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Compliance Journal Authors: Elizabeth White, Don MacVittie, Fouad Khalil, Jason Bloomberg, Pat Romanski

Related Topics: Cloud Computing, Security Journal, Compliance Journal

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When Compliance Comes Down to Security | @CloudExpo #Cloud #Security

The top three regulations and how you can prepare

In the business world, it's hard to throw a rock without hitting a compliance requirement. All must be obeyed, but some call for a high level of control and auditability. Governing bodies are exerting their authority like never before, increasing the number of auditors and handing out heavy fines - sometimes as much as $1 million.

This has become the new norm, and it isn't likely to turn around any time soon. It's important, then, to be aware of the primary threats that could undermine compliance efforts. The top three such issues are discussed below.

The Challenges of SOX
Public companies in the U.S. as well as foreign companies listed on U.S. exchanges are required by Sarbanes-Oxley (SOX) to assess their internal controls, have that assessment validated by an external auditor and report the assessment to the SEC. Information security professionals need to ensure that their organization complies with requirement in Section 302 and Section 404 of the legislation.

For the financial industry, SOX-404 and internal controls remain the most critical on the compliance horizon. Financial industry compliance challenges include Annual Financial and SSAE-16 audit requirements. However, audits of identity management (logical access) controls continue to result in exceptions. Companies struggle with adherence to privileged access controls - lack of visibility into what, when and how administrators access production environments.

SSH keys are a critical component for ensuring adequate and compliant controls for cardholder data environments. However, many organizations have no visibility into or assume compliance with their SSH key environments until an auditor identifies the issue or exception in their reports. SSH is one of those unseen workhorses in IT infrastructures, which is why it is also referred to as the "dark side" of PCI DSS compliance.

Financial institutions have expanded their business models beyond simply doing payroll, tax, investments, etc. They have taken on additional services to expand their markets and revenue potential. These vary from complete HR services to retirement services to medical payment services and much more. But changing industry business models change the threat landscape and expand the definition of sensitive information. Their protected data definitions now go beyond SSN and DOB to also include credit card data and medical data (protected health information). This increases the complexity of their compliance initiatives and the scrutiny of the audits they start to undergo.

Managing Privileged Access
The privileged and logical access controls within privileged access management (PAM) will continue to be a compliance nightmare. They cause the most audit infractions. One of the main reasons for this is the fact that more companies are outsourcing tech support, and more companies are employing remote workers. Both of these groups must be granted remote access to an organization's production environment and highly sensitive information in order to do their jobs. This access also includes machines talking to other machines in an automated fashion.

Enterprises must grant third-party access to a variety of vendors and contractors, but managing this access often comes as an afterthought in the organization's overall security strategies and postures. The 2014 U.S. State of Cybercrime Survey revealed some dangerous trends on this topic:

  • Seventy percent of enterprises enter into contracts with external vendors without having conducted any security checks
  • Only 44 percent of enterprises put forth the effort to vet the security of third-party providers and others in their IT supply chain

Better security and privacy controls may be supported by third-party and vendor contract agreements, but these actions may not exclude organizations from accountability and responsibility as it relates to a security breach.

HIPAA HITECH
If SOX-404 were a cat, HIPAA/HITECH would be a lion in comparison. Organizations may have to comply with PCI, FISMA, SOX, BASEL III or other regulations, but none of these are a match for the HIPAA/HITECH tidal wave in terms of severity. The U.S. federal government (Health and Human Services, Office for Civil Rights) is more active than ever in enforcing this law and is levying harsher fines with greater frequency for noncompliance.

Regulatory bodies have kept track of the areas that healthcare providers have failed at most often in the past, and auditors are concentrating their firepower in those areas and are levying massive fines for noncompliance. Targeted areas include:

  • Risk analysis and risk management
  • Content and timeliness of breach notifications
  • Notice of privacy practices
  • Individual access
  • Training to policies and procedures
  • Device and media controls
  • Transmission security

As enterprises branch out into new markets, they will need to exercise caution regarding whether those markets are covered by HIPAA and whether they are being compliant to avoid being hit with heavy fines.

Compliance via SSH Security
With so many regulations to keep in mind and so many financial and legal risks, the following best practices can help enterprises improve their SSH environment security - and, therefore, their compliance.

1. No more manual key management
If you insist on manually managing keys, you are relegating your highly skilled IT staff to the mental equivalent of drudgery. A centralized SSH key management system not only ameliorates the issues listed above, it increases your ROI by letting your IT staff tackle more complicated issues.

2. Take control of your SSH key deployment
While most SSH key deployments are straightforward, rotation and removal can be tricky. Control who can add keys to your environment, and deploy, remove and rotate keys in a centralized way. Sometimes a rotated key can create a new vulnerability. This encourages the tendency to leave a key in place long after its original user has moved on. Automate SSH key rotation.

3. Take inventory to understand your environment
You will need to find out how many SSH keys you have, where they are and which users have which keys. Once you understand your environment, you can take steps to tame it.

4. The ability to audit in real time
Lest you end up on the wrong side of a SOX audit, your auditors need to be able to view the source of any breach clearly and perform an audit trail. Make sure your organization has a system in place to provide auditors with exactly the information they need, when they need it.

The Whole Compliance Package
With penalties as high as a million dollars, organizations cannot afford to not be compliant. As they consider compliance risks across their business, they need to honestly assess whether they could survive an audit. Continuous compliance should become the goal, facilitated by security and privacy controls interwoven into day-to-day processes and procedures. When the inevitable breach does occur, having integrated security controls in place will go a long way toward both ensuring compliance with reporting requirements and expedite breach investigations.

More Stories By Fouad Khalil

Fouad Khalil is VP of Compliance at SSH Communication Security with extensive experience in the technology space with more than 25 years spanning disciplines in software development, IT support, program and project management and most recently IT Security and Compliance management. He has come up the technology ladder his entire career from network, system and database administration, software programming, system, software and GUI design, project and product development, solution implementation and much more.

He has been an active member in ISACA, IIA and Infragard for over ten (10) years and an active contributor to ISSA and ISC2 regionally and nationwide. He is CISA and ITIL Foundations certified.

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