[HN Gopher] Ransomware Group Files SEC Complaint over Victim's F...
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       Ransomware Group Files SEC Complaint over Victim's Failure Disclose
       Data Breach
        
       Author : LinuxBender
       Score  : 120 points
       Date   : 2023-11-16 16:16 UTC (6 hours ago)
        
 (HTM) web link (www.securityweek.com)
 (TXT) w3m dump (www.securityweek.com)
        
       | jerf wrote:
       | What a magnificent snarl of incentives for the SEC. The SEC wants
       | disclosure for good reasons, but if you disclose because the
       | hacker group is the one that reported it, that is essentially the
       | "negotiating with terrorists" incentive structure. Ignore the
       | report because it's the hacking group and it opens the defense
       | for all companies to claim the report is made by the hacking
       | group (because they can easily be deceptive about who is
       | reporting). And so on and so on... what a mess.
        
         | AlotOfReading wrote:
         | "Pay up or we'll report you to the government" is a textbook
         | example of blackmail. The gordian knot is easy to cut here
         | though. The SEC can to refer illegal activities to the DOJ for
         | prosecution separately from however they deal with the
         | reporting issues.
        
           | jerf wrote:
           | Well, the SEC can refer all they want, but the DOJ is going
           | to have jurisdiction over approximately 0% of the referrals.
        
             | RandomLensman wrote:
             | Want to refer it to the DOD instead?
        
               | brewdad wrote:
               | Interior? Education? We can keep referring until we hit
               | the right department.
        
               | nvy wrote:
               | The joke is that DOD is the long arm of US foreign
               | policy. Can't prosecute? Invade.
        
               | jerf wrote:
               | Definitely closer to what I mean. Intelligence agencies
               | is probably closer to the reality though.
               | 
               | To those mystified by my crypticness, yes, my point is
               | that the criminals are going to not be in the US and be
               | where the US can't simply prosecute them, and this is not
               | just a coincidence. They are in those places for that
               | very reason. They may even be _actively supported by
               | their local government_ , so don't count on extradition
               | or anything else like that. Even nominally friendly
               | governments that we have treaties with are perfectly
               | capable of 100% coincidentally simply not being able to
               | find those guys, so sorry, we feel really bad for you
               | though, if they want to. Paper is only worth the actions
               | it produces.
        
               | bluGill wrote:
               | That depends. Most countries you refer to the department
               | of state who in turn talks to law enforcement in the
               | country where the hackers are from and that country takes
               | care of the problem.
               | 
               | However most hackers seem to be from countries like
               | Russia, or North Korea where law enforcement will tell
               | the state department to go away. DoD probably is the only
               | option we have (though intelligence/CIA should get
               | involved) - is it worth war?
        
             | JumpCrisscross wrote:
             | > _the DOJ is going to have jurisdiction over approximately
             | 0% of the referrals_
             | 
             | Why? A U.S.-listed company was hacked.
        
               | hiatus wrote:
               | I think they are referring to jurisdiction to enforce any
               | judgement against the actor, which is likely in a foreign
               | state with no extradition agreement with the US.
        
               | JumpCrisscross wrote:
               | > _jurisdiction to enforce any judgement against the
               | actor, which is likely in a foreign state with no
               | extradition agreement with the US_
               | 
               | Justice has a long memory. A common theme, when new
               | extradition agreements are struck, usually in the context
               | of trade or security arrangements, is how to deal with
               | the backlog of overdue enforcement.
        
               | hiatus wrote:
               | I agree in general, but I won't hold my breath for any
               | agreement to be made between the US and Russia, Iran,
               | North Korea, or China in my lifetime.
        
           | anonymousDan wrote:
           | Yes, I don't see the issue. If I understand correctly then
           | reporting doesn't necessarily mean you are going to be in
           | trouble (so long as you report in time)?
        
             | koolba wrote:
             | Plus you can use any SEC whistleblower money for your legal
             | defense against the hacking.
        
           | autoexec wrote:
           | > "Pay up or we'll report you to the government" is a
           | textbook example of blackmail.
           | 
           | It's hard to feel too bad about companies who are actually
           | doing illegal things that the government should be notified
           | about anyway. It's like someone reporting their drug dealer
           | to the police because they discovered their dealer was lacing
           | their drugs with fentanyl. Sure, they're a snitch, but people
           | are safer knowing the truth.
        
             | FireBeyond wrote:
             | Exactly. The desired outcomes may be different, but the
             | incentives are temporarily, perversely aligned.
        
             | marcosdumay wrote:
             | Hum, no, your example is not blackmail. It would be like
             | the customer asking for free drugs or else he would report
             | the dealer.
             | 
             | Anyway, the obvious course of action is to persecute the
             | company and arrest the hacker. The problem here is probably
             | that arresting the hacker is difficult.
        
         | sonicanatidae wrote:
         | Oh I think they'll managed to figure out a way to keep
         | corporations safe, at the expense of the citizens. That's the
         | historical precedent.
        
           | JumpCrisscross wrote:
           | > _at the expense of the citizens_
           | 
           | The SEC doesn't work for "the citizens," its mandate is in
           | respect of investors. Especially small investors. U.S. law,
           | broadly, prioritizes first consumers, then investors, and
           | way, way, way below that, workers.
        
         | RationalDino wrote:
         | I don't see any snarl.
         | 
         | The law requires disclosure so that companies can't hide
         | material information from investors. The SEC wants all
         | incentives lined up so that companies will choose to report.
         | The primary way that the SEC catches them now is that the data
         | showed up somewhere like a data breach. So ultimately, the
         | behavior of the hacker group is the source.
         | 
         | This hacker group just cut out several steps in the middle. The
         | SEC verifies it, the company gets punished, and companies are
         | on notice that they really should report. Just like the law
         | says.
         | 
         | What WOULD be a problem is if the hacker group got rewarded for
         | reporting...
        
           | nickff wrote:
           | If the SEC pursues prosecutions based on reports from hackers
           | which uses the threat of SEC reports to extract payments, the
           | SEC will be enabling and enforcing blackmail. The SEC would
           | essentially be an accessory to the crime.
        
             | elefanten wrote:
             | That's not how the law would see it. Blackmailers
             | incorporating otherwise-legal third party activity into
             | their threat does not add legal liability for that 3rd
             | party. Nor does it excuse any pre-existing liability for
             | the blackmail target.
        
               | nickff wrote:
               | I'm not sure whether there'd be legal liability; that
               | would probably depend on whether the third-party was
               | aware of the scheme, and how often they 'enabled' it. I
               | doubt that the SEC would be found to be an accessory the
               | first time this happened (unless they'd been specifically
               | warned), but if this happened frequently, I think they'd
               | likely be found guilty by way of 'reckless or wanton
               | negligence'. They might even be subjects of civil actions
               | by victims of these blackmail schemes at a later date (if
               | the circumstances were right).
        
           | fooker wrote:
           | >What WOULD be a problem is if the hacker group got rewarded
           | for reporting
           | 
           | Insider trading? But without being an actual insider.
        
       | dmoy wrote:
       | > It's worth pointing out that the new SEC data breach disclosure
       | rules will only go into effect in mid-December 2023. In addition,
       | companies will be required to notify the SEC within four business
       | days of determining that a cybersecurity incident is material to
       | investors, which, based on MeridianLink's statement, has yet to
       | happen.
       | 
       | And there's the rub. Not so much the December bit, but the
       | "material to investors" part. That has specific meaning, and
       | until there are external requirements/penalties/whatever around
       | security breaches, simple data theft may not rise to the level of
       | materiality for the company. Since they e.g. don't really get
       | hurt if their customers' private info is leaked.
       | 
       | "We'll pay for three years of identity protection services if you
       | sign up at XYZ link" is about all that happens today, if you're
       | lucky. Well, multiply the cost of that (in bulk rates) by the
       | number of customers who will actually bother signing up (pretty
       | low %), and you get a number which is, to no surprise, probably
       | not material for most companies.
       | 
       | (Ransomware, e.g. physically stopping the business from
       | functioning, probably does rise to the level of materiality, if
       | no quick backup and recovery can be done)
        
         | lainga wrote:
         | > Since they e.g. don't really get hurt if their customers'
         | private info is leaked
         | 
         | I don't know, that could depress future customer retention and
         | hurt the business. Seems like it would run afoul of the Matt
         | Levine Everything is Securities Fraud theory.
        
           | dmoy wrote:
           | > that could depress future customer retention and hurt the
           | business.
           | 
           | But it doesn't really though, does it? People largely dgaf.
           | 
           | My info has been leaked by my hospital, medical insurance
           | company, three major retailers, two social networks, etc etc.
           | None of them appear to be impacted much, if at all. For some
           | of them (insurance, the grocery store (!!?)), I don't have
           | realistic choices to stop using the service anyways.
        
           | brewdad wrote:
           | Unless the event is especially egregious that seems unlikely.
           | Firstly, most consumers won't even know the breach happened.
           | Secondly, you can quickly run out of places to go. Lets say I
           | leave Target because they get hit by a ransomware attack. A
           | year later Walmart gets hit. Do I go back to Target? Shop
           | exclusively online? Most likely, I continue to use whatever
           | company or service is cheapest and most convenient. All of my
           | PII is already on the Dark Web from a hundred other breaches
           | by now.
        
             | lainga wrote:
             | You're not thinking the Matt Levine way. None of that
             | matters. What matters is whether said (undisclosed) event
             | could be _construed_ to have materially harmed the
             | business, and thus form grounds for a shareholder suit.
             | 
             | The Theory is half tongue in cheek. But the other half is a
             | serious representation of what happens in reality. Levine
             | makes the case clearer than I do how the line of thinking
             | can extend to catch-22s where disclosure _and_
             | nondisclosure could both arguably be grounds for a suit.
        
           | gustavus wrote:
           | Ya because it hurt Experian so bad.... I'm still bitter about
           | that.
        
         | JohnFen wrote:
         | > Since they e.g. don't really get hurt if their customers'
         | private info is leaked.
         | 
         | They don't? They do at least a little. I know that I, at least,
         | avoid doing business with companies that have suffered such
         | leaks. Also, bigger picture, that such leaks happen makes me
         | think hard about doing business with _any_ company that stores
         | any data about me.
        
         | rossdavidh wrote:
         | Matt Levine (of Bloomberg) has an ongoing joke: "everything is
         | securities fraud". Essentially, if anything bad happens (data
         | breach discovered, CEO caught in sexual harassment complaint,
         | whatever), and you didn't say in your previous quarterly
         | filings that it was happening, then there is a case for suing
         | you in court and claiming that was material info you didn't
         | disclose. So far, the courts have not often been willing to say
         | "that isn't securities fraud". Not saying it's impossible in
         | this case, but I wouldn't count on it.
        
           | civilitty wrote:
           | Isn't that the same as mail and wire fraud?
           | 
           | Defraud someone for financial gain over the internet or by
           | using USPS mail and those umbrella charges apply.
        
             | philipov wrote:
             | It's different because in the case of mail and wire fraud,
             | everything begins as fraud. A CEO having an affair isn't
             | inherently fraud, but it becomes fraud when you don't admit
             | to it.
        
           | philipov wrote:
           | Someone just posted this
           | [https://news.ycombinator.com/item?id=38293817] by Matt
           | Levine: "Hackers Know Everything Is Securities Fraud"
           | 
           | I note that it was published less than 20 minutes ago, well
           | after the above comment was written.
        
             | rossdavidh wrote:
             | Yeah, I got it in my inbox after making that comment, and
             | thought "well that was a pointless comment", but I suppose
             | it does help that you linked to the Levine column. It is no
             | doubt a sign of the times (and not a good one) that the
             | funniest columnist is a guy who works at Bloomberg who
             | writes about "Money Stuff".
        
       | bastard_op wrote:
       | After having been part of various hacking cover-ups over the
       | years, usually in some sort of triage for these sorts of things,
       | I almost welcome the behavior vs. mega corporations or even
       | state/local government getting away with it. Shame the fools that
       | let it happen.
        
       | ceejayoz wrote:
       | The really funny follow-up will be applying for a whistleblower
       | award. https://www.sec.gov/whistleblower/claim-award
       | 
       | (They won't get it; there's an exemption "If you obtained the
       | information by a means or in a manner that is determined by a
       | United States court to violate applicable Federal or state
       | criminal law", but it'd be hilarious to try.)
        
         | Chris2048 wrote:
         | what if a third party disclosed the leak, and merely received a
         | tipoff from the hackers. Would a tip-off count as illegal?
        
           | jtokoph wrote:
           | So you could have two hackers who each tip each other off to
           | companies that they have independently hacked. They can just
           | claim each other's rewards since they had nothing to do with
           | the actual attack?
        
             | Chris2048 wrote:
             | I guess. The old "Hackers on a train" dilemma.
        
       | fbdab103 wrote:
       | I guess everyone is looking for new revenue streams in this
       | market.
        
       | tcbawo wrote:
       | I wonder how many ransomware/hacking groups are being
       | clandestinely paid by the sort of firms that would short the
       | stock and benefit from such a disclosure. Or maybe these groups
       | already plugged into the option markets and are profiting on both
       | ends.
        
         | raincom wrote:
         | Almost all middle-eastern governments hire ransomware/hacking
         | groups to take on firms/companies they don't like. [1]
         | 
         | [1]
         | https://www.thebureauinvestigates.com/stories/2023-01-15/hac...
        
       | miga wrote:
       | It is logical for the ransomware (or any lawbreaker) to minimize
       | lawbreaker in order to reduce risk and penalty.
       | 
       | It is also a legal act that may be considered to mitigate the
       | guilt in the eyes of the court. Much safer than actually
       | releasing the data.
       | 
       | Why did other ransomware gangs did not think of this first?
       | 
       | Is it because they are irrational or just lack proficiency in the
       | law?
        
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       (page generated 2023-11-16 23:01 UTC)