product here at ScienceLogic and will be working overtime in the coming months to take our business and products to a “Blue Ocean” environment that will shock and surprise many others in the media. However Sevick and Wetzel will be amongst the first to get a close-up on why and how we will deliver a new paradigm to this marketplace in 2009!

A few excerpts from their post:

“We noticed yet more specialty network management vendors, leading us to wonder how the market can support such a plethora of them, and we felt empathy for IT teams that have to master yet more interfaces.”

“Application performance management and application acceleration vendors were well represented. Such products play well in today’s climate because they allow enterprises to get the most out of existing IT investments instead of buying more “stuff”. One particularly interesting vendor we talked to was ScienceLogic. They are integrating IT infrastructure and application monitoring into a single, not-very-expensive platform that will serve mainstream business well. This is smart, and we predict they will give the CA’s, BMC’s, HP’s and IBM’s of the world a run for their money.”

Check out the blog post here and keep App Performance View on your radar..

Pouring over endless details of risks, regulations, taxonomies, and technologies can sometimes give us a narrow view of the world, so it seems worthwhile to take a minute to mark the 125th anniversary of the cataclysmic eruption of Krakatoa this week. For those of us that want to think big but can’t remember that far back, this week is also the 3rd anniversary of Hurricane Katrina’s devastating sweep across a wide stretch of the US Gulf Coast.

By now, I expect that most of you have read or are familiar with the 2007 book, The Black Swan, by Nassim Nicholas Taleb, which argues that these kinds of unpredictable, outlying occurrences are the ones that really shape businesses, countries, economies, and people. Taleb argues that although these “Black Swan” events are almost completely unforeseeable, we mistakenly try to explain the circumstances at the time and make predictions about similar events in the future.

In my ERM work with clients, and especially in the context of research I’ve been doing with my colleague Stephanie Balaouras on business continuity and resiliency, questions come up about how to plan for catastrophes... and they’re good questions. Were the CardSystems or TJX data breaches foreseeable? What about the Societe General debacle or the 2004 Indian Ocean tsunami? What’s next? Should these types of events be included in our risk assessments?

We’d like to get your opinion on these and other risks that may be on the very edge of the statistical tail. At what point do they belong in your risk register?

Of course, it’s possible to define mitigating controls for crises, disasters, or incidents without knowing for sure what they’re going to look like. That’s one of the hallmarks of a good crisis management plan. And that’s an important point, because trying to predict the next unforeseeable event can be a real challenge sometimes.

Corruption, intimidation, robbery, violent assault, forgery, large-scale fraud. No, not the subject of the latest John Grisham novel, but sensational allegations, made public Apr. 4 by Hermitage Capital Management -- until recently the largest foreign portfolio investor in Russia. In a detailed and damning report, titled Criminal Justice -- Russian-Style, Hermitage alleges the fund's Russian subsidiaries have fallen victim to an elaborate con designed to defraud the fund of hundreds of millions of dollars. 
  
The most sensational part of Hermitage's allegations is that the attempted larceny was carried out with the direct connivance of officials in the Russian police. Hermitage alleges the police seized documents and equipment that were instrumental to the attempted fraud, which involved bogus court cases based on forged documents, the aim of which was to sue Hermitage subsidiaries for hundreds of millions of dollars. "The most shocking thing is not that there are corporate raiders in Russia who attempt to steal your shares," says Jamison Firestone, managing partner of Firestone Duncan, Hermitage's law firm. "The shocking thing is that the police worked hand-in-hand with them, and actually performed the theft of the documents so that the corporate raiders could then do their work."

So the two-pronged scam worked in one area and failed in another. The perpetrators weren’t able to steal the assets from us based on the fake court claims, but they were able to steal $230 million from the Russian government by filing amended tax returns on behalf of our stolen companies. What makes this story even more shocking is that we filed six 255-page criminal complaints with the Russian authorities in December last year, one month before the tax fraud took place, and they did nothing to stop it. Two complaints were sent to the Russian General Prosecutor, two to the Russian State Investigative Committee and two to the Internal Affairs Department of the Interior Ministry. There was enough information to prevent the fraud and indict a number of people behind it if the government had acted. 

Instead of doing anything to save the Russian state from this highly sophisticated and organized looting, two of our complaints were thrown out immediately; two were returned to the same Interior Ministry official we were complaining about (essentially, he was being asked to “investigate himself”); and one was thrown out for “lack of any crime committed.” Only one complaint was taken seriously. It was taken up by the Russian State Investigative Committee in early February, but before it could get any traction, the case was lowered to the South region of the Moscow district of the State Investigative Committee (the lowest level of the Committee) and by June, another senior Interior Ministry official whom we had named in our complaint had joined the “investigation” team (again, to “investigate himself”). To this day there has been no serious response by the Russian authorities to this massive fraud against the Russian state. 

As we described in our April letter, the problem of corporate “raiding” is now so endemic in Russia that President Medvedev speaks about it as one of the biggest problems faced by Russian businesses. In this case, raiders have taken this problem to a new and absurd extreme by “raiding” the Russian state itself and so far getting away with it. Together with HSBC, we will shortly be filing new criminal complaints with the Russian General Prosecutor and Russian State Investigative Committee as well as with many law enforcement authorities outside of Russia. It is hard to predict what will happen next in this unfolding and unbelievable saga, but as always we will keep you updated on any further developments as they arise.

Of course we see individual identity theft on a regular basis (actually as Ross Anderson points out its not really identity theft but poor controls on the bank's parts using SSNs as secrets and so on), but you dont see a major corporation stolen every day.