Lessons from Federal Trade Commission cases
When managing your network, developing an app, or even organizing paper files, sound security is no accident. Companies that consider security from the start assess their options and make reasonable choices based on the nature of their business and the sensitivity of the information involved. Threats to data may transform over time, but the fundamentals of sound security remain constant. As the Federal Trade Commission outlined in Protecting Personal Information: A Guide for Business, you should know what personal information you have in your files and on your computers, and keep only what you need for your business. You should protect the information that you keep, and properly dispose of what you no longer need. And, of course, you should create a plan to respond to security incidents.
There’s another source of information about keeping sensitive data secure: the lessons learned from the more than 50 law enforcement actions the FTC has announced so far. These are settlements – no findings have been made by a court – and the specifics of the orders apply just to those companies, of course. But learning about alleged lapses that led to law enforcement can help your company improve its practices. And most of these alleged practices involve basic, fundamental security missteps. Distilling the facts of those cases down to their essence, here are ten lessons to learn that touch on vulnerabilities that could affect your company, along with practical guidance on how to reduce the risks they pose.
- Start with security.
- Control access to data sensibly.
- Require secure passwords and authentication.
- Store sensitive personal information securely and protect it during transmission.
- Segment your network and monitor who’s trying to get in and out.
- Secure remote access to your network.
- Apply sound security practices when developing new products.
- Make sure your service providers implement reasonable security measures.
- Put procedures in place to keep your security current and address vulnerabilities that may arise.
- Secure paper, physical media, and devices.
Cyber Security is Everyone’s Responsibility
Data breaches resulting in the compromise of personally identifiable information of thousands of Americans. Intrusions into financial, corporate, and government networks. Complex financial schemes committed by sophisticated cyber criminals against businesses and the public in general.
These are just a few examples of crimes perpetrated online over the past year or so, and part of the reason why Director James Comey, testifying before Congress last week, said that “the pervasiveness of the cyber threat is such that the FBI and other intelligence, military, homeland security, and law enforcement agencies across the government view cyber security and cyber attacks as a top priority.” The FBI, according to Comey, targets the most dangerous malicious cyber activity—high-level intrusions by state-sponsored hackers and global cyber syndicates, and the most prolific botnets. And in doing so, we work collaboratively with our domestic and international partners and the private sector.
But it’s important for individuals, businesses, and others to be involved in their own cyber security. And National Cyber Security Awareness Month—a Department of Homeland Security-administered campaign held every October—is perhaps the most appropriate time to reflect on the universe of cyber threats and on doing your part to secure your own devices, networks, and data.
What are some of the more prolific cyber threats we’re currently facing?
Ransomware is type of malware that infects computers and restricts users’ access to their files or threatens the permanent destruction of their information unless a ransom is paid. In addition to individual users, ransomware has infected entities such as schools, hospitals, and police departments. The actors behind these sophisticated schemes advise the users that if they pay the ransom, they will receive the private key needed to decrypt the files. Most recently, these cyber criminals—demonstrating some business savvy—give victims the option of decrypting one file for free to prove that they have the ability to restore the locked files. More on ransomware.
Business e-mail compromise, or BEC, scams continue to impact many businesses across the U.S. and abroad. BEC is a type of payment fraud that involves the compromise of legitimate business e-mail accounts—often belonging to either the chief executive officer or the chief financial officer—for the purpose of conducting unauthorized wire transfers. After compromising a company’s e-mail account—usually through social engineering or malware—the criminals are then able to send wire transfer instructions using the victim’s e-mail or a spoofed e-mail account. BEC scams have been reported in all 50 states and in 100 countries and have caused estimated losses of more than $3 billion worldwide. More on BEC scams.
Intellectual property theft involves robbing individuals or companies of their ideas, inventions, and creative expressions—often stolen when computers and networks are accessed by unscrupulous competitors, hackers, and other criminals. Intellectual property can include everything from trade secrets and proprietary products and parts to movies, music, and software. And the enforcement of laws protecting intellectual property rights (IPR)—which are critical to protecting the U.S. economy, our national security, and the health and safety of the American public—is an FBI criminal priority. The Bureau’s IPR focus is the theft of trade secrets and infringements on products that can impact consumers’ health and safety, including counterfeit aircraft, automotive, and electronic parts. More on intellectual property theft.
“The FBI is doing everything we possibly can, at every level, to make it harder for cyber criminals to operate,” says Associate Executive Assistant Director David Johnson, “and I believe many of them are now starting to think twice before they put fingers to keyboard. But we also ask that the public do its part by taking precautions and implementing safeguards to protect their own data.”
Check back on our website during the month of October for information on protecting your data and devices and on FBI efforts to combat the most egregious cyber criminals.
- Internet Crime Complaint Center (IC3)
- More on National Cyber Security Awareness Month
- Department of Justice’s Best Practices for Victim Response and Reporting of Cyber Incidents
- U.S. Computer Emergency Readiness Team cyber security tips
- Department of Homeland Security cyber security information
- Stay Safe Online website
- FBI Cyber’s Most Wanted
- More on FBI efforts to combat cyber crime
- We all have seen the “cards in the seat pockets in front of you” on a plane. Simply figure out how to divide your sanctuary spaces so that all of the exits will be used and create a chart like the one below, reproduce it and stick it in the pockets in front of the pews.
- No one expects you to conduct a fire drill on Yom Kippur, but you can ask your ushers and key staff to attend a rehearsal meeting in advance of services. Discuss your plans and their roles with them ahead of time.
- Pre-write directions that should be kept on the bimah. In the event of an emergency you shouldn’t count on people to call an “audible” (i.e., improvise).
September 15, 2016/Alert Number I-091516-PSA
RANSOMWARE VICTIMS URGED TO REPORT INFECTIONS TO FEDERAL LAW ENFORCEMENT
The FBI urges victims to report ransomware incidents to federal law enforcement to help us gain a more comprehensive view of the current threat and its impact on U.S. victims.
What Is Ransomware?
Ransomware is a type of malware installed on a computer or server that encrypts the files, making them inaccessible until a specified ransom is paid. Ransomware is typically installed when a user clicks on a malicious link, opens a file in an e-mail that installs the malware, or through drive-by downloads (which does not require user-initiation) from a compromised Web site.
Why We Need Your Help
New ransomware variants are emerging regularly. Cyber security companies reported that in the first several months of 2016, global ransomware infections were at an all-time high. Within the first weeks of its release, one particular ransomware variant compromised an estimated 100,000 computers a day.
Ransomware infections impact individual users and businesses regardless of size or industry by causing service disruptions, financial loss, and in some cases, permanent loss of valuable data. While ransomware infection statistics are often highlighted in the media and by computer security companies, it has been challenging for the FBI to ascertain the true number of ransomware victims as many infections go unreported to law enforcement.
Victims may not report to law enforcement for a number of reasons, including concerns over not knowing where and to whom to report; not feeling their loss warrants law enforcement attention; concerns over privacy, business reputation, or regulatory data breach reporting requirements; or embarrassment. Additionally, those who resolve the issue internally either by paying the ransom or by restoring their files from back-ups may not feel a need to contact law enforcement.
The FBI is urging victims to report ransomware incidents regardless of the outcome. Victim reporting provides law enforcement with a greater understanding of the threat, provides justification for ransomware investigations, and contributes relevant information to ongoing ransomware cases. Knowing more about victims and their experiences with ransomware will help the FBI to determine who is behind the attacks and how they are identifying or targeting victims.
Threats to Users
All ransomware variants pose a threat to individual users and businesses. Recent variants have targeted and compromised vulnerable business servers (rather than individual users) to identify and target hosts, thereby multiplying the number of potential infected servers and devices on a network. Actors engaging in this targeting strategy are also charging ransoms based on the number of host (or servers) infected. Additionally, recent victims who have been infected with these types of ransomware variants have not been provided the decryption keys for all their files after paying the ransom, and some have been extorted for even more money after payment.
This recent technique of targeting host servers and systems could translate into victims paying more to get their decryption keys, a prolonged recovery time, and the possibility that victims will not obtain full decryption of their files.
What to Report to Law Enforcement
The FBI is requesting victims reach out to their local FBI office and/or file a complaint with the Internet Crime Complaint Center, at www.IC3.gov, with the following ransomware infection details (as applicable):
- Date of Infection
- Ransomware Variant (identified on the ransom page or by the encrypted file extension)
- Victim Company Information (industry type, business size, etc.)
- How the Infection Occurred (link in e-mail, browsing the Internet, etc.)
- Requested Ransom Amount
- Actor’s Bitcoin Wallet Address (may be listed on the ransom page)
- Ransom Amount Paid (if any)
- Overall Losses Associated with a Ransomware Infection (including the ransom amount)
- Victim Impact Statement
The FBI does not support paying a ransom to the adversary. Paying a ransom does not guarantee the victim will regain access to their data; in fact, some individuals or organizations are never provided with decryption keys after paying a ransom. Paying a ransom emboldens the adversary to target other victims for profit, and could provide incentive for other criminals to engage in similar illicit activities for financial gain. While the FBI does not support paying a ransom, it recognizes executives, when faced with inoperability issues, will evaluate all options to protect their shareholders, employees, and customers.
The FBI recommends users consider implementing the following prevention and continuity measures to lessen the risk of a successful ransomware attack.
- Regularly back up data and verify the integrity of those backups. Backups are critical in ransomware incidents; if you are infected, backups may be the best way to recover your critical data.
- Secure your backups. Ensure backups are not connected to the computers and networks they are backing up. Examples might include securing backups in the cloud or physically storing them offline. It should be noted, some instances of ransomware have the capability to lock cloud-based backups when systems continuously back up in real-time, also known as persistent synchronization.
- Scrutinize links contained in e-mails and do not open attachments included in unsolicited e-mails.
- Only download software – especially free software – from sites you know and trust. When possible, verify the integrity of the software through a digital signature prior to execution.
- Ensure application patches for the operating system, software, and firmware are up to date, including Adobe Flash, Java, Web browsers, etc.
- Ensure anti-virus and anti-malware solutions are set to automatically update and regular scans are conducted.
- Disable macro scripts from files transmitted via e-mail. Consider using Office Viewer software to open Microsoft Office files transmitted via e-mail instead of full Office Suite applications.
- Implement software restrictions or other controls to prevent the execution of programs in common ransomware locations, such as temporary folders supporting popular Internet browsers, or compression/decompression programs, including those located in the AppData/LocalAppData folder.
Additional considerations for businesses include the following:
- Focus on awareness and training. Because end users are often targeted, employees should be made aware of the threat of ransomware, how it is delivered, and trained on information security principles and techniques.
- Patch all endpoint device operating systems, software, and firmware as vulnerabilities are discovered. This precaution can be made easier through a centralized patch management system.
- Manage the use of privileged accounts by implementing the principle of least privilege. No users should be assigned administrative access unless absolutely needed. Those with a need for administrator accounts should only use them when necessary; they should operate with standard user accounts at all other times.
- Configure access controls with least privilege in mind. If a user only needs to read specific files, he or she should not have write access to those files, directories, or shares.
- Use virtualized environments to execute operating system environments or specific programs.
- Categorize data based on organizational value, and implement physical/logical separation of networks and data for different organizational units. For example, sensitive research or business data should not reside on the same server and/or network segment as an organization’s e-mail environment.
- Require user interaction for end user applications communicating with Web sites uncategorized by the network proxy or firewall. Examples include requiring users to type in information or enter a password when the system communicates with an uncategorized Web site.
- Implement application whitelisting. Only allow systems to execute programs known and permitted by security policy.
High Holiday Security and Emergency Preparedness Planning Library
- 10 Simple Ways to Make Your Synagogue Safer During the Holidays and Year Round (PDF)
- JCRC-NY High Holiday Security Thinkplate®: 2014
- Access control considerations during High Holiday services (PDF)
- Houses of Worship and the High Holidays (PDF)
- Planning for the Unexpected – High Holiday Edition 2010 (PDF)
Synagogue-specific Security & Emergency Planning
- JCRC-NY: Sample Building Access Policies & Procedures
- JCRC-NY: Security & Emergency Preparedness Committees
- DHS: Potential Indicators, Common Vulnerabilities, and Protective Measures: Religious Facilities
- FEMA: Guide for Developing High-Quality Emergency Operations Plans for Houses of Worship
- National Counter Terrorism Security Office, United Kingdom: Counter Terrorism Protective Security Advice for Places of Worship
Consider the following elements of heightened vigilance:
- Increase visible security measures. Someone planning an attack may look at your facility, conclude that it is defended and decide to go elsewhere. Several recent incidents also underscore that the presence of armed security and law enforcement personnel and the placement of security checkpoints do not guarantee that an attack will be averted or interupted. Nevertheless, their presence can enable the timely discovery and quick resolution of potential threats and reduce the lethality of terrorist attacks.
- Review your policies and procedures. How else can you send a signal to outsiders that your facility is a tough target? For example, does your staff do regular inspections of your facility looking for something that, “Just doesn’t look right?” If not, start now. If they do, should you increase the frequency. Review JCRC’s Sample Access Policies and Procedures to identify additional steps.
- Test your systems. OK, you’ve identified systems to screen your mail, respond to bomb threats and suspicious objects and you have an active shooters plan. The key question is: “Will they work in reality?” Do your panic buttons function? Test them (after you first alert the alarm company). Have you had tabletop exercises and drills covering multiple hazards? How can you make sure that your entire staff and constituencies are on their collective toes?
- Check in with your local police. For most Jewish organizations, September is the start of a new program year. Reach out to your local police. Offer them the opportunity to get to know your programs, your rhythms, your people and your building. Ask them for suggestions as to how to make your people safer.
- If you see something, say something. Think how to build a culture of security, because security is everbody’s business. If any of your staff, students, volunteers, congregants or clients sees or hears something suspicious they should feel comfortable to report it to the appropriate person in your facility and the information should be passed on to the police. In NYC the number is 1-888-NYC-SAFE. Elsewhere in New York State the number is 1-866-SAFE-NYS. Every tip is investigated.