[HN Gopher] SEC charges four companies with misleading cyber dis...
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       SEC charges four companies with misleading cyber disclosures
        
       Author : impish9208
       Score  : 67 points
       Date   : 2024-10-22 16:56 UTC (6 hours ago)
        
 (HTM) web link (www.sec.gov)
 (TXT) w3m dump (www.sec.gov)
        
       | hn_throwaway_99 wrote:
       | It's amusing to me how the economic and cultural incentives at so
       | many companies is to lie as much as possible when it comes to
       | breach disclosures while pretending that you're still technically
       | telling the truth.
       | 
       | I think that in _all_ of these cases it would have been no worse
       | for the companies in question if they just sent out a dry,  "just
       | the facts, ma'am" report of what actually happened, without any
       | of the BS "the security of our customer data is our primary
       | priority!" statements to begin with that always accompany these
       | kinds of breach disclosures. E.g. something like:
       | 
       | On <date>, due to a vulnerability in the third party vendor
       | SolarWinds which provides network security services for us, we
       | detected the following breaches of customer data:
       | 
       | 1. xxx
       | 
       | 2. yyy
       | 
       | The steps we are currently taking, and what you should do: zzz.
       | 
       | ----
       | 
       | Perhaps one good thing that can come out of this is that some
       | sort of "standard" format for breach disclosures comes about
       | (think the "Nutrition Facts" labels on food boxes in the US). All
       | I do when I see companies trying to minimize breach disclosures
       | is assume they're bullshitting anyway.
        
         | kmeisthax wrote:
         | If companies were mere profit-seeking entities, these breach
         | notices would be minimally disruptive to the business. Most
         | people do not immediately jump ship just because a breach
         | happened.
         | 
         | But most companies are not just that. They're barely-legal
         | Ponzi schemes. The board and their appointed CxOs are selected
         | specifically on the basis of how much they can get the stock
         | price up. This results in companies making lots of terribly
         | short-sighted decisions.
         | 
         | In the specific case of breach disclosures, _any_ bad news
         | about a company tends to create uncertainty, which makes short-
         | term investors and speculators close their positions, which
         | drops the price. This drop tends to be short-term, but it
         | imperils the liquidity of the investment, and liquid
         | investments tend to be more valuable, so...
        
           | TeMPOraL wrote:
           | Thanks, that does explain the long-standing conundrum I had.
           | Having worked for a cybersec/GRC startup in the past[0], I
           | got a good look at how risks and their impacts are
           | categorized, but I still couldn't figure out, _why does
           | anyone care_.
           | 
           | Like, "reputational damage", obviously nobody cares if a
           | company gets breached - 99% of the customers won't notice,
           | 99% of the remaining won't understand it, and the competitors
           | are probably just as much at risk; all you need to do is
           | issue some PR note and maybe offer free credit monitoring
           | (some US peculiarity), and you're done. Same for most other
           | things leading to "reputational damage". It feels like it's
           | obviously a loss of $nothing, so why do CFOs and CISOs seem
           | to put so much interest in this impact category?
           | 
           | Well, I haven't thought about stock prices, and their lack of
           | correlation with customer experience. My bad.
           | 
           | --
           | 
           | [0] - I suppose I had all the things I needed to figure it
           | out, somehow I didn't connect the dots. And/or was too busy
           | trying to ensure our fancy probability math wasn't bullshit
           | to pay attention to the larger context.
        
         | JumpCrisscross wrote:
         | > _in all of these cases it would have been no worse for the
         | companies in question if they just sent out a dry, "just the
         | facts, ma'am" report of what actually happened_
         | 
         | This assumes there is someone on staff capable of writing a no-
         | nonsense diagnosis.
        
           | TeMPOraL wrote:
           | Sure there are. The person writing the release gets fed some
           | internal bullet points or summaries as source material; that
           | material is strictly less bullshit than the resulting
           | official press release.
        
         | SpicyLemonZest wrote:
         | I'm sympathetic, but I feel like the order against Mimecast
         | illustrates a big part of the problem here. This seems to me
         | like a pretty detailed disclosure:
         | 
         | > The investigation revealed that the threat actor accessed and
         | downloaded a limited number of our source code repositories, as
         | the threat actor is reported to have done with other victims of
         | the SolarWinds Orion supply chain attack. We believe that the
         | source code downloaded by the threat actor was incomplete and
         | would be insufficient to build and run any aspect of the
         | Mimecast service. We found no evidence that the threat actor
         | made any modifications to our source code nor do we believe
         | that there was any impact on our products. We will continue to
         | analyze and monitor our source code to protect against
         | potential misuse.
         | 
         | But the SEC feels this was misleading, because they did not
         | specify which source code repositories were targeted or what
         | percentage of the code in those repositories was exfiltrated.
         | That's the dynamic that drives these kind of disclosures,
         | oversharing driving demands for even more absurd levels of
         | oversharing. They had to go calculate that precisely 76% of
         | their M365 interop code was exfiltrated - is that information
         | worth the cost of producing it, or even valuable to anyone in
         | any way?
        
           | Veserv wrote:
           | You do not need to say precisely 76%. Nobody is going to
           | complain if you spend less resources to get a less strict
           | upper bound like 80%. Hell, you can make it easy for yourself
           | and just say 100%; costs nothing and guaranteed to not
           | understate the customer impact. The problem is deceptively
           | implying less customer impact.
           | 
           | But no company will deliberately overstate the customer
           | impact, think of what it would do to their bottom lines. They
           | much prefer spending a bunch of money to minimize
           | overstating. Exactly.
           | 
           | If only they were allowed to understate customer impact then
           | they could harvest even more of that reputational arbitrage
           | is not a very compelling justification.
        
           | notatoad wrote:
           | >is that information worth the cost of producing it, or even
           | valuable to anyone in any way?
           | 
           | It's valuable to the SEC, because they're the ones tasked
           | with enforcing these rules and specifics are what allow for
           | enforcement. If you publish an actual percentage, then they
           | can ding you for lying if the percentage was wrong. being
           | vague isn't misleading on its own, but it can be used to be
           | misleading.
           | 
           | if they actually know what was exfiltrated, then putting
           | specifics in the disclosure should be a trivial matter. maybe
           | not a percentage of lines in the codebase, but you've got to
           | give the SEC enough that they could potentially check it and
           | determine if it was a lie. and "a limited number" isn't
           | specific enough to do that.
        
       | MattSteelblade wrote:
       | > Unisys will pay a $4 million civil penalty;
       | 
       | > Avaya. will pay a $1 million civil penalty;
       | 
       | > Check Point will pay a $995,000 civil penalty; and
       | 
       | > Mimecast will pay a $990,000 civil penalty.
       | 
       | With the exception of Mimecast, these are companies that are
       | bringing in billions of dollars in revenue annually. How is this
       | supposed to deter them?
        
         | 0xffff2 wrote:
         | They pay the penalty and they are expected fix the issue. If
         | they don't, there will be additional enforcement actions.
        
           | Mistletoe wrote:
           | Doing anything at all probably costs more than $1M.
        
             | alephnerd wrote:
             | Not that much more.
             | 
             | Furthermore, security vendors like Avaya and Unisys could
             | arguably be in breach of contract with customers because it
             | could be argued that they misrepresented their internal
             | security protocols to customers.
        
         | ensignavenger wrote:
         | Unisys and Avaya are both reporting losses. This fine makes it
         | even more of a loss. Further, if they don't mend their ways,
         | the SEC will give them an even bigger fine.
        
         | alephnerd wrote:
         | > How is this supposed to deter them
         | 
         | Unisys and Avaya are both security vendors. This absolutely is
         | a bad look for them, as almost every Security RFP asks about
         | internal controls and how a vendor has remediated against these
         | issues, and this is ammunition for any competitor to ask a
         | prospect to re-evaluate purchases from either due to
         | misrepresenting their security procedures.
         | 
         | Furthermore, Unisys only has an operating profit of around
         | $200M a year, so a $4M fine is fairly brutal (that's an entire
         | security team's operating budget for a company at Unisys'
         | size).
         | 
         | Avaya's is smaller still, so that $1M is fairly brutal for them
        
         | teeray wrote:
         | The law should be written to require a mandatory percentage of
         | revenue. That will wake them up.
        
           | kmeisthax wrote:
           | It will not.
           | 
           | The reason why companies get breached is because the systems
           | being breached are all legacy. Company A buys company B who
           | bought company C, which merged with company D. C fires D's
           | old IT department, because it's redundant, so now D's billing
           | system is being managed by C's IT department. C then sells
           | itself to B, who has a much more robust billing system. At
           | this point, it'd make sense to replace the billing system
           | from D, but everyone who knew how it worked got fired in the
           | C/D merger. So it sits around because nobody wants to break
           | that part of the business. Then A buys B and does another
           | round of layoffs, so anyone who even knew about this is gone.
           | 
           | Ten years and hundreds of iterations of this exact cycle
           | later, you get an e-mail from a stranger saying they found
           | all your customer records being sold on a cybercrime forum.
           | Your IT department scrambles to remediate a breach in a
           | system they've never heard of that nobody remembers
           | installing or maintaining. It's just always been _there_.
           | Corporate amnesia runs deep. People are finding forgotten old
           | servers running unpatched versions of Windows Server 2003
           | that were so ritualistically overlooked you 'd need to be
           | high on Class Z mnestics just to perceive them.
           | 
           |  _Every_ enterprise IT department is like this. That 's why
           | companies get breached so damned often. There is never enough
           | time in the budget to properly document legacy systems, nor
           | are the decision-makers at the top even aware of the fact
           | that they exist. Their job is to eat things, and they eat
           | voraciously. If you want to stop this from happening, you
           | need to make M&A illegal, not just inflict more pain to the
           | invisible arms the corporate body cannot perceive pain from.
        
             | philipov wrote:
             | Well, you've convinced me. M&A should be illegal.
        
             | akira2501 wrote:
             | > Every enterprise IT department is like this.
             | 
             | That's because it's not understood what a liability
             | allowing this to occur is. Perhaps if we fine them based on
             | revenue they would understand that IT is a core part of
             | their company and can no longer live on the edges of the
             | business units.
        
           | JumpCrisscross wrote:
           | > _law should be written to require a mandatory percentage of
           | revenue. That will wake them up._
           | 
           | Percent of revenue fines regressively to margin.
           | 
           | 10% of Walmart's revenue is 4 years' profits. 10% of
           | Equifax's is a few quarters'. Moreover, you'd have a
           | bureaucrats' delight of companies splitting revenues across
           | entities while courts have to litigate common control claims.
           | Unless you have a good reason to punish low-margin businesses
           | more heavily than high-margin ones, this is an inefficient
           | scheme.
           | 
           | Better: fines based on damages, trebled.
        
             | TeMPOraL wrote:
             | > _Better: fines based on damages, trebled._
             | 
             | Except damages for data leaks are kind of hard to compute,
             | since in practice they're $0 until some of the data is
             | provably used to cause some non-$0 worth of damage down the
             | line.
        
         | Hilift wrote:
         | The fines are symbolic. Even if you look at the fine for the
         | hotel data breach in 2018, that was only $52 million (US) and
         | $23 million (UK), total of $75 million. And the Equifax breach?
         | An executive VP of IT sold $584k of shares right after the
         | breach and before the press release. Nothing happened to him,
         | he said he was unaware of the breach.
         | https://www.npr.org/sections/thetwo-way/2017/09/08/549434187...
         | 
         | The SW supply chain attack is one of the most brilliant cyber
         | attacks in recent history. They hit a train load of gold bars,
         | and had a much as 14 months of dwell time with potentially
         | 18,000 customers. Discovery must have been disappointing for
         | the attackers.
         | 
         | If you follow the most important rule, secrecy, you get
         | plausible deniability and small-er fines.
        
         | SpicyLemonZest wrote:
         | It's not a case of deterrence. As the orders linked from the
         | press release describe, all four of these companies have been
         | cooperating extensively with the SEC to fix things up and
         | agreed to continue doing so as part of the settlement.
        
         | advisedwang wrote:
         | SEC likely offered low settlements here to get agreements
         | without having to battle in court whether SEC even has the
         | authority to do this. Now that they have to some degree
         | established authority here* they can go for enforcement harder
         | and push companies further on disclosure.
         | 
         | * ie a practical precedent, not a legal one
        
       | librasteve wrote:
       | I feel that it is time to criminalise corporate fraud - ie
       | executives presiding over businesses or state organizations that
       | lie, deliberately obscure or suppress any relevant facts should
       | expect jail time. This ought to be at similar levels of time and
       | standards of "should know" as health and safety law.
       | 
       | Several recent examples would have fallen foul of this ...
       | Grenfell tower, Tesla FSD, Boeing 737max, Thames Water, United
       | Utilities and the EA.
        
         | Etheryte wrote:
         | I agree, we already see this in the financial industry, if you
         | don't do your part to prevent money laundering, you can be
         | facing real jail time. It's long overdue that similar liability
         | came to other industries, the examples you brought up show it's
         | clearly necessary. The free market and its financial incentives
         | alone are not cutting it.
        
       | mise_en_place wrote:
       | Probably not the case here, but the issue is with how some of the
       | NIST standards around cybersecurity are certified. API endpoints
       | are manually tested and then screenshots are provided. Completely
       | manual and very inefficient and prone to human error. This is an
       | issue of US national security, we need more skilled hackers in
       | this space.
        
       | hbcondo714 wrote:
       | FWIW, other publicly traded companies disclosed[1] their breaches
       | since the rule went live a year ago.
       | 
       | [1] https://last10k.com/stock-screeners/cybersecurity
        
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