Your Gateway to Cyber Risk Management
DFAR ANALYSIS
SMB Case Studies
Presented By: Carter Schoenberg
President & CEO
HEMISPHERE Cyber Risk Management
www.hemispherecyber.com
(703) 881-7785
About HEMISPHERE
 Established in 2015
 Offices in U.S. (Virginia)
 Professional cyber risk management services
(Small & Mid-size Businesses, Law Firms, and Insurance Sectors)
 Proprietary risk modeling
Your Gateway to Cyber Risk Management
Your Gateway to Cyber Risk Management
CUI IV&V Engagements
PoP: 15 engagements between July 2016 - Present
Company Sizes: Ranging from 35 to 416 employees
Geography: CONUS
Average Cost of Engagement: $29,515
Average Identified Savings from Recommendations: $58,724
Your Gateway to Cyber Risk Management
CUI IV&V Engagements
Challenges – Government Side
 DFAR only evaluates what is deemed of interest to them
 DoD has conveyed presumptions about what business owners “normally do” (e.g. having
policies and procedures in place to meet traditional -1 controls of NIST SP 800-53)
 Communications about requirements has been limited
 CUI vs. CDI vs. CTI
 Consequences of failing to adopt are not clear
 Oct 2017 conveys “30 days to adopt” whereas full implementation is hard stopped at
12/31/2017 (What does this mean for companies post January 1, 2018?)
 Self Certification as an evaluation criteria or “Reps & Certs”?
 Industry Day issues: Flow down for CSPs and adoption of 800-53 vs. 800-171
 DoD Acquisition Workforce (background and expertise)
Your Gateway to Cyber Risk Management
Cyber Plans and SSPs
I don’t have time for this stuff!
Incident Response
80%
Challenges – Contractor Side (SMBs)
 Lack of qualified staff
 Little or no inputs from legal
 “I have ISO 27000 Series, I am good” (40 controls do not align)
 They believe liability ends with the solicitation’s requirements
Your Gateway to Cyber Risk Management
Ask The Audience
You be the Judge
Scenario: “ACME” - 8(a) firm in Virginia wins large
contract to support NAVY in San Diego, Pensacola, and
New London
 ACME contacted by law enforcement agency about activity on their network associated
with a cyber incident
 Analysis confirms malware propagated on core enterprise network of ACME (introduced
via smartphone plugged into contractor laptop)
 Data supports that information has been exfiltrated that likely included staff PII
What do you do?
Your Gateway to Cyber Risk Management
Did You Know?
 60% of small businesses close their doors after a cyber event
 Most cyber events are internal
 More money is spent on cyber defense
today than ever before
~ Small Business Trends, 2017
Your Gateway to Cyber Risk Management
Did You Know?
 62% of all cyber insurance claims came from small businesses
 Most coverages levels are inadequate
 Duty to disclose before taking action
 Courts are moving away from “if you were
breached” to “how well did you respond and
recover?”
POLICY VALUE
Incident Response
80%
Your Gateway to Cyber Risk Management
CUI IV&V Engagements
Our Approach
 Review each organization (as a business)
 Ascertain how many states may have purview in the event of a breach
 Identify the language in existing contracts where the client must demonstrate adherence
to DFAR updates (NIST SP800-171 and Penetration Clauses)
 Review any existing operational policies and procedures
 Conduct technical scans of client’s environment (Nessus, Nmap, and Wireshark)
 Conduct Operational and Physical Assessments
 Analysis
 Draft Report
 Final Report with onsite formal debrief
Your Gateway to Cyber Risk Management
CUI IV&V Engagements
Findings
NIST SP 800-171 Adoption (110 Controls)
Averages:
Adopted:
Adopted with Limitations
Not Adopted:
29%
37%
34%
How many understood
how to reclaim these
costs?
Your Gateway to Cyber Risk Management
CUI IV&V Engagements
Findings
Beyond
800-171
CONTROL DESCRIPTION
AC-1 ACCESS CONTROL POLICY AND
PROCEDURES
AC-9 PREVIOUS LOGON
AC-10 CONCURRENT SESSIONS
AC-14 PERMITED ACTIONS WITHOUT ID &
AUTHENTICATION
AT-4 SECURITY TRAINING RECORDS
AU-10 NON-REPUDIATION
AU-13 MONITORING FOR INFORMATION
DISCLOSURE
CA-3 SYSTEM INTERCONNECTIONS
CA-6 SECURITY ASSESSMENT
CM-9 CHANGE MANAGEMENT PLAN
CP-2 CONTINGENCY PLAN
CP-4 CONTINGENCY PLAN TESTING
IA-3 DEVICE ID AND AUTHENTICATION
Your Gateway to Cyber Risk Management
CUI IV&V Engagements
Findings
Beyond
800-171
CONTROL DESCRIPTION
IA-8 ID AND AUTHENTICATION (NON ORG USERS)
IR-8 INCIDENT RESPONSE PLAN
IR-9 INFORMATION SPILLAGE
MP-1 MEDIA PROTECTION PLAN
PE-7 VISITOR CONTROL
PE-19 INFORMATION LEAKAGE
PL-4 RULES OF BEHAVIOR
PL-7 3RD PARTY PERSONNEL
PL-8 INFOSEC ARCHITECTURE
PS-6 ACCESS AGREEMENTS
PS-7 3RD PARTY PERSONNEL SCREEENING
PS-8 PERSONNEL SANCTIONS
Your Gateway to Cyber Risk Management
CUI IV&V Engagements
Findings
 Access Control Plan
 Media Protection Plan
 Incident Response Plan
 Configuration/Change Mgt. Plan
 Ability to Continuously Monitor
 Inventory of Assets
 Multifactor Authentication
5 out of 15
4 out of 15
1 out of 15
0 out of 15
0 out of 15
2 out of 15
1
Your Gateway to Cyber Risk Management
Cyber Plan vs. SSP
Some entities require a System Security Plan (SSP). How is a SSP different from a “Cyber Plan”?
Incident Response
80%
Context and Visualization
Estimated time to complete in-house with
1) No outside assistance
2) No internal cybersec SME
6 months
Your Gateway to Cyber Risk Management
Corporate Cyber
and Incident Response Plans
It is not simply “your”
Business you need to worry about.
Incident Response
80%
63% of cyber breaches attributed to
a 3rd party.
~ Soha Security Survey 2016
Your Gateway to Cyber Risk Management
Corporate Cyber
and Incident Response Plans
Regulators and Plaintiffs
Incident Response
80%
What will be asked for?
Likely first items
 Corporate Policies
 Incident Response Plan
Your Gateway to Cyber Risk Management
Corporate Cyber
and Incident Response Plan
What to Do What Not to Do
Incident Response
 Make it easily accessible
 Actionable
 Repeatable
 Paper version stuck on a shelf
 Very technical
 Hard to enforce
Your Gateway to Cyber Risk Management
Government Contractor ISAO
“GovCon-ISAO”
Addresses 21 out of 110 Controls
Incident Response
More than just info-sharing
Takes the guess work out of what to share and why
Interactions with DHS enables early warning indicators
Benchmarking against peers
Your Gateway to Cyber Risk Management
Questions
Incident Response
Carter Schoenberg, President & CEO
Carter@hemispherecyber.com
(703) 881-7785 Office
SUBJECT: SSCA

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HEMISPHERE SMB Case Study

  • 1. Your Gateway to Cyber Risk Management DFAR ANALYSIS SMB Case Studies Presented By: Carter Schoenberg President & CEO HEMISPHERE Cyber Risk Management www.hemispherecyber.com (703) 881-7785
  • 2. About HEMISPHERE  Established in 2015  Offices in U.S. (Virginia)  Professional cyber risk management services (Small & Mid-size Businesses, Law Firms, and Insurance Sectors)  Proprietary risk modeling Your Gateway to Cyber Risk Management
  • 3. Your Gateway to Cyber Risk Management CUI IV&V Engagements PoP: 15 engagements between July 2016 - Present Company Sizes: Ranging from 35 to 416 employees Geography: CONUS Average Cost of Engagement: $29,515 Average Identified Savings from Recommendations: $58,724
  • 4. Your Gateway to Cyber Risk Management CUI IV&V Engagements Challenges – Government Side  DFAR only evaluates what is deemed of interest to them  DoD has conveyed presumptions about what business owners “normally do” (e.g. having policies and procedures in place to meet traditional -1 controls of NIST SP 800-53)  Communications about requirements has been limited  CUI vs. CDI vs. CTI  Consequences of failing to adopt are not clear  Oct 2017 conveys “30 days to adopt” whereas full implementation is hard stopped at 12/31/2017 (What does this mean for companies post January 1, 2018?)  Self Certification as an evaluation criteria or “Reps & Certs”?  Industry Day issues: Flow down for CSPs and adoption of 800-53 vs. 800-171  DoD Acquisition Workforce (background and expertise)
  • 5. Your Gateway to Cyber Risk Management Cyber Plans and SSPs I don’t have time for this stuff! Incident Response 80% Challenges – Contractor Side (SMBs)  Lack of qualified staff  Little or no inputs from legal  “I have ISO 27000 Series, I am good” (40 controls do not align)  They believe liability ends with the solicitation’s requirements
  • 6. Your Gateway to Cyber Risk Management Ask The Audience You be the Judge Scenario: “ACME” - 8(a) firm in Virginia wins large contract to support NAVY in San Diego, Pensacola, and New London  ACME contacted by law enforcement agency about activity on their network associated with a cyber incident  Analysis confirms malware propagated on core enterprise network of ACME (introduced via smartphone plugged into contractor laptop)  Data supports that information has been exfiltrated that likely included staff PII What do you do?
  • 7. Your Gateway to Cyber Risk Management Did You Know?  60% of small businesses close their doors after a cyber event  Most cyber events are internal  More money is spent on cyber defense today than ever before ~ Small Business Trends, 2017
  • 8. Your Gateway to Cyber Risk Management Did You Know?  62% of all cyber insurance claims came from small businesses  Most coverages levels are inadequate  Duty to disclose before taking action  Courts are moving away from “if you were breached” to “how well did you respond and recover?” POLICY VALUE Incident Response 80%
  • 9. Your Gateway to Cyber Risk Management CUI IV&V Engagements Our Approach  Review each organization (as a business)  Ascertain how many states may have purview in the event of a breach  Identify the language in existing contracts where the client must demonstrate adherence to DFAR updates (NIST SP800-171 and Penetration Clauses)  Review any existing operational policies and procedures  Conduct technical scans of client’s environment (Nessus, Nmap, and Wireshark)  Conduct Operational and Physical Assessments  Analysis  Draft Report  Final Report with onsite formal debrief
  • 10. Your Gateway to Cyber Risk Management CUI IV&V Engagements Findings NIST SP 800-171 Adoption (110 Controls) Averages: Adopted: Adopted with Limitations Not Adopted: 29% 37% 34% How many understood how to reclaim these costs?
  • 11. Your Gateway to Cyber Risk Management CUI IV&V Engagements Findings Beyond 800-171 CONTROL DESCRIPTION AC-1 ACCESS CONTROL POLICY AND PROCEDURES AC-9 PREVIOUS LOGON AC-10 CONCURRENT SESSIONS AC-14 PERMITED ACTIONS WITHOUT ID & AUTHENTICATION AT-4 SECURITY TRAINING RECORDS AU-10 NON-REPUDIATION AU-13 MONITORING FOR INFORMATION DISCLOSURE CA-3 SYSTEM INTERCONNECTIONS CA-6 SECURITY ASSESSMENT CM-9 CHANGE MANAGEMENT PLAN CP-2 CONTINGENCY PLAN CP-4 CONTINGENCY PLAN TESTING IA-3 DEVICE ID AND AUTHENTICATION
  • 12. Your Gateway to Cyber Risk Management CUI IV&V Engagements Findings Beyond 800-171 CONTROL DESCRIPTION IA-8 ID AND AUTHENTICATION (NON ORG USERS) IR-8 INCIDENT RESPONSE PLAN IR-9 INFORMATION SPILLAGE MP-1 MEDIA PROTECTION PLAN PE-7 VISITOR CONTROL PE-19 INFORMATION LEAKAGE PL-4 RULES OF BEHAVIOR PL-7 3RD PARTY PERSONNEL PL-8 INFOSEC ARCHITECTURE PS-6 ACCESS AGREEMENTS PS-7 3RD PARTY PERSONNEL SCREEENING PS-8 PERSONNEL SANCTIONS
  • 13. Your Gateway to Cyber Risk Management CUI IV&V Engagements Findings  Access Control Plan  Media Protection Plan  Incident Response Plan  Configuration/Change Mgt. Plan  Ability to Continuously Monitor  Inventory of Assets  Multifactor Authentication 5 out of 15 4 out of 15 1 out of 15 0 out of 15 0 out of 15 2 out of 15 1
  • 14. Your Gateway to Cyber Risk Management Cyber Plan vs. SSP Some entities require a System Security Plan (SSP). How is a SSP different from a “Cyber Plan”? Incident Response 80% Context and Visualization Estimated time to complete in-house with 1) No outside assistance 2) No internal cybersec SME 6 months
  • 15. Your Gateway to Cyber Risk Management Corporate Cyber and Incident Response Plans It is not simply “your” Business you need to worry about. Incident Response 80% 63% of cyber breaches attributed to a 3rd party. ~ Soha Security Survey 2016
  • 16. Your Gateway to Cyber Risk Management Corporate Cyber and Incident Response Plans Regulators and Plaintiffs Incident Response 80% What will be asked for? Likely first items  Corporate Policies  Incident Response Plan
  • 17. Your Gateway to Cyber Risk Management Corporate Cyber and Incident Response Plan What to Do What Not to Do Incident Response  Make it easily accessible  Actionable  Repeatable  Paper version stuck on a shelf  Very technical  Hard to enforce
  • 18. Your Gateway to Cyber Risk Management Government Contractor ISAO “GovCon-ISAO” Addresses 21 out of 110 Controls Incident Response More than just info-sharing Takes the guess work out of what to share and why Interactions with DHS enables early warning indicators Benchmarking against peers
  • 19. Your Gateway to Cyber Risk Management Questions Incident Response Carter Schoenberg, President & CEO Carter@hemispherecyber.com (703) 881-7785 Office SUBJECT: SSCA