So where does this leave cyber security issues? 

In the paper, we propose a simple solution: take-down companies should share their raw, unverified feeds of phishing URLs with their competitors. Each company can examine the raw feed, pick out the websites impersonating their clients, and focus on removing these sites.

Since we presented our findings to the Anti-Phishing Working Group eCrime Researchers Summit, we have received considerable feedback from take-down companies. Take-down companies attending the APWG meeting understood that sharing would help speed up response times, but expressed reservations at sharing their feeds unless they were duly compensated. Eric Olsen of Cyveillance (another company offering take-down services) has written a comprehensive rebuttal of our recommendations. He argues that competition between take-down companies drives investment in efforts to detect more websites. Mandated sharing of phishing URL feeds, in his view, would undermine these detection efforts and cause take-down companies such as Cyveillance to exit the business.

I do have some sympathy for the objections raised by the take-down companies. As we state in the paper, free-riding (where one company relies on another to invest in detection so they don’t have to) is a concern for any sharing regime. Academic research studying other areas of information security (e.g., here and here), however, has shown that free-riding is unlikely to be so rampant as to drive all the best take-down companies out of offering service, as Mr. Olsen suggests.

While we can quibble over the extent of the threat from free free-riding, it should not detract from the conclusions we draw over the need for greater sharing. In our view, it would be unwise and irresponsible to accept the current status quo of keeping phishing URL feeds completely private. After all, competition without sharing has approximately doubled the lifetimes of phishing websites! The solution, then, is to devise a sharing mechanism that gives take-down companies the incentive to keep detecting more phishing URLs.

Here is our stab at devising a suitable sharing mechanism. We propose the creation of a members-only sharing club with compensation for net contributors paid for by net receivers. Take-down companies submit real-time copies of their entire feeds to a trusted third party (for the sake of argument, let’s assume that the APWG takes on this role). The APWG collates the individual feeds, marks the source of each submission (i.e., which take-down company) along with a timestamp. The APWG makes the amalgamated feed available immediately to all members. The members pick out phishing URLs impersonating their own clients, while ignoring the rest. Crucially, the expensive task of verifying phishing URLs and initiating take-down continues to be performed by the take-down company.

Periodically, the combined feed is audited to determine the reciprocity of contributions. Take-down companies provide a list of their clients to the auditor. The auditor then computes the number of phishing websites impersonating each take-down company’s clients that are missed by the takedown company but identified by others. The auditor also tallies the time difference for phishing websites that are identified by others first.

For example, suppose bank A1 has hired take-down company A to remove phishing sites on its behalf, and bank B1 has hired take-down company B. Suppose 500 phishing sites impersonate A1, and that A identifies 400 while B identifies an additional 100 sites missed by A. Likewise, suppose another 500 phishing sites impersonate bank B1, and that B identifies 300 while A identifies an additional 200 sites missed by B. B has received a net of 100 useful phishing sites more from A than B has given to A. Consequently, B should pay A a previously-agreed ‘finder’s fee’ for identifying these extra 100 websites.

The ‘finder’s fee’ provides additional incentive for take-down companies to invest in better phishing website detection. Designed properly, such a sharing club can overcome the potential for free-riding that companies such as Cyveillance fret about, while increasing sharing to shorten phishing website lifetimes.

Some subtleties must be mentioned, however. If the finder’s fee is big enough, some companies may be tempted to cheat to minimize their payout. For instance, underperforming take-down companies could claim to have independently discovered missing data from their feed shortly after collecting it from the shared feed. This can be mitigated by adding a credible threat of detection — inserting a few dubious fake phishing URLs that only appear in the shared feed. If the company claims to have ‘independently’ rediscovered these URLs, then they will be caught cheating. Another issue is that the auditing system does incur some overhead, which could be avoided if sharing was made unconditional.

To sum up, we recognize that many take-down companies will be reticent to share. However, we feel that sharing is too important to the goal of tackling phishing to brush aside because of a few inevitable complications. For the good of protecting consumers, the anti-phishing industry should learn to co-operate!

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.”

===============================

* 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.

The announcement is of course Good News — because once the PCeU is up and running next Spring, it should plug (to the limited extent that £2 million a year can plug) the “level 2″ eCrime gap that I’ve written about before. viz: that SOCA tackles “serious and organised crime” (level 3), your local police force tackles local villains (level 1), but if criminals operate outside their force’s area — and on the Internet this is more likely than not — yet they don’t meet SOCA’s threshold, then who is there to deal with them?

In particular, the PCeU is envisaged to be the unit that deals with the intelligence packages coming from the City of London Fraud Squad’s new online Fraud Reporting website (once intended to launch in November 2008, now scheduled for Summer 2009).

Of course everyone expects the website to generate more reports of eCrime than could ever be dealt with (even with much more money), so the effectiveness of the PCeU in dealing with eCriminality will depend upon their prioritisation criteria, and how carefully they select the cases they tackle.

Nevertheless, although the news this week shows that the Home Office have finally understood the need to fund more ePolicing, I don’t think that they are thinking about the problem in a sufficiently global context.

A little history lesson might be in order to explain why.

Back in 1930’s, Bonnie and Clyde and other US bank robbers were using the new-fangled automobile to flee across state lines — creating jurisdictional problems as a result. The US solution was to make bank robbery (along with auto-theft and other related offences) into federal offences rather keeping them as state-specific infractions. In particular this meant that the FBI could provide federal level policing (tracking down and killing John Dillinger for example).

We have the same jurisdictional issues dealing with cyberspace, with criminals in one country fleecing consumers in another while using systems hosted in a third. The Convention on Cybercrime addresses part of the problem by trying to ensure international consistency where eLaws are specifically needed (which of course is only the case for small parts of eCriminality, fraud is fraud whether eEnabled or not). However, there is limited inter-jurisdictional co-ordination for eCrime investigations — for example Interpol (often incorrectly perceived to be international police force) merely keeps a large database and passes faxes from one place to another.

In practice, most cross-border investigations are done as “joint operations” and the jointness is usually very limited — one force does all the legwork and a liaison officer in the other country deals with local paperwork. There’s usually a quid pro quo element to these joint operations, for budgeting reasons if no other.

What isn’t happening, or at least only in a handful of very specialised areas, is any international co-operation in setting priorities or selecting cases to pursue. Every country is doing its own thing about eCrime, and there’s a widespread impression that any criminal who can operate from “across the state line” is essentially immune from serious investigation.

We identified this problem last year when we (Ross Anderson, Rainer Böhme, Tyler Moore and myself) wrote a report on Security Economics and the Internal Market for ENISA. It’s not an easy one to fix whilst politicians (and populaces) are unwilling to see “foreign” police officers operating in their country, and the establishment of a truly international “cyber police force” seems equally unlikely.

Our policy proposal to tackle the issue harks back to WWII’s SHAEF, which has morphed into similar arrangements within NATO. In essence liaison officers from multiple forces would sit around a single table, working with a central coordinator, to set policy and decide which investigations to pursue. They would then communicate back to their own countries, who have specifically budgeted to provide appropriate assistance. So it’s very like “joint operations”, but the scheme is multi-laterial, and has a true command and control function in the centre — who will quickly learn to shy away from politically sensitive topics and make a real impact on eCriminality.

To summarise then, a welcome to the Home Office for finally finding a small amount of funding for some country-wide ePolicing; but it’s well past time to be working on world-wide initiatives.