Top 10

Froud on Fraud’s Top 10 Cybersecurity Technologies to Implement in 2017

In direct response to a certain organisation’s ‘Top 10 Cyber Security Technologies to Watch in 2017’, [cough, Gartner, cough], I have come up my own list of bleeding edge security technologies that every organisation should spend millions of $/£/€/¥ on.

Yes, even if you don’t MAKE millions, you should borrow the money and buy them anyway.

Being honest, my fight to bring security ‘back to basics’ has failed – despite my enormous 210 person following – so I have decided to sell-out and promote nothing except buzz-phrases and acronyms. You know, like everyone else.

However, I am convinced that if you buy, implement, and actually take these technologies seriously, you can forget the security basics. The combination of these 10, never-seen-before, shiny new objects will provide the silver bullet you’re looking for:

  1. Directorate Approbation Paradigm (DAP) – Historically, achieving ‘management buy-in‘ was the ultimate goal for anyone attempting to implement a security program. Quite rightly, caring about the future of an organisation was considered naive, and proponents of this stone-aged technology were left begging for work on LinkedIn. Some of these poor souls even became CISOs. Now, with DAP technology, every single person in an organisation will take security seriously, even if their bosses don’t!
  2. Command & Control Commission (CCC) – While not strictly a technology the CCC is responsible taking the output from the EIC below, combining it with the DAP above and obtaining the budget to buy everything else on this list. This is the spider in the middle of the web, making sure that all technologies work together. Called ‘governance‘ in the old days, the new CCC is clearly superior given that you’ve never heard of it, and it’s an acronym.
  3. Protocol, Method, & Archetype Orchestrator (PMAO) – Much as leeches were seen as the go-to technology in medieval medicine, ‘policies, procedures and standards‘ were seen as a foundation for every security program. While clearly nothing more than a quaint superstition, they nevertheless laid the groundwork for the PMAO revolution. Imagine it; a series of artefacts designed to record not only an organisation’s entire security culture, but their process knowledge and system baselines as well! No way just policies, procedures and standards could do all of that!
  4. Exposure Investigation & Computation (EIC) – I almost feel sorry for the poor saps who only had the ‘risk assessment‘ process to measure their risk profile. Can you imagine basing you risk treatment and technology purchasing decisions only on expert opinion and business goals!? Instead, EIC, in combination with AI, big data, The Cloud, and fairy dust, can tell you exactly how many millions to spend on technology! No more embarrassing moments when you try to explain to your boss how you tried to save them money by fixing the actual problem! Like people and process could ever be the problem!
  5. Intelligence Preservation Administration Schema (IPAS) – Can you imagine the nerve of the International Standards Organisation when they came up with the Information Security Management System (ISMS)? A so-called ‘framework’ designed for “systematically managing an organization’s sensitive data” with – and you won’t believe this- “a set of policies and procedures”! How naive! Instead, with IPAS, you can basically ignore the hard work and common sense approach to doing security properly and hide behind an expensive appliance with flashing green lights! Blinking green, you know it’s working!
  6. Transformation Regulation Authority (TAR) – Before the advent of TAR technology, organisations across the globe relied on a ‘change control board’ to ensure that unmeasured risk was not introduced into an environment. As yes, once again, actual humans – apparently those with ‘expert’ knowledge – were allowed to determine what was right for the business. A clearer case could not be made to put this in the safe ‘hands’ of technology written by someone else.
  7. Episode Reply & Adversity Restoration (ERAR) – We’ve all seen those commercials from the 50’s where attractive actors extolled the virtues of smoking? Well, ‘incident response & disaster recovery‘ were just as misleading, and just as dangerous! Like anything involving people and process could possibly help you stay in business! ERAR on the other hand, will not only detect bad things happening, it will keep your business up and running! Surely THAT’S worth a few million all by itself!!
  8. Capital Durability Projection (CDP) – The future of any organisation should never be placed in the hands of those who care. The experiment called corporate social responsibility failed because it was assumed that it’s the people who are the most important aspect of a business. At least now we know it’s money that’s most important, so the old concept of ‘business continuity planning’ can be replaced by EDC and those making the world better with technology. Finally the people can be safely ignored.
  9. Asset Management (AM) – This is one aspect of security where technology is actually sadly lacking. Asset management is the centre of everything, and without it, no other aspect can be truly be done well. Spreadsheets just don’t cut it, and no GRC that I’ve seen gives asset management its due. This much change, even in The Cloud.
  10. Continuous Compliance Validation (CCV) – This is an idea whose time has come, it’s about time technology provides a REAL solution to overly manual processes.

All facetiousness aside, I am a huge fan of technology. Or more accurately, I am a huge fan of the appropriate application of technology. If you buy something based on anything other than 1) the results of your risk assessment, and 2) answers to the RIGHT questions, you have no business being in charge of a budget.

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PCI L1 Service Provider

From FinTech Concept to PCI Compliant in 6 Months?

Anyone wanting to start a new business in FinTech/payments – digital wallets for example – has to address PCI. Like it not, payment cards are still the dominant form of non-cash payment on the planet. By far.

So what if you have a great idea in this amazing world of opportunity, but your skill-set is in payments and innovation, and not IT or cybersecurity. How do you get your service to market, AND play by the rules? Can you do this in time to be ahead of game given the incredibly short timeframe of today’s competitive advantage?

Well, you could just self assess, but you are restricting yourself to a maximum of 300,000 transaction annually.  But more importantly, would you trust your money to a service provider who self assesses? No, neither would I.

However, I’m talking about full Level 1 Service Provider compliance through a reputable QSA (yes, there are some out there). How can you set up the infrastructure, get all the documentation in place, AND get all the way through a PCI DSS Level 1 assessment in 6 months? And if you do, have you really done it properly?

The answer is yes, you can, but there are MANY caveats, and if you deviate from these steps you will not get there. I am only interested in helping organisations get compliant properly, I have no interest in adding more crap service providers to the ecosystem.

First, you have to completely ignore the PCI DSS. Any plans you make to design both your physical infrastructure and your security program from scratch must be with real security in mind. Never compliance alone. For that, many organisations turn to the ISO 27001 standard. There are others, but try finding affordable consultants who can help you implement them. As long as you realise they are all just frameworks, not step-by-step instructions, then you’re ready to start asking questions.

So What Are the Steps to Compliance?


  1. Get Help – This should be no surprise. I don’t perform emergency appendectomies, I’m not remotely qualified, why would you try to achieve compliance when that’s not your experience or skill-set. Yes, is can be expensive, but nowhere near as expensive as any of the alternatives. There are some very good consultants out there, do your homework and find the best one for you.
  2. Outsource the Infrastructure – Unless you’re an expert in everything from hardened operating systems, to logging and monitoring, to firewall management, you will want to outsource as much of the platform as you possibly can. Unfortunately, finding a single provider who can take on anything more than physical hosting and some networking stuff is still ridiculously difficult. Amazon Web Services (AWS) for example is about as bad as you can get. Unless of course you want a dozen or so independent service providers to manage along with Amazon.
    You MUST ask the right questions, and this is where your  consultant comes into play. S/he will write your RFP, interview providers, and eventually produce a responsibility mapping of services against the PCI DSS. This will match their Attestation of Compliance, as YOU should only do business with L1 PCI compliant service providers.
    You are welcome to use my mapping if you don’t have one: PCI DSS v3.2 SP Responsibility Mapping
  3. Policies, Standards & Procedures – You have to start somewhere, so you will likely want to buy a Policy Set. Once again, you have to be very careful as there are dozens of options but few will be fit for purpose. In this case, ‘fit for purpose’ means the service must 1) get you through compliance, 2) provide a platform for your unique culture, and 3) be self-sustainable for the long-term.
    If you buy a Policy Set with ‘PCI’ in the title, you have already failed. Buy one that your consultant can customise on your behalf, and then teach you to manage yourself. Get one that; 1) Is already mapped to both the PCI DSS and your chosen framework (usually ISO 27001), 2) has document management built in (numbering, content standards, assigned coordination etc.), and 3) is easily distributed to the subject matter experts best placed to maintain them.
    I have written a quasi-white paper on how to choose the right the right service, you use the questions as an RFP: ‘Selecting the Right Policy Set
  4. Hire a Completely Independent QSA – While it may be very tempting to have your consultant take care of all the ‘PCI stuff’, bite the bullet and keep these separate. No, you don’t have to be an expert in this stuff, but if you are relying completely on your consultant you are building in a single source of failure. By all means have your consultant run with the assessment, but be involved. If you don’t, you’ll have no idea what you paid for in the first place. In fact, you may even want to build in some SLAs regarding how much remediation is required from by QSA. There will always be some, but if it involves significant scope creep or capital cost, your consultant has failed you. Remember, you have outsourced almost the entire function of PCI to your platform provider, validation of compliance should be a formality.

Of course this is oversimplified, but I’m already way over my self-imposed word limit. However, while I haven’t included any of the inevitable challenges, the process is a simple as security itself, it’s up to you to find someone who can make it simple.

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Froud on Fraud: Cybersecurity Predictions for 2017

This time last year I wrote Froud on Fraud: Top 5 Predictions for 2016. Unsurprisingly, none of these things has transpired. At least not yet anyway [embarrassed silence].

So why do this again, when it’s fairly clear that any insight I have – if any – is aimed more towards potential long-term trends than to short-term results?

The reason I’m taking another stab is I can’t help feeling that 2017 is going to something of a watershed year for cybersecurity. At least I hope so, because there is so much hype, scaremongering and dross out there that something needs to change. And it must change soon, before cybersecurity professionals get lumped into the same category as the better known examples of sleaze; used car salesmen, estate agents, and lawyers (no offence Sis).

The last few years has been bad for the cybersecurity/privacy profession. From Snowden, to the Snooper’s Charter, from Target to Yahoo there has been no good news. Forget that the press will not print good news if they can possibly help it, things actually are getting worse. State sponsored attacks, organised crime, numerous vulnerabilities in Android and iOS, irresponsible Internet of Things manufacturers, there is little to smile about.

But instead of coming to the rescue, the cybersecurity industry seems Hell-bent on making it worse by cashing in on the confusion. From biometrics vendors disgracefully overstating their worth, to consulting practices doing everything in their power to cross-sell and upsell their wares, it’s becoming increasingly difficult to know where to turn.

The only bright side? Legislation.

Yes, legislation. The Payments Service Directive (PSD2) and the General Data Protection Regulation (GDPR) – for example – are both designed to start putting things right in payments and data privacy respectively. No one with a vested interest in keeping things the same was ever going to do anything themselves, so now they’ll have to. Banks, large retail, you name it, there will now be a price to pay for how you treat the consumer.

And let’s face it, it’s all about the consumer.

So with the above in mind, these are my predictions for 2017:


  1. ISO 27001 certification will be increasingly important: Unlike PCI which is entirely prescriptive, no other regulation that I have ever seen requires anything other than ‘appropriate‘ or ‘reasonable‘ security measures. Appropriate and reasonably to whom is always the first question. ISO 27001, and other frameworks like it, perform one overarching function; to provide demonstrable evidence that an organisation is taking security seriously. Whether the organisation is actually taking security seriously is another matter, but it is hard to fake certification. Not impossible mind you, just difficult. ‘Compliance’ with GDPR, and other data privacy regulations globally will look to ISO for help.
  2. Biometrics vendors will keep pushing their wares, and fail: OK, so this one is more of a wish than a prediction, but I am so sick of the hype around biometrics that I need to vent. Yes, biometrics if very important, yes, it’s better than a password in most scenarios, but it is NOT an answer by itself. Biometrics will not replace the password, nor will it ever be a solution all by itself. It will do what every other form of authentication should do; take its rightful place in the arsenal of identity management systems.
  3. Amazon GO will be the new model for brick & mortar: Any brick and mortar retailer not terrified by the opening of the Amazon GO store in Seattle is completely missing the point. The point is that consumers don’t care how they PAY, they care how they BUY. Cash, credit cards, even the Apple Pays and their ilk are just forms of payment, they are not relevant to how we choose the products and services we actually BUY. We demand a lot more from our merchants than a glorified cash register. In Invisible Payments, Are They Real? (Aug ’15) I went a little further than Amazon did, and will go even further in a week or so. And while I don’t expect 2017 to see a sharp increase in GO-esque stores, it’s definitely a glimpse of the near future.
  4. Containerised Security Services: Anyone who has looked to Amazon Web Services or Azure for hosting their e-commerce systems often do so in order to outsource security as well. The fact that neither of these services provide much is often a nasty surprise. Yes, the merchants asked the wrong questions (or none at all), but it is incomprehensible to me that vendors like AWM DON’T provide comprehensive security wrappers. 2017 will see an increase in modular and full-service security programs (at least to PCI minimums) from all of the major providers. Hopefully these will be easily understandable and transparent to non-experts, because even the better service providers do a piss-poor job of getting their point across.
  5. Automated Governance, Risk & Compliance: GRC is a fantastic concept, implemented poorly. However, with the ever increasing regulatory landscape, larger organisations simply can’t keep up with the audit  ommitments. GRC tools have traditionally been mostly manual in nature, which explains their lack of adoption. More and more GRC vendors are looking to automate compliance baseline input by providing APIs to end-point vendors (A/V, SIEM, vulnerability scanning etc) for automated input of production system data. 2017 will see GRC vendors finally focusing on the only thing that makes sense; asset management and automated baseline comparisons of known-good profiles.

OK, so 5. is a bit of a stretch, but there’s no way my OCD would allow for only 4 predictions.

What are your predictions?

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Gartner’s Top 10 for InfoSec in 2016: 10 More Useless Acronyms?

On June 15th, Gartner released it’s Top 10 Technologies for Information Security in 2016. As a security ‘professional’ with over 15 years front-line experience, it has taken me this long to find out what half of these things are even trying to achieve. My initial impression was that this was just an attempt to corner the market on acronyms.

Now that I’ve had a little more time to look at them, it’s not just about acronyms, it’s about selling things. Things the vast majority of businesses don’t need. Things that if you DID introduce them into your current environment it would be like building a castle on a swamp (hope you got the Monty Python reference);

Utterly useless, expensive, and completely missing the point.

The breakdown:

  1. Cloud Access Security Brokers (CASBs), provide a “…critical control point for the secure and compliant use of cloud services across multiple cloud providers.” – In the real world this is called performing proper due diligence, before you outsource to a cloud provider. The right reporting should be built into the SLAs. Good God, even the PCI DSS makes this a requirement!
  2. Endpoint Detection and Response (EDR), “EDR tools typically record numerous endpoint and network events, and store this information either locally on the endpoint or in a centralized database.” then compare the output to “known indicators of compromise (IOC)“. [Ed. note the 2-for-1 on the acronym front] – Why the Hell would you wait for a ‘known indicator of compromise’ instead of trying to fix the problem pro-actively first?!  Hardening guides, vulnerability management, system baselining, FIM et al are all designed to produce baselines of known-good configs thereby minimising exposure. This is nothing more than a rebranding of basic security tenet in order to sell a technology.
  3. Non-Signature Approaches for Endpoint Prevention, uses “machine learning-based malware prevention using mathematical models as an alternative to signatures for malware identification and blocking.” – Seriously (see 2. above)? Once you have your system at a known-good config, stop anything NOT that. Are you seriously going to spend God-knows how much on a new technology instead of doing what you SHOULD have doing all along …for free(ish)?
  4. User and Entity Behavioral Analytics (EUBA), “…provides user-centric analytics around user behavior, but also around other entities such as endpoints, networks and applications.” – This one just pisses me off, and I can only assume Gartner were paid a ton of money by EUBA vendors to add this to the list. This is the THIRD nod to baselining and I’m only at number 4 on the list.
  5. Microsegmentation and Flow Visibility, which is basically more granular segmentation (think system-to-system instead of the usual network-to-network). – So let’s see; most organisations have horrible segmentation at the network level, so to combat this, buy a technology that puts the ‘firewalls’ on each endpoint and maps your traffic flows at that level. I have an idea, why don’t you just do segmentation properly with the infrastructure you have and THEN decide if you need more. I seriously doubt you will unless you’re an IaaS/PaaS provider.
  6. Security Testing for DevOps (DevSecOps) – In other words; building security and security testing into every step of the development process. This is new? I have to assume this was just padding to avoid a Top 9 scenario.
  7. Intelligence-Driven Security Operations Center Orchestration Solutions, “an intelligence-driven SOC [ISOC] also needs to move beyond traditional defenses, with an adaptive architecture and context-aware components.” – So what you’re saying is; Let me know if something happens that’s not normal? Errr, isn’t that reporting events outside of a KNOWN-GOOD BASELINE!?!
  8. Remote Browser solutions “…remotely present the browser session from a “browser server” (typically Linux based) running on-premises or delivered as a cloud-based service.” – This one kinda makes sense, but haven’t we had jump-servers for decades that could do something very similar?
  9. Deception “technologies are defined by the use of deceits and/or tricks designed to thwart, or throw off, an attacker’s cognitive processes, disrupt an attacker’s automation tools, delay an attacker’s activities or disrupt breach progression.” – Anyone who uses this technology deserves to be hacked. This is perhaps the stupidest concept I have ever seen and I cannot believe it’s on anyone’s list. Gartner should actually be ashamed of themselves.
  10. Pervasive Trust Services, “As enterprise security departments are asked to extend their protection capabilities to operational technology and the Internet of Things, new security models must emerge to provision and manage trust at scale.” – Finally we agree on something; centralised management of end-points based on known-good configs.

As far as I am concerned, 99.9% of organisations can effectively ignore this Top 10 list. You will NEVER find a technology that fixes stupid. Just do security properly and you’ll achieve what every organisation is looking for; appropriate, value-for-money, security.

It’s a shame Gartner can’t monitise a ‘Top 10 Information Security Back to Basics’, that would actually be worth a read.


Biometrics is Dead, Long Live Mobile!

In my continuing crusade against greedy and self-serving biometrics vendors – which is absolutely NOT all of them – I figured I would give them a little taste of their own medicine with a ridiculous assertion in the title.

Of course biometrics isn’t dead [I believe it’s still in its infancy] and of course it will only continue to grow in distribution and influence. Its adoption will sky-rocket as mobile devices take over the world and IoT makes thinking for yourself redundant, and I for one am more than happy for it to spend time more in the sun.

What I cannot / will not accept from biometrics:

  1. Its growth at the expense of ANY other form of authentication (without appropriate justification),
  2. Its false and irresponsible claims to its security, and;
  3. Its blatant disregard for its ultimate benefactor; the mobile phone

Put to one side for a minute that not ONE legislation / regulation in payments actually requires biometrics (where “strong authentication” is primarily defined as 2-factor), and focus for a second on how biometrics has even made it as far as it has. Simply put, without the mobile phone, there would BE no biometrics in the mainstream.

It’s not like we would all carry around a separate device to perform biometric authentication, would we? No, we wouldn’t, so it’s only because biometrics is so readily available that we even consider it an alternative to passwords. That’s right, an ALTERNATIVE, and for the foreseeable future, one completely driven by consumer preference. No financial institution in their right mind will make biometrics mandatory, probably ever. I certainly wouldn’t.

So if the mobile phone is so all-powerful, why aren’t they attacking passwords? Simple, a) they have no need to, they are the dominant factor, and b) they are smart enough to realise that without the OTHER two factors they are not providing the best solutions possible.

In other words, they get it.

Rather a bleak picture, isn’t it? 1) not required for regulatory compliance, 2) will never be mandatory, only a consumer preference, 3) will never be suitable for some forms of authentication due to false ‘positives’, and; 4) it completely reliant on something else for its distribution. But even with all of this against it, I will embrace biometrics, in all its forms, if it provides me the convenience I crave, with ENOUGH security to transfer the risk to someone else (my bank for example).

And that’s really what it all boils down to; risk. A simple word but one completely misunderstood, and usually handled poorly. Bottom line; if the effort to steal something is greater than its value, it’s safe …enough. That’s all biometrics and passwords provide; security enough, and the amount of security you have to provide for a transaction is directly proportional to the value of the transaction.

For example, why would you use Apple Pay when it requires authentication that the contactless card does not? Is it more convenient? No. Does it provide more value-add services? No. Does it have anywhere near the distribution of plastic? No. Do YOU have to care about the security of contactless? No, you don’t.

Biometrics is, and will always be only a player in the game. While mobile holds most of the cards, any form of biometrics will be beholden to it, so they should play nice.