DoD CMMC Version 0.6 Released

The US Department of Defense released version 0.6 of its Cybersecurity Maturity Model Certification program on Thursday, November 7, 2019.

More Ratings Clarity

As we have previously discussed, the CMMC will use a maturity rating system to assess not only the technical controls that are in place (which the DoD refers to in the CMMC as “practices”), but also the policies and procedures that the contractor has implemented to help guide the use of that technology.

The maturity ratings will range from level 1 to level 5, and the contractor will be rated separately for the controls and the polices. This rating system is used for each of the seventeen (17) different “domains” defined within the CMMC.

The DoD recognizes that many of its contractors are likely to still be rushing to get themselves to at least an overall rating of level 3 for each domain (which the DoD appears to suggest as a “reasonable” baseline for security), and thus this version focuses on the requirements to meet levels 1-3. Requirements for levels 4 and 5 are left for a later version.

It should be noted that a contractor’s overall maturity rating in each domain will be equal to the lowest of the two maturity ratings. That is, an contractor that has superior technical controls in a particular domain (i.e., one deserving a 5 rating) but which has yet to implement any policies and procedures (i.e., one deserving a 1 rating) will only be given an overall maturity rating of 1 for that domain.

Ratings Requirements in Government Contracts

It remains unclear how the DoD will specify the maturity level required for a given contract. For example, we know that the contractor will be rated across each of the domains, but it is not yet clear whether a contractor will have a single, aggregate rating that will be used for assessment on a particular contract, or if the contracts are expected take a more granular view, specifying each of the ratings across all of the domains. From earlier comments by the DoD, it would appear that they are likely to use a single, aggregate rating and that it will be the lowest rating across all domains. Clarity on this issue would be beneficial because it will allow contractors to prioritize their remediation and enhancement efforts within their Plan of Action and Milestones (“POAM”).

CMMC Domains

As discussed above, the CMMC divides cybersecurity into seventeen (17) domains. These domains are:

  • Access Control (AC)
  • Asset Management (AM)
  • Audit and Accountability (AA)
  • Awareness and Training (AT)
  • Configuration Management (CM)
  • Identification and Authentication (IDA)
  • Incident Response (IR)
  • Maintenance (MA)
  • Media Protection (MP)
  • Personnel Security (PS)
  • Physical Protection (PP)
  • Recovery (RE)
  • Risk Management (RM)
  • Security Assessment (SAS)
  • Situational Awareness (SA)
  • Systems and Communications Protections (SCP) and
  • System and Information Integrity (SII)

Much like the NIST Cybersecurity Framework’s Functions (Identify, Protect, Detect, Respond, Recover) and their corresponding controls categories, at a high level, the CMMC domains can be useful for organizations’ management, including boards and the C-Suite, as a means for organizing discussions around issues to be addressed by, or being addressed in, their organization’s cybersecurity strategy. This can allow for a more granular discussion between the security/technology teams and the contractor’s senior management without the senior management having to become experts in any particular domain. For self-assessment purposes, these domains and the corresponding maturity within them can be very useful for contractors as they assess how to invest their hard-earned IT and security budgets.

A Missing Domain

However, as is common with many cybersecurity strategies, the DoD has overlooked a key domain: legal and regulatory concerns. While it appears from the comments in Appendix B that the DoD may intend the legal and regulatory aspects to be included across all of the domains, many organizations are not aware of their legal and regulatory exposure. Forcing contractors to explicitly address this as part of their maturity assessment will be beneficial. For example, many organizations’ incident response plans focus on data privacy reporting obligations and do not address their cybersecurity incident reporting requirements, such as those imposed by the Securities and Exchange Commission. The failure to address the full spectrum of legal and regulatory requirements as part of an incident response plan is a strong indicator of the overall maturity of the contractor’s approach to its cybersecurity strategy. Thus, legal and regulatory domain should be incorporated into the CMMC’s requirements.

Capabilities and Practices

Version 0.6 adds additional clarity within each of the domains as to what the DoD expects of its contractors. There are now a set of 40 defined capabilities, or achievements to ensure cybersecurity objectives are met within each domain. Each of these capabilities has associated with it at least one practice that is to be implemented to demonstrate compliance with that practice. Different practices are assigned to different maturity levels. Each practice also has associated with it one or more external references. These external references are provided to help practitioners understand how the practices are to be implemented, but strict compliance with the external references is not required to achieve CMMC certification.

Conflicting Messaging

While the CMMC represents a significant improvement over most organizations’ approach to cybersecurity, version 0.6 of the CMMC still misses the boat. The NIST Cybersecurity Framework and the Cybersecurity & Infrastructure Security Agency’s “Cyber Essentials” for small and medium businesses both encourage businesses to conduct a thorough business assessment before making any significant technology investments. However, CMMC v.0.6 encourages contractors to treat cybersecurity primarily as a technological problem. This is evidenced in part by the way the technical domains are prioritized over more business-oriented domains like risk management. For example, organizations can achieve a level 2 rating without ever even considering risk management, which is a mistake as it forces the DoD’s contractors to invest in technologies that may not be necessary and prioritizes doing something over doing the right thing. Even within the Audit and Accountability domain, a domain which by its title should be focused more on business-level issues, the proscribed practices are purely technology focused. The US Government, and especially the Executive Branch agencies entrusted with protecting our nation, should be providing consistent messaging and prioritization to everyone on this very important topic.


We believe the NIST/CISA approach to be the approach that will provide the best value to both the contractor and the DoD, and is also the approach that is more likely to result better cybersecurity as the contractor will have business-oriented reasons for maintaining and enhancing the programs rather than it being treated as a compliance-type expense from which the business derives limited value. In addition, under the CMMC’s current approach, contractors are likely to spend money on practices that will have only a marginal improvement on their actual security while ignoring other controls from which they would greatly benefit. The DoD needs to bring the level 1 requirements more in line with the NIST Cybersecurity Framework and CISA’s guidance.

We also want to stress that we support the DoD’s efforts with respect to the CMMC. Requiring contractors to change the way they view and address cybersecurity is a long overdue change. However, there are some fundamental issues that need to be addressed. We hope the DoD will reassess its approach and address these issues before version 1.0 is released.

Microsoft is Helping to Combat Ransomware

Image Courtesy Microsoft

Some users of Office 365 will soon have a new tool to fight ransomware.  As we noted in our recent article on corporate ransomware protection, one of the most common ways companies are infected with ransomware is through infected Microsoft Office files.  These files typically have macros, or computer programs, embedded in them that kick off the ransomware infection.  Microsoft recently announced that users of Office 365 ProPlus will soon be able to open all documents from untrusted sources (e.g., anything sent via E-mail or downloaded from the Internet) using “Microsoft Office Application Guard,” a separate virtual environment.  The virtual environment is isolated from the user’s operating system and standard programs, and is destroyed when the user logs out.  This means that any infection that may be caused by the untrusted document should not be able to infect the user’s computer, and will be destroyed within the virtual environment when the user logs out.  This should significantly limit the spread of ransomware, or at least force the criminals to find other approaches for infecting user computers.

We expect to see Microsoft make this available to lower-tier Office 365 users in the near future as well. If your organization uses Office 365, we encourage you to take advantage of this exciting security feature which should help significantly reduce your organization’s attack surface.

That being said, no security system is perfect.  For example, a file may be run in the virtual environment without any negative effects being detected, but it may include a “sleeper” version of the ransomware that waits days, or even months, before it will launch.  Others may seek to detect whether they are being launched in the virtual environment and, if detected, may postpone any malicious activity until they are outside the virtual environment.  Still others may attempt to escape the virtual environment by exploiting vulnerabilities.

In the end, as we discussed previously, disabling macros can significantly reduce your attack surface.  If you must enable macros, the Australian Cyber Security Center has created this handy chart that outlines some of the risks associated with the different levels of macros.

(Source: Australian Cyber Security Center)  

Corporate Ransomware Protection

Recent headlines have touted the fact that the number of ransomware attacks are down. However, before you breathe a sigh of relief, it is important to understand that the number of attacks has dropped because fewer criminals are indiscriminately sending malware-infected files and links to anyone and everyone (although this technique, referred to as “phishing,” does still happen quite a bit!). Instead, many have shifted to targeting corporations, healthcare providers, schools, governments, and other entities with deeper pockets. We will refer to this as “corporate ransomware,” although it is important to remember that the criminals are targeting non-corporate entities, too.

Anatomy of a Corporate Ransomware Attack

To understand what is happening in a ransomware attack, it is helpful to understand both what the victim sees and the approaches typically undertaken by the criminals. If you are already familiar with these topics, you can skip ahead.

The Victim’s View of the Attack

A ransomware attack involves the criminal locking the victim’s data with a key that only the criminal controls. The criminal then holds the data for ransom which is frequently demanded in “altcoin” or cryptocurrecies, such as Bitcoin or Etherium. The criminals typically threaten to delete the key within a certain amount of time (e.g., 3 days) unless the ransom is paid.

The process of locking the data can take several forms, and is generally called “encrypting” the data. To gain access to the data, the victim must either purchase the key from the criminal (i.e., pay the ransom) or find a tool to reverse the encryption (called decrypting the data). While decryption tools do exist, criminals change their tactics frequently and will adopt new forms of encryption to render the decryption tools useless.

The Criminal’s View of a Corporate Ransomware Attack

Corporate ransomware attacks involve more up-front work on the part of the criminals. The criminals typically choose one of two attack vectors: social engineering and spear phishing, or exploiting vulnerabilities in Internet-facing software and systems.

Social Engineering and Spear Phishing Attacks

Social engineering is the attack method preferred by many cyber criminals because it is highly effective. Social engineering involves gathering information about a victim using publicly available sources (referred to as “open source intelligence” or “OSINT”), including corporate websites, social media, print/online media, government records, and even by simply calling the corporation. The criminals use this OSINT to build a profile of their target corporation, including contact information for key individuals. Many criminals know that corporations have put in place additional features to protect their senior management, and thus the criminals may bypass those people as targets. Instead they target those in the corporation’s upper-middle-management who are less likely to think they are the target of an attack, making them easier victims. Targeting a few individuals, a practice called spear phishing, reduces the likelihood that the E-mail, text, WhatsApp, or other messages that the criminals will send to the victim will be identified as a potential problem. Spear phishing can be made even more effective through business E-mail compromise, a technique in which the criminal sends a message that impersonates someone else in the corporation, such as the CEO or the victim’s manager.

When the victim opens the message and clicks on the link or attachment in the message, they create a path through which the attacker can gain access to the victim’s corporate network account. This access allows the criminal to install additional software and change settings on the victim’s computer, and provides a footprint from which the criminal can malware laterally within the corporation. The criminal can also use the access to the victim’s account to send E-mails and other messages from the victim’s account(s) to the victim’s contacts. This practice, referred to as “Island Hopping”, can be very effective, as illustrated by the recent attack on the Los Angeles Court System and the attack on the US electrical grid.

Vulnerabilities in Internet-facing Software and Systems

As we discussed in our post about vulnerabilities, exploits, etc., computer hardware and software frequently contain flaws which create vulnerabilities in the hardware or software. In some cases the vulnerabilities are severe enough that criminals can exploit them to take control of the software or hardware. For example, a recently discovered flaw in the Remote Desktop Protocol that ships with Microsoft Windows can allow criminals to quickly take complete control over the target computer.

Identifying a target corporation’s computers and the vulnerabilities they contain can take some time, although there are automated tools like OpenVAS, Nessus, and OWASP Zap that can make this easier. The criminal uses the information gathered from these tools to identify specific exploits that can be leveraged to gain access to the system. Since this style of attack does not require a victim to take any action, these attacks can be significantly harder to detect, allowing the criminals to persist in the victim’s networks for a long time and thereby ensuring comprehensive damage when the ransomware is triggered.

The Return on Investment

The return on the criminals’ investment in corporate ransomware attacks is huge. Instead of typical individual ransomware attacks in which the victims are forced to pay a few hundred to a thousand dollars to decrypt their files, corporate ransomware victims must pay thousands of dollars, and in some cases significantly more (some have reportedly paid over $900,000 to decrypt their files).

Should you pay the Ransom?

Although it may be the only way for some victims to recover their files, paying the ransom is not typically recommended by the US Federal Bureau of Investigation (FBI) and other law enforcement agencies. This is for a variety of reasons, including the facts that it:

  • incentivizes the criminals to continue to target others;
  • encourages other criminals to turn to ransomware attacks; and,
  • may not result in the recovery of your data (yes, there are dishonest criminals).

Ransomware Protections

The best way to avoid a corporate ransomware attack is to be prepared. As discussed in detail below, Fathom Cyber’s recommended approach includes a combination of training, attack surface reduction, data backups, insurance, and planning.


As described above, your company’s employees are likely to be the targets of social media/spear phishing attacks like those described above. The best way to help them avoid falling victim to the attacks is to train them on how to recognize an attack and then to periodically test them to make sure they are keeping security top-of-mind.  Services like and Cofence’s PhishMe can help with this process.  Fathom Cyber also runs custom, spear phishing tests for our clients.

Reduce your Attack Surface

Employee awareness is critical toward reducing your organization’s likelihood of being the victim of a ransomware attack, but lets face it, everyone makes mistakes.  That is why employee training should not be your only defense.  Instead, your organization should reduce its attack surface.

Enable Multi-factor Authentication

Multi-factor authentication involves the use of more than just a username and password to login to a system.  It requires at least two of: something you know (e.g., the password), something you have (e.g., your phone or a “fob”), and something about you (e.g., your face, fingerprint, etc.).  In particular, the use of a fob or token-based code (such as  Microsoft Authenticator, Google Authenticator, or Duo), as opposed to SMS/text based codes, can make it significantly harder for ransomware to spread throughout your organization.  In fact, according to a recent Microsoft study, the use of multi-factor authentication would have prevented over 99% of recent account take-over attempts.  Since account takeover is a significant part of the way ransomware spreads, multi-factor authentication can reduce this portion of the organization’s attack surface.

Take Systems Offline or Require VPN Access

As we saw with the recent discovery of the Bluekeep vulnerability in Windows’ Remote Desktop Protocol (“RDP”), vulnerabilities in the software or operating systems running on any device that is exposed to the Internet can cause significant security problems.  Wherever possible, move devices behind a firewall that has only the minimum number of ports open to the Internet, and instead make the devices accessible only via a Virtual Private Network (“VPN”) tunnel through the firewall.  The VPN should require multi-factor authentication for all users and, where practical, equipment certificates as well.  Moving devices behind a firewall will significantly reduce the organization’s attack surface.

In the age of virtualization and containers, we also often see systems or containers stood up for a particular purpose (e.g., to test a new version of software).  However, what frequently happens is that those systems stay running even after they are no longer in use.  If a system or container does not need to be running, it should be taken offline.  This lessens the administrative burden and reduces the attack surface by reducing the number of devices that can be attacked.

Disable Macros

Macros can be powerful tools for automating repetitive tasks.  Unfortunately, macros are also used extensively by criminals when attacking a victim.  Disabling macros in Microsoft Office programs like Word, PowerPoint, and Excel, as well as non-Microsoft programs that have macro capabilities such as Adobe Acrobat will significantly reduce the organization’s attack surface.

Disable Unnecessary Browser Extensions

Browser extensions are a frequently overlooked source of vulnerabilities.  Depending on their source, the extensions may not be maintained to quickly remove newly-discovered vulnerabilities, and since the browser is the user’s primary interface with a malware-laden Internet, it is wise to disable all unnecessary browser extensions.  This should be done for all browsers permitted in the environment including Chrome, Edge, Internet Explorer, Firefox, and Safari.

Patch Systems

One way in which ransomware spreads is by exploiting known vulnerabilities in various software or hardware.  Keeping systems patched with the latest versions of software will significantly reduce the attack surface by taking away potentially exploitable vulnerabilities.  We typically recommend enabling automatic updates in an environment, especially for end-user devices.  As discussed above, users are targeted by phishing and spear phishing attacks, making their devices a common source of entry to the organization.  At the same time, many end-user devices run with few if any custom applications.  This makes any changes in an automated update much less likely to cause problems on the end-user device.

Automatically deploying software updates on servers and other equipment may require more analysis.  Servers frequently run custom software, and changes to the operating system or other software may have unexpected consequences that will have a more significant impact on the organization. Similarly, networking equipment plays a vital role in keeping the organization’s communications functioning properly, and any issues created by a software update may result in a significant impact on the organization. Therefore, we recommend more thorough testing before deploying updates to servers and communications equipment.

Back up Data

The steps outlined above are straightforward, and can often be implemented with little or no cost to the organization, but can result in a significant reduction to the organization’s attack surface.  However, the organization needs to prepare to recover from eventual successful ransomware attack. One of the best ways to recover from a ransomware attack is to restore the data from backups.

Online Backups

Some organizations use online, or cloud-based, data storage, such as Box, DropBox, OneDrive, Google Drive, etc., for their data storage.  This is very convenient, as it allows access to the data from anywhere.  However, online data storage should not be confused with backed up data.  Many ransomware authors actively search for and encrypt data stored in these online data stores.  Unless the online data is backed up (some online data storage providers offer this as an additional, fee-based option), the ransomware is likely to render the online unavailable just as it does the locally-stored files. 

One exception to this is online providers who store multiple versions of a file.  In that case, the customer may be able to recover an earlier, unencrypted version of the file.  You should consult with your online data storage provider to see if this option is available and, if not, consider backing up to offline media or paying the online data storage provider to back up the data.

Offline Backups

The best way to keep your data from being encrypted is to keep it out of reach by the ransomware.  This typically involves storing the data in an offline backup, such as tape or removable drive.  However, it should be stressed that this media must be taken offline except when it is being written to/read from for backup/recovery purposes. Otherwise, it will be encrypted by the ransomware!


Whether you decide to rely on offline backups, online backups, or an online data storage provider’s version control as your way of recovering from a ransomware attack, it is crucial that the backups are regularly tested to ensure they provide the information needed to get the organization up and running quickly.  It is also important to test for other aspects of a recovery scenario, including the installation of operating systems and software on new computers should that become necessary.  Testing can provide invaluable benchmarking data that can be used to show how investing in other cybersecurity tools (e.g., a properly configured Security Incident and Event Monitor, or SIEM), can be more cost-effective than relying on recovering from backups, especially when productivity and other losses are taken into account.

Cyber Insurance

Another important consideration in an overall ransomware incident response plan is whether the organization should purchase cyber insurance.  Cyber insurance is intended to give victims of a computer attack a way of covering their losses.  The problem is, many cyber insurers aren’t yet sure how to characterize the risks, and most policies are focused on one particular type of business (typically B-to-C like an E-commerce site (like Amazon) or a forum(like Yelp or Reddit)).  If your company is in the B-to-B space, you need to be much more selective about the policy you choose, because it may not cover the losses that are most likely for your business.  Just look at the First National Bank of Blacksburg, where the bank bought cyber insurance but it had a carve-out for exactly the kind of loss it had previously experienced.  The magnitude of the pay-outs are so unexpectedly large that some insurance companies are also finding creative excuses for why they shouldn’t pay a claim.

When the policy covers the risks/events, cyber insurance can be invaluable.  Some policy types give immediate access to expensive specialists who can help ensure the organization is in compliance with its legal, regulatory, and most importantly ethical/moral obligations, including providing assistance communicating with the press and customers.

It should be noted that many carriers, including some major insurers, are exiting the cyber insurance market because they do not yet have a good way of characterizing the maturity of the customers’ cybersecurity and data privacy programs or the potential damages.  The Department of Defense’s forthcoming Cybersecurity Maturity Model Certification may help with that.


A ransomware attack can have serious consequences for an organization. However, though careful planning and testing, the organization can survive, or at least recover from, a ransomware attack without having to pay the ransom. A Defensible Cybersecurity program includes ransomware planning and much more. Contact Fathom Cyber to learn more about how we can help your organization build a Defensible Cybersecurity program.

Vulnerabilities, Exploits, Patches, Threats, and Risks

Many in the cybersecurity industry use terms including vulnerabilities, threats, and risks as though they are synonymous, but they are not. Understanding the differences, and using the terms correctly and consistently, is an important part of creating a more systematized and defensible cybersecurity strategy.


A vulnerability is a weakness or flaw in a computing device. Vulnerabilities can arise from flaws in the way the hardware is designed, such as those dubbed Spectre and Meltdown; from flaws in the software, such as those creating SQL injection vulnerabilities; or from simply being connected, such as Denial of Service vulnerabilities.


An exploit is a tool or technique used by an attacker that takes advantage of a vulnerability to achieve a goal. Such goals can include causing commands to be executed by the victim’s computer, retrieving data from a database without authorization, and causing a device to stop providing service to others.


A patch is a software-based update that fixes a vulnerability. A properly patched vulnerability cannot be exploited.


A threat is a vulnerability that can be exploited. It is important to note that the mere existence of an exploit is not enough for a vulnerability to become a threat. The threat actor (i.e., criminal or hacker) must have the ability to use the exploit on the vulnerability before the combination can become a threat.


Risk is usually expressed as the product of the likelihood that a vulnerability will be exploited and the severity or impact of the vulnerability. Risks can be expressed in a variety of ways, including simple ordinals (e.g., low, medium, and high) or as a quantity (e.g., using techniques described by the FAIR Institute).

Cyber Criminals Targeting College-age Students

According to published reports, a threat actor dubbed “Silent Librarian” has been targeting individual college-age students (i.e., “spear phishing” the students). Silent Librarian is using information from the students’ social media posts to learn more about their buying habits, where they go to school, places they have visited, books they have read, etc. They then carefully craft E-mail messages with subjects and contents that are relevant to the student (e.g., “Overdue Library Books”). The E-mails include graphics and other information that mimic those used by the students’ school. The E-mails contain links to convincing but phony websites that capture the students’ credentials. The students’ information is saved and then they are automatically logged into the school’s website, helping to hide the fact that the login page did not belong to the school. The students’ accounts are then used for a variety of purposes, including accessing academic journals that are only available through a paywall, stealing intellectual property including research, mining the E-mail and other messages for information that can be used later for influence campaigns, and as a basis for sending infected E-mails to classmates and friends.

The three best things students can do: 1) remain aware and vigilant, including carefully scrutinizing every web URL to ensure it belongs to their school, 2) use unique passwords on every website and a password manager to maintain the information, and 3) insist that their school implement multi factor authentication and make sure it is enabled on their account. For more information about staying safe online, download our Top 7 Tips.

Top 7 Tips for Reducing Individual Cybersecurity Risks

Keeping cyber criminals at bay isn’t as hard as it may seem. Although no security system is perfect, following these 7 basic tips can significantly reduce your risk of becoming a victim.

  1. Stop and Think Before You Click a Link – Before you click on a link or open an attachment in an online message (i.e., an E-mail, text message, instant message, etc.), ask yourself if you were expecting the message, even if it was from someone you know and trust.  If you weren’t expecting the message, contact the sender via another means (e.g., call or text them) to see if they truly sent the message.  A few extra seconds of effort can save you a lot of headaches later.  For more information about common online messaging-based attacks, visit Stay Safe Online ( Think you have the skills to spot a fake online message?  Try Google’s phishing quiz at
  2. Avoid Less Reputable Websites – Although some websites pay attention to cybersecurity and attempt to keep their sites safe, many sites do not.  Their primary focus is to drive viewers to the site to increase advertising revenue or sales, and the maintenance and security of the site often take a back seat.  Regardless of whether the link is in an online message, search engine result, or other source, before you click on the link you should ask yourself whether the site is likely to be secure, and if you are unsure, don’t visit the site.  Advertising-laden sites are also more prone to unintentionally posting advertisements that can push malware down to your device and should therefore be avoided where possible.
  3. Back up your data – Ransomware is one of the biggest threats facing organizations and individuals today.  Ransomware will encrypt your locally stored data and online storage, such as Carbonite, OneDrive or Drobox.  Some online storage companies keep multiple older versions of your data, helping to improve your chances of recovering unencrypted versions of your files.  However, we recommend that you back up your data to offline sources such as external hard drives that you keep unplugged from your computer except when backing up your data to them.  This allows you to successfully recover your data in the event the online backup provider is the victim of a ransomware attack or otherwise goes offline.
  4. Use Antivirus and Firewall Software – Old antivirus software used to bog down computers, but today’s antivirus software is both highly efficient and effective.  If you don’t want to pay for antivirus software, Microsoft Windows even comes with its own antivirus software called Windows Defender that consistently receives high ratings in independent reviews.  Similarly, Windows Firewall does a good job of helping to keep attackers at bay.  If you need help enabling Windows Firewall or Windows Defender, visit  Several well-known companies, including McAfee, Norton, BitDefender, and AVG also make antivirus software for Android devices, and if you own an Android device you should consider installing one of those.  We also recommend downloading and running an alternative antivirus program, such as Malwarebytes, as a safety precaution every few months.
  5. Enable Automatic Software Updates – Most operating systems, such as iOS, Android, and Windows, and most commercial software, such as Microsoft Office, Adobe Acrobat, Google Chrome, and Mozilla Firefox are regularly updated by their manufacturers.  Almost every update contains fixes for security vulnerabilities that were found in the operating system or software.  Most of these tools can automatically install the latest updates from the manufacturer, and it is a good idea to enable automatic updates.
  6. Use Multifactor Authentication Where Possible – Usernames and passwords are not enough to keep attackers at bay.  A third form of authentication, called multifactor authentication, is a necessity and should be used whenever available.  Multifactor authentication can take different forms, including text messages or synchronized pseudo-random numbers that change frequently.  Although some forms of multifactor authentication are stronger than others, any multifactor authentication is better than none.
  7. Use a Password Manager – Password mangers such as 1Password, Dashlane, and LastPass store your passwords in an encrypted form that only you can access and can automatically log you into your favorite websites.  The stored passwords can be synchronized across your mobile and desktop/laptop devices.  Password managers are safer than storing passwords in your browser, and they allow you to use unique passwords on every website.

For more practical cybersecurity news and tips, subscribe to our newsletter. Click Here to download a PDF version of this document, along with our impactful article on the role individuals play in cybersecurity.

The Key to Good Cybersecurity: You

Transformer Fire

Did you know that your organization and you can be a cyber criminal’s target even if you do not have much valuable information?  Imagine that it is the morning of February 3rd, 2020.  Frigid temperatures extend as far south as Texas and are expected to stay in place for at least the next 6-8 days.  As you are getting ready for work you hear the local fire company’s siren begin to wail.  A few seconds later your whole house goes dark.  You pull out your phone to turn on the flashlight app and it starts wildly chirping and buzzing.  There is an alert from the Federal Emergency Management Agency (“FEMA”) advising everyone of a nearly nation-wide blackout and recommending that everyone stay off the streets and at home while emergency crews work to assess and address the situation. 

Your Wi-Fi is out, so try connecting your laptop to the Internet via your phone but the phone has trouble keeping you online.  So, you E-mail your office that you will try again in a bit when the power comes back on, then change into warmer clothes and settle in on your couch armed with a heavy blanket, a book, and the old AM/FM radio that you found buried at the back of your closet.

By noon the news begins reporting that the blackout was the result of a coordinated attack.  The attackers created malicious software (malware) that overwhelmed the protective switches, called relays, which are used by power companies to keep their electrical distribution equipment from being damaged.  The malware kept the relays from working properly, causing transformers and other equipment to overheat and, in some cases, to catch fire.  Officials are still assessing the damage, but they are warning that although there is some inventory of spare parts and equipment, much of the equipment will need to be newly manufactured which could take months.

As the day progresses you accept the fact that the power will be out a while and that the fire-and-blanket approach is not a long-term strategy.  You are about to hop in the car to buy a generator when your phone rings.  It is the CEO of your company.  The FBI called her moments ago and told her that they traced the problem back to an individual E-mail account at your company: your account.  Foreign agents gained access to your E-mail account and used it to send infected E-mails to select customers of your company.  These infected E-mails allowed the foreign agents to gain control of other systems, and to eventually work their way up to a company that has access to the electrical grid.  From there, they were able to infect the grid and cause the nation-wide blackout.  The FBI assured the CEO that they will not publicly name your company, but cautioned that given the scope of the damage and the number of agencies involved it may not be long before the company’s name, your name, and your collective role in the blackout are leaked.  You hang up and collapse onto your couch, your head spinning at the thought that your world has forever changed.

Could This Really Happen?

While this scenario may sound far-fetched, cyber criminals target victims for a variety of reasons, and most aspects of this scenario have already occurred.  For example, according to the Wall Street Journal, agents of the Russian government gained access to an excavating company’s E-mail systems in 20181.  They exploited the excavating company’s trusted relationship with its customers and moved up to larger, more sophisticated companies, eventually gaining access to the US electrical grid.  “They got to the point where they could have thrown switches” and disrupted power flows, said Jonathan Homer, chief of industrial-control-system analysis for DHS2.  “Some companies were unaware they had been compromised until government investigators came calling, and others didn’t know they had been targeted until contacted by the Journal.”  Thankfully, investigators from the FBI and DHS were able to stop the foreign agents before damage could be done to the US electrical grid.  Otherwise, the US may have suffered the same fate as Ukraine in 2018, when an attack on its electrical grid caused massive equipment failures and lengthy power outages3.

To help keep this from happening to you, follow our Top 7 Tips for Reducing Individual Cybersecurity Risks. Click Here to download a PDF version of this document, along with our Top 7 Tips for Reducing Individual Cybersecurity Risks.

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CMMC Version 0.4 Released 4-SEP-2019

The United States Department of Defense published Version 0.4 of the CMMC on September 4, 2019. The publication includes some new insights into the DoD’s plans for the CMMC, including:

    Reinforcement of the January 2020 target date for the release of CMMC 1.0 and the June 2020 target date for incorporation of the CMMC in all RFIs;
    A softening of the target date for incorporation of the CMMC as a mandatory requirement for all acquisitions to “Fall 2020” (this had previously been September 2020);
    A commitment for a second daft of the CMMC which is due in November 2019;
    They are actively pushing to streamline the CMMC and are seeking public comments on how the requirements should be reprioritized and/or reassigned, as well as whether certain requirements should be removed or added;
    The DoD is aware that small and medium businesses may be more severely impacted than large government contractors and is trying to factor SMB concerns into the CMMC;
    The DoD is stressing process maturity, not merely the implementation of certain pieces of technology (which they refer to as “practices”) and asserts that such maturity can help make up for shortcomings in technical control implementations.

  • As illustrated in Figure 1, below, the CMMC defines eighteen (18) different cybersecurity-related domains, from Access Control to Systems and Information Integrity. Every domain is comprised of capabilities, and each capability is comprised of both practices and processes.
  • Figure 1

  • The CMMC defines two sets of maturity metrics: one for technical practices (i.e., whether certain controls have been implemented), and one for processes (i.e., how well the organization has documented not only its plans for implementing the controls, but also monitoring how well it is performing/implementing the controls). The practice maturity levels are:
    Basic Cyber Hygiene;
    Intermediate cyber Hygiene;
    Good Cyber Hygiene;
    Proactive; and,
  • The process maturity levels are:
    Reviewed; and,
  • Each organization’s maturity will be assessed against all eighteen domains, and the assessment will look at at both the practices and processes. Organizations, especially small and medium organizations, frequently do not prioritize documentation of processes, therefore it can take months, and even years, for organizations to obtain process maturity level 2 or beyond. We strongly encourage organizations to start documenting their processes now, before CMMC 1.0 is released. We recognize that this process can be intimidating for even sophisticated organizations. Contact Fathom Cyber today to learn more about how we can help your organization prepare for CMMC 1.0.

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Department of Defense CMMC Update

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We attended a presentation in early August by Katie Arrington, who is spearheading the Department of Defense’s (“DoD”) efforts to increase the role cybersecurity plays in acquisitions. At that time, Ms. Arrington mentioned that Version 0.4 of the DoD’s Cybersecurity Maturity Model Certification (“CMMC”) would be released on August 30, just before the long Labor Day weekend. The DoD’s Office of the Under Secretary of Defense for Acquisition & Sustainment announced late last week that “Due to the impending holiday [the office] will release the Draft CMMC 0.4 once it clears review by DoD Public Affairs”. This is disappointing for the hundreds of thousands of Defense Industrial Base (“DIB”) contractors who are waiting for additional clarity from the DoD before kick-starting their maturity assessment and improvement processes. DoD is currently targeting a January, 2020 release date for CMMC Version 1.0, with June and September roll-outs for mandatory inclusion of the CMMC in all RFIs and acquisitions, respectively. We recommend that all contractors perform a pre-assessment now so that they have as much lead time as possible to make any necessary changes or improvements.

Outsourcing Comes with Risks

Many companies are considering “moving to the cloud” and other forms of outsourcing because the costs are lower and they assume the outsourcing provider is going to properly handle all of the associated issues, including security. Some outsourcing providers take security seriously and for small and medium businesses who do not have the resources to handle security well themselves, outsourcing to those providers can help significantly reduce their overall risk.

But outsourcing also brings with it its own risks, and many small and medium businesses are rushing to adopt the cloud and other outsourcing without really understanding the risks. Just ask the 400 dental offices around the country who relied on The Digital Dental Record (TDDR), a provider of practice management and patient information storage solutions for dental offices. TDDR was the victim of a ransomware attack last week, and although there are reports that the company has access to a third-party decryption program, the restoration process has been very slow. In fact, only about 1/4 of the impacted dental practices have come back online over the course of the week. In the meantime, the impacted practices have had to cancel appointments and turn away patients because they do not have access to the patients’ records and other information. Some of the impacted practices may not survive if they are unable to treat patients soon.

According to TDDR’s public statements on the issue, it will likely take several more days, and possibly weeks, before their data recovery efforts will be complete. In some cases, the third-party decryption tools are not entirely successful, which means that some of the practices may permanently lose some or all of their patient data.

In addition, since some criminals masquerade their data exfiltration efforts as ransomware attacks, TDDR is not yet certain whether a HIPAA violation or other data breach has occurred. Many states have strict notification and response laws, especially when healthcare information is stolen or otherwise released without authorization. TDDR and its dental practice customers will need to carefully monitor the situation to ensure they meet both their state and federal obligations.

The data restoration and potential data breach response costs will be significant for TDDR. Depending on its contracts with its clients, TDDR may also be responsible for their lost revenue, any additional data breach response costs, potential penalties, and other costs. Many outsourcing contracts limit the contractor’s liability to a multiple of the fees paid, and it will be interesting to see if TDDR’s customers will come close to being made whole. Of course that also assumes that TDDR will continue to be in business long enough to pay any such claims, and that TDDR’s insurance will cover any shortfall given the number of customers and patients whose data is involved.

Outsourcing can be a lifesaver for small and medium businesses, giving them access to tools and resources that would otherwise be unreachable. However, it is important to carefully define and assess the risks that go along with outsourcing before an accurate cost/benefit analysis can be performed.

A proper risk analysis is a core part of a defensible IT and cybersecurity strategy because it allows the organization’s executives to agree how the risks should be addressed, i.e., through acceptance, avoidance, transfer/insurance, mitigation, or even enhancement. For those risks where risk transfer through insurance makes sense, a risk analysis allows the organization to ensure the insurance properly covers the risks. For those risks where mitigation is the chosen option, the risk analysis allows the organization to create well-structured mitigation policies and procedures, as well as corresponding incident response plans.

Organizations of all sizes benefit from a risk-based, defensible cybersecurity program. Unfortunately for TDDR’s customers, it may be too late. Has your organization conducted a thorough cybersecurity risk assessment and, if so, are you confident in the resulting policies, procedures, and plans? Are you confident that your insurance properly covers your risks? Have you tested your incident response plans?

At Fathom Cyber, our Defensible Cybersecurity Strategists know that cybersecurity and data privacy are more than just an IT issues: they are vital to our customers’ survival. That is why we don’t offer cookie-cutter approaches to cybersecurity and data privacy. Instead, we help organizations analyze their risks so they can make business-intelligent cybersecurity and data privacy decisions.

Contact Fathom Cyber to learn more about how we can help your organzation create a Defensible Cybersecurity Strategy.