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CYBERSECURITY

INVESTIGATIONS

Planning & Best Practices

Michal Ploskonka, CPA

Senior Managing Consultant [email protected]

Lanny Morrow, EnCE

Managing Consultant [email protected] May 4, 2016 Cy Sturdivant, CISA Managing Consultant [email protected]

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• Participate in entire webinar

• Answer polls when they are provided

• If you are viewing this webinar in a group

 Complete group attendance form with

• Title & date of live webinar

• Your company name

• Your printed name, signature & email address

 All group attendance sheets must be submitted to [email protected]

within 24 hours of live webinar

 Answer polls when they are provided

• If all eligibility requirements are met, each participant will be emailed their CPE certificates within 15 business days of live webinar

TO RECEIVE CPE CREDIT

• Historical perspective on cyber threats • 2016 cyber threat landscape

• Types of data & industries at risk • Current regulatory environment

• Best practices in cybersecurity preparedness & monitoring • Incident response strategies

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HISTORICAL PERSPECTIVE

Actors

Thrill seekers

Pioneers

Teenagers

Organized crime

rings

State sponsored

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CHARACTERISTICS OF CYBERCRIMINALS

• Skilled • Persistent • Sophisticated • Tactical • Well funded • Difficult to detect • Evolving

– Technical attacks not needed – Can use deceivingly simple

methods (K.I.S.S) – Use of social engineering

e.g., Business Email Compromise

EVOLUTION OF CYBER THREATS

Monetary gain/loss Loss of proprietary information Loss of public trust Identity theft Disruption Social engineering Email account hijacking Trojans Viruses

Approach

End Result

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2016 CYBER THREAT LANDSCAPE

• The United States is extremely well connected

 87% of the population use the internet

 The country ranks 2ndglobally for online business-to-consumer

transactions

• Cyberattack is ranked as the # 1 risk for doing business in the U.S., followed by data fraud or theft.

• Constantly evolving technology

• Rapid increase in the number of connected devices • Rapid increase in the volume of stored data

 Especially unstructured data

CYBER THREAT LANDSCAPE

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“ ”

Robert Mueller, FBI Director

on Cyber Threat Landscape

“There are only two types of companies: those

that have been hacked, and those that will be.

Even that is merging into one category: those

that have been hacked and will be again.”

1. Tax-Refund Fraud 2. Corporate Account

Takeover 3. Identity Theft

4. Theft of Sensitive Data 5. Theft of Intellectual

Property

Source: American Institute of CPAs – October 2013 study

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• Notable data breaches

 2013 – Target ($252 M in initial costs)

 2014 – Home Depot ( $43 M by end of 2014)

 2015 – U.S. Office of Personnel Management, Anthem, IRS, Experian (T-Mobile Customers), Ashley Madison

 2016 – Hyatt Hotels, Trump Hotel Collection, FDIC, Mossack Fonseca (Panama Papers)

• Business email compromise

 Wire/ACH losses

 W-2 information

• Ransomware

RECENT DEVELOPMENTS

BUSINESS EMAIL COMPROMISE

Banks are not the focus of the simpler

schemes From October 2013 to December 2014, nonbank businesses lost $215 M through compromised email attacks From January 2015 to August 2015, business losses due to business email compromise increased to $800 M

(of which $747 M in the U.S.)

Combined worldwide losses due to BEC

exceed $2.3 B as of April 2016

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TYPES OF DATA & INDUSTRIES AT RISK

DATA AT RISK

• Credit/debit card information via POS systems • Potential Protected Health Information (PHI) • Employee data (PII)

• Social Security numbers

• Connectivity to health provider networks via pharmacies • User names & passwords

• Intellectual property

 Blueprints  Business plans  Trade secrets, etc.

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INDUSTRIES AT RISK

Targets

– Businesses • Financial institutions/banks • Insurance companies • Retailers

• Health care providers • Manufacturers • Critical industries • Governments • Law firms – Individuals • Everyone

• Key executives & decision makers

• Accounting & finance • Privileged users

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REGULATORY ENVIRONMENT

• Computer Fraud and Abuse Act (18 U.S.C §1030) of 1986 • Many cyber crimes prosecuted under traditional statutes • States provide penalties for crimes perpetrated by use of

computers or perpetrated against computers • State security breach notification laws

REGULATORY ENVIRONMENT

• Regulatory requirements may vary by industry

 FTC – Section 5(a) provides consumer protection

 Health Insurance Portability and Accountability Act (HIPAA)  Federal Financial Institutions Examination Council (FFIEC)  SEC – Division of Investment Management Guidance No. 2015-02

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BEST PRACTICES IN CYBERSECURITY

PREPAREDNESS & MONITORING

CYBERSECURITY PREPAREDNESS –

UTILIZING THE NIST FRAMEWORK

• NIST Framework

 Helps identify & prioritize actions for reducing cybersecurity risk  Tool for aligning policy, business & technological approaches to

managing that risk

 Enables organizations to apply principles & best practices of risk management to improve cybersecurity & secure critical

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NIST FRAMEWORK CORE FUNCTIONS

NIST Core Functions

 Standard cybersecurity controls • Five functions

• 22 categories or subdivisions • 98 subcategories

 Form “operational culture” that addresses cybersecurity risks

NIST FRAMEWORK OVERVIEW

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IDENTIFY

Identify Functions are foundational. These controls help an organization understand how to manage cybersecurity risk to systems, assets, data & capabilities. Relating these to a business context is critical for prioritizing efforts

Categories

 Asset Management  Business Environment  Governance

 Risk Assessment

 Risk Management Strategy

PROTECT

Protect Functions are the safeguards that ensure delivery of critical infrastructure services. In terms of ensuring resilience, these safeguards help to limit or contain the impact of a cybersecurity event.

Categories:

 Access Control  Awareness & Training  Data Security

 Information Protection Processes & Procedures  Maintenance

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DETECT

Detect Functions identify the occurrence of a cybersecurity event

Categories

 Anomalies & Events  Security Continuous

Monitoring

 Detection Processes

RESPOND

Respond Functions allow an organization to take action on a detected cybersecurity event. The goal of Respond Functions is to contain the impact of a cybersecurity event & remediate vulnerabilities Categories  Response Planning  Communications  Analysis  Mitigation  Improvements

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RECOVER

Recover Functions are for resilience planning

particularly the restoration of capabilities or services impaired by a

cybersecurity event

Categories

 Recovery Planning  Improvements  Communications

CYBERSECURITY PREPAREDNESS EFFORTS

Discuss cybersecurity issues with the Board & Senior Management on a regular basis, at least quarterly

Evaluate evolving cyber threats & vulnerabilities in the risk assessment process for the technologies you use & the products & services you offer

Ensure accountability is assigned to those who make business decisions that may introduce new cyber risks

Ensure ongoing employee awareness training is kept up to date & provided on a routine basis

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A cybersecurity program should integrate all aspects of an institutions existing programs.

Be sure to utilize what you already have

• Overall Information Security Program

• Business Continuity & Disaster Recovery, including capacity & performance planning

• Incident Response & Crisis Management Plans • Third-Party Risk Management

DEVELOP A CYBERSECURITY PROGRAM

CYBERSECURITY BEST PRACTICES

Board & Senior Management Responsibilities, Duties & Best Practices

• Ensure adequate strategic plans & budgetary resources are provided • Ensure the information security officer has adequate authority, resources &

independence

• Ensure threat intelligence & collaboration is timely, ongoing, risk focused, reported & actionable

• Develop attainable, measurable & repeatable processes to mitigate risks • Incorporate cybersecurity into the risk-based audit plan

• Maintain accurate asset inventories & be aware of ports of entry (you can’t protect what you don’t know exists)

• Ensure enterprisewide awareness training is performed (educate & motivate) • Ensure BIA, BCP/DR, information security & incident response policies &

procedures address cybersecurity

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CYBERSECURITY BEST PRACTICES

• Use e-mail filters, Internet Protocol (IP) filtering & data file integrity checks • Use encryption to protect confidential data

• Implement data loss prevention controls (USB ports, email, etc.) • Do not use default or weak passwords (12 alphanumeric & complex) • Track, report, independently test & update security patches based on a risk

priority schedule (Microsoft & non-Microsoft patches)

• Rename network admin accounts, separate production & admin login privileges & do not share network admin login credentials

• Control executable file authorities (least privileged access)

• Conduct internal & external vulnerability scans to ensure systems are hardened

• Update anomaly detection tools regularly & understand configurations • Use log analyzers (Security Information & Event Management – SIEM tools) to

wade through the false positives & assign responsibility for log review

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• Identify “Crown Jewels”

• Plan before something bad happens • Set a response protocol

• Establish an internal response team

• Identify your external resources in advance

 Legal counsel (notification requirements)

 IT security experts

 Digital forensics

 Public Relations

BREACH RESPONSE STRATEGIES

CANDIDATES FOR “DREAM TEAM”

IT & risk management Operations management Internal counsel External counsel Outside Consultants: -Incident response -Digital forensics -Forensic investigations Law enforcement Insurance company Data center

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Assemble team & designate leader Classify/ declare the incident Determine notification requirements Investigate & document Contain damage Recover & build on experience

RESPONSE PROTOCOL

 “Locking down” systems is first priority

 Second priority is to forensically preserve affected systems

 Phishing schemes for ransomware, wire transfers or information harvesting

• Very low likelihood of tracing to offender  “Inside job” or collusion

• More likely to be traced

 Forensic preservation involves creating full image copies of affected systems

 Insurance companies often require some level of investigation & expert opinion

 Forensic documentation is key

• Interviews by experienced professionals to ascertain chain of events & identify potential inside issues

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• Investigate & document

 Collect, analyze, protect & preserve evidence

 Chain of custody rules

 Inventory compromised systems & information

 Document date, time, system, detailed event description, contact information, identification of the asset, etc.

 Identify & document threat actor tactics, techniques & procedures

 Report all findings to the incident response team

• This information may be valuable to law enforcement

INVESTIGATION PHASE

NEVER TOO PREPARED …

 Need backups for each team member

 Perpetually updated contact information

 Review vendors (contracts, policies, contacts, bonding, security)

 “Fire drill” – Unexpected test incident to test systems. Superior to other forms of testing

 Unique tests – “dumpster diving” the trash, after-hours workstation checks, periodic “fake” phishing emails, installed software, internet history, USBs, etc.

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SPECIAL TOPICS IN CYBERSECURITY

• Best Practices

 Entry point – often phishing

 Education is key to preventing the “fatal click”

 In lieu of payment, restore from backups

 Backup policy should include special class of “essential operating items.” These should be backed up daily

 Restoring from a smaller set of essential files saves lots of time & money, reduces down time

 Notify local law enforcement, this is particular focus right now

 Paying the ransom will only encourage future attempts

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• Not necessarily a cybersecurity attack but same consequences

 Employee(s) compromise sensitive, proprietary or intellectual property-type information

 Motivation is often to open a competing business, join with a competitor, damage reputation or to sell information to others

 Common methods include (1) removable device, (2) email or (3) upload to cloud storage

 Monitoring systems should accommodate internet & email activity involving file uploads or transfers

 Periodic email review or flagging particular keywords recommended

 “Whitelisting” USB devices recommended

 More common than DoS attacks & other types of threats, but far less understood or planned for

THEFT OF TRADE SECRETS

• Policies relatively new • Everyone needs one

(backstop essential) • Consider types of losses

 Business interruption

 Additional expenses

 Your financial losses

 Losses to third parties

• Negotiate coverages

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RESOURCES

• National Institute of Standards & Technology’s “Framework for Improving Critical Infrastructure Cybersecurity”

• FTC’s “Start with Security” Guide

• “Best Practices for Victim Response & Reporting of Cyber Incidents” drafted by the Cybersecurity Unit of the U.S. Department of Justice (Computer Crime & Intellectual Property Section)

• Internet Crime Complaint Center

• Secret Service – Electronic Crimes Task Force

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CONTINUING PROFESSIONAL EDUCATION (CPE)

CREDITS

BKD,LLPis registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org.

The information in BKD webinars is presented by BKD professionals, but applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor before acting on any matters covered in these webinars.

CPE credit may be awarded upon verification

of participant attendance

For questions, concerns or comments

regarding CPE credit, please email the BKD

Learning & Development Department at

[email protected]

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FOR MORE INFORMATION

THANK YOU!

Lanny Morrow | 816.221.6380 | [email protected] Cy Sturdivant | 615.988.3600 | [email protected] Michal Ploskonka | 630.282.9495 | [email protected]

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