Monday, March 29, 2010

Continuous Monitoring Highlighted in Recommended FISMA Changes

Submitted by Ryan Barnett 03/29/2010

The SANS Institute's weekly NewsBites newsletter covered an important story last week with regards to proposed changes to the Federal Information Security Management Act (FISMA) which was presented at a House subcommittee meeting on March 24. The most important change is a shift towards are more agile, real-time monitoring capability. Alan Paller, Director of Research at the SANS Institute, stated the following in his testimony:
One of the most important goals of any federal cyber security legislation must be to enable the defenders to act as quickly to protect their systems as the attackers can act. We call this continuous monitoring and it is single handedly the most important element you will write into the new law. Continuous monitoring enables government agencies to respond quickly and effectively to common and new attack vectors. The Department of State has demonstrated the effectiveness of this security innovation. Most major corporations use it. This model is the future of federal cybersecurity. As our response to attacks becomes faster and more automated, we will take the first steps toward turning the tide in cyberspace, and protecting our sensitive information.

Continuous Monitoring capabilities, not only for government but also the commercial sector, is absolutely critical for identifying attempted and actual compromises and conducting proper incident response. Proper real-time network security monitoring is woefully lacking and this claim is supported by the Verizon 2009 Data Breach Investigations report which found that "Breaches still go undiscovered and uncontained for weeks or months in 75 percent of cases." This is mainly due to a lack or proper real-time continuous monitoring of network traffic.

Breach Security has seen these issues first hand with our government customers who want to protect their web applications. They are lacking lacking real-time visibility into their web data streams and are unaware of who is attacking them, how they are doing it and if and when they are successful. Web application firewalls give them them the visibility they need and the situational awareness required to identify and respond to real-time attacks.

Mr. Paller also recommends the use of the Consensus Audit Guidelines (CAG) as created by the Center for Strategic and International Studies (members of the Consortium include NSA, US Cert, DoD JTF-GNO, the Department of Energy Nuclear Laboratories, Department of State, DoD Cyber Crime Center plus the top commercial forensics experts and pen testers that serve the banking and critical infrastructure communities). Mr. Paller stated in his testimony:
Both the guidance for implementing FISMA and the guidance for auditing compliance are focusing on out of date, ineffective defenses. What we need instead is a process that directs agencies to focus their cyber security resources on monitoring their information systems and networks in real time so that they can prevent, detect and/or mitigate damage from attacks as they occur. And oversight must be focused on the effectiveness of the agencies’ real‐time defenses.
The CAG list is much more update-to-date not only with current attack methodologies of advanced persistent threats (APT) but also includes critical audit components such as what metrics should be captured and how to test the effectiveness of the controls. One example taken from the CAG is Control 7: Application Software Security which lists specific, operational controls for web applications such as:

How can this control be implemented, automated, and its effectiveness measured?

  1. QW: Organizations should protect web applications by deploying web application firewalls that inspect all traffic flowing to the web application for common web application attacks, including but not limited to Cross-Site Scripting, SQL injection, command injection, and directory traversal attacks. For applications that are not web based, deploy specific application firewalls if such tools are available for the given application type.

Again, web application firewalls can be used as a tactical remediation tool to help organizations reduce their time-to-fix metric of fixing identified vulnerabilities by acting as a virtual patch (or compensating control as specified in control 7 of the
CAG). The graphic on the right is taken from Whitehat Security's Statistics Report and it tracks the average time to fix a class of vulnerability measured in days. As you can see, most of these issues aren't resolved for months. The CAG, on the other hand, recommends the following remediation times:
Additionally, all high-risk vulnerabilities in Internet-accessible web applications identified by web application vulnerability scanners, static analysis tools, and automated database configuration review tools must be mitigated (by either fixing the flaw or through implementing a compensating control) within fifteen days of discovery of the flaw.
WAFs can help to close the gap of remediation time between what is recommended by CAG and the time that it normally takes an organization to implement source code level changes in production. This type of continuous monitoring and agile response capabilities are a key component of defense and it is good news that the government is looking to ensure FISMA includes them.

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