Some notes on Trump's cybersecurity Executive Order

President Trump has finally signed an executive order on "cybersecurity". The first draft during his first weeks in power were hilariously ignorant. The current draft, though, is pretty reasonable as such things go. I'm just reading the plain language of the draft as a cybersecurity expert, picking out the bits that interest me. In reality, there's probably all sorts of politics in the background that I'm missing, so I may be wildly off-base.

Holding managers accountable

This is a great idea in theory. But government heads are rarely accountable for anything, so it's hard to see if they'll have the nerve to implement this in practice. When the next breech happens, we'll see if anybody gets fired.

"antiquated and difficult to defend Information Technology"

The government uses laughably old computers sometimes. Forces in government wants to upgrade them. This won't work. Instead of replacing old computers, the budget will simply be used to add new computers. The old computers will still stick around.

"Legacy" is a problem that money can't solve. Programmers know how to build small things, but not big things. Everything starts out small, then becomes big gradually over time through constant small additions. What you have now is big legacy systems. Attempts to replace a big system with a built-from-scratch big system will fail, because engineers don't know how to build big systems. This will suck down any amount of budget you have with failed multi-million dollar projects.

It's not the antiquated systems that are usually the problem, but more modern systems. Antiquated systems can usually be protected by simply sticking a firewall or proxy in front of them.

"address immediate unmet budgetary needs necessary to manage risk"

Nobody cares about cybersecurity. Instead, it's a thing people exploit in order to increase their budget. Instead of doing the best security with the budget they have, they insist they can't secure the network without more money.

An alternate way to address gaps in cybersecurity is instead to do less. Reduce exposure to the web, provide fewer services, reduce functionality of desktop computers, and so on. Insisting that more money is the only way to address unmet needs is the strategy of the incompetent.

Use the NIST framework

Probably the biggest thing in the EO is that it forces everyone to use the NIST cybersecurity framework.

The NIST Framework simply documents all the things that organizations commonly do to secure themselves, such run intrusion-detection systems or impose rules for good passwords.

There are two problems with the NIST Framework. The first is that no organization does all the things listed. The second is that many organizations don't do the things well.

Password rules are a good example. Organizations typically had bad rules, such as frequent changes and complexity standards. So the NIST Framework documented them. But cybersecurity experts have long opposed those complex rules, so have been fighting NIST on them.

Another good example is intrusion-detection. These days, I scan the entire Internet, setting off everyone's intrusion-detection systems. I can see first hand that they are doing intrusion-detection wrong. But the NIST Framework recommends they do it, because many organizations do it, but the NIST Framework doesn't demand they do it well.

When this EO forces everyone to follow the NIST Framework, then, it's likely just going to increase the amount of money spent on cybersecurity without increasing effectiveness. That's not necessarily a bad thing: while probably ineffective or counterproductive in the short run, there might be long-term benefit aligning everyone to thinking about the problem the same way.

Note that "following" the NIST Framework doesn't mean "doing" everything. Instead, it means documented how you do everything, a reason why you aren't doing anything, or (most often) your plan to eventually do the thing.

preference for shared IT services for email, cloud, and cybersecurity

Different departments are hostile toward each other, with each doing things their own way. Obviously, the thinking goes, that if more departments shared resources, they could cut costs with economies of scale. Also obviously, it'll stop the many home-grown wrong solutions that individual departments come up with.

In other words, there should be a single government GMail-type service that does e-mail both securely and reliably.

But it won't turn out this way. Government does not have "economies of scale" but "incompetence at scale". It means a single GMail-like service that is expensive, unreliable, and in the end, probably insecure. It means we can look forward to government breaches that instead of affecting one department affecting all departments.

Yes, you can point to individual organizations that do things poorly, but what you are ignoring is the organizations that do it well. When you make them all share a solution, it's going to be the average of all these things -- meaning those who do something well are going to move to a worse solution.

I suppose this was inserted in there so that big government cybersecurity companies can now walk into agencies, point to where they are deficient on the NIST Framework, and say "sign here to do this with our shared cybersecurity service".

"identify authorities and capabilities that agencies could employ to support the cybersecurity efforts of critical infrastructure entities"

What this means is "how can we help secure the power grid?".

What it means in practice is that fiasco in the Vermont power grid. The DHS produced a report containing IoCs ("indicators of compromise") of Russian hackers in the DNC hack. Among the things it identified was that the hackers used Yahoo! email. They pushed these IoCs out as signatures in their "Einstein" intrusion-detection system located at many power grid locations. The next person that logged into their Yahoo! email was then flagged as a Russian hacker, causing all sorts of hilarity to ensue, such as still uncorrected stories by the Washington Post how the Russians hacked our power-grid.

The upshot is that federal government help is also going to include much government hindrance. They really are this stupid sometimes and there is no way to fix this stupid. (Seriously, the DHS still insists it did the right thing pushing out the Yahoo IoCs).

Resilience Against Botnets and Other Automated, Distributed Threats

The government wants to address botnets because it's just the sort of problem they love, mass outages across the entire Internet caused by a million machines.

But frankly, botnets don't even make the top 10 list of problems they should be addressing. Number #1 is clearly "phishing" -- you know, the attack that's been getting into the DNC and Podesta e-mails, influencing the election. You know, the attack that Gizmodo recently showed the Trump administration is partially vulnerable to. You know, the attack that most people blame as what probably led to that huge OPM hack. Replace the entire Executive Order with "stop phishing", and you'd go further fixing federal government security.

But solving phishing is tough. To begin with, it requires a rethink how the government does email, and how how desktop systems should be managed. So the government avoids complex problems it can't understand to focus on the simple things it can -- botnets.


Dealing with "prolonged power outage associated with a significant cyber incident"

The government has had the hots for this since 2001, even though there's really been no attack on the American grid. After the Russian attacks against the Ukraine power grid, the issue is heating up.

Nation-wide attacks aren't really a threat, yet, in America. We have 10,000 different companies involved with different systems throughout the country. Trying to hack them all at once is unlikely. What's funny is that it's the government's attempts to standardize everything that's likely to be our downfall, such as sticking Einstein sensors everywhere.

What they should be doing is instead of trying to make the grid unhackable, they should be trying to lessen the reliance upon the grid. They should be encouraging things like Tesla PowerWalls, solar panels on roofs, backup generators, and so on. Indeed, rather than industrial system blackout, industry backup power generation should be considered as a source of grid backup. Factories and even ships were used to supplant the electric power grid in Japan after the 2011 tsunami, for example. The less we rely on the grid, the less a blackout will hurt us.


"cybersecurity risks facing the defense industrial base, including its supply chain"

So "supply chain" cybersecurity is increasingly becoming a thing. Almost anything electronic comes with millions of lines of code, silicon chips, and other things that affect the security of the system. In this context, they may be worried about intentional subversion of systems, such as that recent article worried about Kaspersky anti-virus in government systems. However, the bigger concern is the zillions of accidental vulnerabilities waiting to be discovered. It's impractical for a vendor to secure a product, because it's built from so many components the vendor doesn't understand.



"strategic options for deterring adversaries and better protecting the American people from cyber threats"

Deterrence is a funny word.

Rumor has it that we forced China to backoff on hacking by impressing them with our own hacking ability, such as reaching into China and blowing stuff up. This works because the Chinese governments remains in power because things are going well in China. If there's a hiccup in economic growth, there will be mass actions against the government.

But for our other cyber adversaries (Russian, Iran, North Korea), things already suck in their countries. It's hard to see how we can make things worse by hacking them. They also have a strangle hold on the media, so hacking in and publicizing their leader's weird sex fetishes and offshore accounts isn't going to work either.

Also, deterrence relies upon "attribution", which is hard. While news stories claim last year's expulsion of Russian diplomats was due to election hacking, that wasn't the stated reason. Instead, the claimed reason was Russia's interference with diplomats in Europe, such as breaking into diplomat's homes and pooping on their dining room table. We know it's them when they are brazen (as was the case with Chinese hacking), but other hacks are harder to attribute.

Deterrence of nation states ignores the reality that much of the hacking against our government comes from non-state actors. It's not clear how much of all this Russian hacking is actually directed by the government. Deterrence polices may be better directed at individuals, such as the recent arrest of a Russian hacker while they were traveling in Spain. We can't get Russian or Chinese hackers in their own countries, so we have to wait until they leave.

Anyway, "deterrence" is one of those real-world concepts that hard to shoe-horn into a cyber ("cyber-deterrence") equivalent. It encourages lots of bad thinking, such as export controls on "cyber-weapons" to deter foreign countries from using them.


"educate and train the American cybersecurity workforce of the future"

The problem isn't that we lack CISSPs. Such blanket certifications devalue the technical expertise of the real experts. The solution is to empower the technical experts we already have.

In other words, mandate that whoever is the "cyberczar" is a technical expert, like how the Surgeon General must be a medical expert, or how an economic adviser must be an economic expert. For over 15 years, we've had a parade of non-technical people named "cyberczar" who haven't been experts.

Once you tell people technical expertise is valued, then by nature more students will become technical experts.

BTW, the best technical experts are software engineers and sysadmins. The best cybersecurity for Windows is already built into Windows, whose sysadmins need to be empowered to use those solutions. Instead, they are often overridden by a clueless cybersecurity consultant who insists on making the organization buy a third-party product instead that does a poorer job. We need more technical expertise in our organizations, sure, but not necessarily more cybersecurity professionals.


Conclusion

This is really a government document, and government people will be able to explain it better than I. These are just how I see it as a technical-expert who is a government-outsider.

My guess is the most lasting consequential thing will be making everyone following the NIST Framework, and the rest will just be a lot of aspirational stuff that'll be ignored.