I A The President s National Infrastructure Advisory Council iiSecuring Cyber Assets Addressing Urgent Cyber Threats to Critical Infrastructure August 20 7 DRAFT Table of Contents Executive Summary Imperative Takeaways 3 Introduction 5 Our Task 5 Our Assessment 5 Recommendations and Supporting Findings 6 Moving Forward Fundamental Change 21 Appendix A Study Methodology 22 Appendix B Acknowledgements 24 Appendix C Urgency of Cyber Threats to Critical Sectors 27 Appendix D National Cyber Governance United Kingdom and Israeli Models 33 Appendix E References 36 About the NIAC The President’s National Infrastructure Advisory Council NIAC is composed of senior executives from industry and State and local government who own and operate the critical infrastructure essential to modern life The Council was established by executive order in October 2001 to advise the President on practical strategies for industry and government to reduce complex risks to the designated critical infrastructure sectors At the President’s request NIAC members conduct in-depth studies on physical and cyber risks to critical infrastructure and recommend solutions that reduce risks and improve security and resilience Members draw upon their deep experience engage national experts and conduct extensive research to discern the key insights that lead to practical Federal solutions to complex problems For more information on the NIAC and its work please visit https www dhs gov national-infrastructure-advisory-council NIAC Pre-Decisional NIAC Pre-Decisional 2 Executive Summary Imperative Takeaways Our review of hundreds of studies and interviews with 38 cyber and industry experts revealed an echo chamber loudly reverberating what needs to be done to secure critical U S infrastructure against aggressive and targeted cyber attacks Cyber is the sole arena where private companies are the front line of defense in a nation-state attack on U S infrastructure When a cyber attack can deliver the same damage or consequences as a kinetic attack it requires national leadership and close coordination of our collective resources capabilities and authorities Our Assessment The National Security Council NSC tasked the President’s National Infrastructure Advisory Council NIAC with examining how Federal authorities and capabilities can best be applied to support cybersecurity of high-risk assets We reviewed a comprehensive dataset of more than 140 Federal capabilities and authorities demonstrating impressive depth and complexity of Federal resources We believe the U S government and private sector collectively have the tremendous cyber capabilities and resources needed to defend critical private systems from aggressive cyber attacks—provided they are properly organized harnessed and focused Today we’re falling short Recommendations The challenges the NIAC identified are well-known and reflected in study after study There is a narrow and fleeting window of opportunity before a watershed 9 11-level cyber attack to organize effectively and take bold action We call on the Administration to use this moment of foresight to take bold decisive actions Establish SEPARATE SECURE COMMUNICATIONS NETWORKS specifically designated for the most critical cyber networks including “dark fiber” networks for critical control system traffic and reserved spectrum for backup communications during emergencies A C T I O N R E Q U I R E D B Y U S Department of Energy DOE U S Department of Homeland Security DHS Office of the Director of National Intelligence ODNI NSC and the Strategic Infrastructure Coordinating Council SICC Electricity Financial Services and Communications FACILITATE A PRIVATE-SECTOR-LED PILOT OF MACHINE-TO-MACHINE INFORMATION SHARING TECHNOLOGIES led by the Electricity and Financial Services Sectors to test public-private and company-to-company information sharing of cyber threats at network speed A C T I O N R E Q U I R E D B Y DOE DHS ODNI NSC and the SICC Identify best-in-class SCANNING TOOLS AND ASSESSMENT PRACTICES and work with owners and operators of the most critical networks to scan and sanitize their systems on a voluntary basis A C T I O N R E Q U I R E D B Y NSC DHS and Congress Strengthen the capabilities of TODAY’S CYBER WORKFORCE by sponsoring a public-private expert exchange program A C T I O N R E Q U I R E D B Y NSC DHS and Congress NIAC Pre-Decisional 3 Establish a set of LIMITED TIME OUTCOME-BASED MARKET INCENTIVES that encourage owners and operators to upgrade cyber infrastructure invest in state-of-the-art technologies and meet industry standards or best practices A C T I O N R E Q U I R E D B Y DOE DHS ODNI NSC and the SICC Streamline and significantly expedite the SECURITY CLEARANCE PROCESS for owners of the nation’s most critical cyber assets and expedite the siting availability and access of Sensitive Compartmented Information Facilities SCIFs to ensure cleared owners and operators can access secure facilities within one hour of a major threat or incident A C T I O N R E Q U I R E D B Y DHS ODNI NSC Federal Bureau of Investigation FBI Office of Personnel Management and all agencies that issue sponsor clearances Establish clear protocols to RAPIDLY DECLASSIFY CYBER THREAT INFORMATION and proactively share it with owners and operators of critical infrastructure whose actions may provide the nation’s front line of defense against major cyber attacks A C T I O N R E Q U I R E D B Y NSC DHS ODNI FBI and the Intelligence Community PILOT AN OPERATIONAL TASK FORCE OF EXPERTS IN GOVERNMENT AND THE ELECTRICITY FINANCE AND COMMUNICATIONS INDUSTRIES— led by the executives who can direct priorities and marshal resources—to take decisive action on the nation’s top cyber needs with the speed and agility required by escalating cyber threats Explanatory chart on page 16 A C T I O N R E Q U I R E D B Y DOE DHS ODNI NSC the SICC the Department of Defense DOD Treasury and Department of Justice DOJ USE THE NATIONAL-LEVEL GRIDEX IV EXERCISE NOVEMBER 2017 TO TEST the detailed execution of Federal authorities and capabilities during a cyber incident and identify and assign agency-specific recommendations to coordinate and clarify the Federal Government’s unclear response actions A C T I O N R E Q U I R E D B Y DOE DHS ODNI NSC and the SICC Establish an OPTIMUM CYBERSECURITY GOVERNANCE APPROACH to direct and coordinate the cyber defense of the nation aligning resources and marshaling expertise from across Federal agencies A C T I O N R E Q U I R E D B Y DHS ODNI NSC DOJ and DOD Task the National Security Advisor to review the recommendations included in this report and within six months CONVENE A MEETING OF SENIOR GOVERNMENT OFFICIALS to address barriers to implementation and identify immediate next steps to move forward A C T I O N R E Q U I R E D B Y National Security Advisor The time to act is now As a Nation we need to move past simply studying our cybersecurity challenges and begin taking meaningful steps to improve our cybersecurity to prevent a major debilitating cyber attack Our Nation needs direction and leadership to dramatically reduce cyber risks The NIAC stands ready to continue to support the President in this area NIAC Pre-Decisional 4 Introduction Today’s cyber attacks are increasingly dangerous and targeted designed by advanced actors to damage or disrupt critical U S infrastructure that deliver vital services—particularly electricity and financial services Attackers can inflict damage on physical infrastructure by infiltrating the digital systems that control physical processes damaging specialized equipment and disrupting vital services without a physical attack As a nation-state cyber attack on U S infrastructure places private companies on the front line this presents a national security challenge unlike any other It is imperative that Federal and private roles in defending these systems are aligned and mutually supportive The President’s National Infrastructure Advisory Council NIAC believes that the Federal Government and private sector collectively have the tremendous cyber capabilities and resources needed to defend critical private systems from aggressive cyber attacks—provided they are properly organized harnessed and focused Today we’re falling short Cyber capabilities and oversight are fragmented and roles and responsibilities remain unclear We’re simply not organized to keep up with the threat Fortunately we find ourselves in a pre-9 11-level cyber moment with a narrow and fleeting window of opportunity to coordinate our resources effectively Our recommendations call on the Administration to use this moment of foresight to take bold decisive actions—requiring the Federal Government to apply its collective authorities and capabilities in concert with the private sector Our Task In support of Presidential Executive Order 13800 Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure issued in May the National Security Council NSC tasked the NIAC to assess how existing Federal authorities and capabilities could be employed to assist and better support the cybersecurity of critical infrastructure assets that are at greatest risk of a cyber attack that could reasonably result in catastrophic regional or national effects on public health or safety economic security or national security The NIAC formed a Working Group of nine members to complete this tasking Our Assessment The Working Group was presented with a comprehensive dataset of more than 140 different Federal capabilities and related authorities encompassing multiple programs and stand-alone activities While this dataset demonstrates the impressive depth of available Federal capabilities it also underscores the complexity of the Federal structure and mechanisms that house these capabilities We examined the top needs of high-risk industries today then examined how existing Federal authorities and capabilities can be best applied to address them We found that many outstanding Federal capabilities play crucial roles in cyber defense and resilience today However their effectiveness is constrained in the following ways • Private sector knowledge of these capabilities and incentives to use them is limited • Access is hindered by multiple legal and administrative constraints • Government capabilities are scattered across a wide swath of agencies departments and their subunits—a complicated labyrinth comparatively few can navigate effectively • Classification of essential threat information can delay and hinder coordinated response NIAC Pre-Decisional 5 Recommendations and Supporting Findings Our review of hundreds of studies and interviews with 38 cyber and industry experts revealed an echo chamber loudly reverberating the enormity of the challenge and what needs to be done See our expert contributors in Appendix B The challenges the NIAC identifies here are well-known and reflected in study after study including past NIAC studies and recently in great detail by the Commission on Enhancing National Cybersecurity CENC In this crowded space the NIAC’s distinct value lies in its ability to provide insights from senior-level private sector owners and operators into how the government can best work with the private sector to secure the most critical infrastructure assets Achieving the level of coordination required to act on these recommendations will not be easy That is why several of our recommendations involve piloting innovative solutions with the most critical sectors where urgency is high and senior leadership are already being engaged We have studied the cybersecurity challenge in detail and are ready to take action Our 11 recommendations reflect a strong consensus on what must be done next Appendices C and D provide additional background and Appendix E lists references NIAC Pre-Decisional 6 Establish SEPARATE SECURE COMMUNICATIONS networks specifically designated for the most critical cyber networks including “dark fiber” networks for critical control system traffic and reserved spectrum for backup communications during emergencies A Launch a pilot project to identify existing but unused underused fiber networks “dark fiber” that could be used to create a dedicated communication network for critical infrastructure sectors Demonstrate the ability for pilot organizations to operate critical control systems in isolation from public networks making them more difficult to access B Identify and dedicate a secure backup communication system to enable real-time communication during a major cross-sector cyber attack This communication system may reserve a portion of the electromagnetic spectrum to separate it from any internet or cyber-based communication network It should enable for example electric utilities to communicate with utility crews working in the field to manually restore power after an attack A C T I O N R E Q U I R E D B Y U S Department of Energy DOE U S Department of Homeland Security DHS Office of the Director of National Intelligence ODNI National Security Council NSC and the Strategic Infrastructure Coordinating Council SICC Electricity Financial Services and Communications Sectors Supporting Findings • The scale scope and frequency of cyber attacks on digital and physical infrastructure systems is growing rapidly Threats are escalating as more sophisticated and organized attackers are designing targeted attacks to damage or disrupt vital services and critical physical systems o Cyber threats today are two-fold attacks targeting information technology IT which includes the software and networks that underpin business functions in critical sectors like Financial Services and attacks targeting operational technology OT which includes control systems designed to operate physical processes like power flows in the electric grid • Industrial control systems connected to business IT systems and the internet constitute a systemic cyber risk among critical infrastructure Cyber-connected OT systems improve automation and efficiency in the control of critical processes—such as generation processing and delivery of power water fuel and chemicals—but also introduce new cyber risks • Several power companies are moving their operational systems to dedicated closed networks they own rather than shared lines they lease from communication providers Isolating these networks can significantly limit access points giving operators fewer digital gates to guard • Backup networks will quickly become flooded and unreliable in a major cyber attack that disrupts primary communications internet email phone and cell communications The government can dedicate spectrum for critical infrastructure communications to hasten response and recovery NIAC Pre-Decisional 7 FACILITATE A PRIVATE-SECTOR-LED PILOT OF MACHINE-TOMACHINE INFORMATION SHARING TECHNOLOGIES led by the Electricity and Financial Services Sectors to test public-private and companyto-company information sharing of cyber threats at network speed A Use the pilot to identify and evaluate state-of-the-art technologies and software platforms resolve interoperability issues address privacy concerns and work through legal and liability barriers that hamper or limit company-to-company and government-to-company sharing today B Leverage build upon and coordinate across existing platforms designed for rapid publicprivate sharing of cyber threats and attack indicators including  DOE’s Cybersecurity Risk Information Sharing Program CRISP operated by the Electricity Information Sharing and Analysis Center E-ISAC which uses classified analysis of network traffic to identify attacks  The Financial Services Information Sharing and Analysis Center’s FS-ISAC machine-tomachine information sharing programs now also used by some in the Energy Sector  DHS’s Automated Indicator Sharing AIS platform which releases attack indicators from multiple sources C Use lessons learned to identify platforms protocols and best practices that Information Sharing and Analysis Centers ISACs can use to expand the pilot to other critical sectors and guide machine-to-machine research and development R D as appropriate A C T I O N R E Q U I R E D B Y DOE DHS ODNI NSC and the SICC Supporting Findings • The public and private sectors remain unable to move actionable information to the right people at the speed required by cyber threats Threat information and mitigations must move at network speed Advances in machine-to-machine information sharing and automated mitigations show great promise • Machine-to-machine information sharing technology and processes are still immature and must grapple with significant legal liability technology trust and cost challenges A pilot offers the opportunity to coordinate on key issues o Securely sharing real-time system data with the Federal Government requires significant trust regarding how the information will be protected shared and used Leaked data creates significant business risks and liability protections are not court-tested o Machine-to-machine sharing requires consensus on common technologies data formats protocols and policies o Automatically implementing mitigations can create unpredictable outcomes in operational control environments NIAC Pre-Decisional 8 o • • Automated indicator sharing can overwhelm operators with data making it difficult to parse and prioritize The most effective value-added platforms will incorporate public-private and business-tobusiness information exchange o The private sector has more raw real-time network data of value and sharing information between companies is often faster o Government analysis adds value by connecting the dots across companies to reveal potential threats add intelligence insights understand intent and provide warnings Today the time required to vet analyze and obtain permission to share threats creates significant delays o Businesses can best lead the development of trusted solutions that meet their needs ISACs vary dramatically in effectiveness across sectors based on their organization industry trust and buy-in member retention and growth and level of resources But ISACs serve as a critical conduit for threat information from the Intelligence Community and for company-to-company exchange Highly functioning ISACs should be used as a model for other sectors NIAC Pre-Decisional 9 Identify best-in-class SCANNING TOOLS AND ASSESSMENT PRACTICES and work with owners and operators of the most critical networks to scan and sanitize their systems on a voluntary basis A Develop a voluntary cost-shared scanning and assessment program that provides onsite tools and expertise to help organizations 1 test their systems for malware using best-in-class tools 2 sanitize their systems and 3 identify government and industry tools and service providers to upgrade and maintain system security B Establish a Center of Excellence to showcase best-in-class tools across the industry and provide a test bed environment for companies to test and evaluate new software particularly for use by small and medium-sized companies and recognize use and expand cybersecurity programs at existing educational institutions A C T I O N R E Q U I R E D B Y NSC DHS and Congress Supporting Findings • • Managers often do not fully understand the magnitude or complexity of the risks they face nor to what extent their systems may be compromised o Security researchers report that more than 30 percent of computers worldwide likely have some malicious code or malware but few companies understand the extent of potential breaches o As a result many companies are not practicing basic cyber hygiene despite the availability of effective tools and practices There is a broad lack of awareness of the Federal tools available to help scan detect mitigate and defend against cyber threats The owners of critical systems can range from Fortune 100 companies to small businesses with diverse risks resources and cybersecurity needs Customizable solutions are needed and one-sizefits all tools are rarely effective o • Government tools or capabilities are often most useful to entities with lower levels of cybersecurity maturity or during widespread cyber attack Supply chain risks remain a struggle for system operators who lack a trusted method to verify the provenance and custody of digital components from design and manufacture to integration and use o There is no way to test for embedded threats or verify the security of devices for critical OT systems DOE the National Labs and DHS could work with the electricity industry and component manufacturers to develop an industry-driven method to verify and certify supply chain security for OT system devices NIAC Pre-Decisional 10 Strengthen the capabilities of TODAY’S CYBER WORKFORCE by sponsoring a public-private expert exchange program A Implement a public-private sector employee exchange program to provide Federal employees with a better understanding of the day-to-day operations of critical infrastructure and the role of cyber systems This could help the Federal Government better identify and design programs tools and resources that can assist private sector organizations and overcome barriers to their use For private sector employees the program would provide a better awareness of the programs tools and resources available from the Federal Government B Prioritize Federal and Congressional action to expand cyber workforce programs using the findings of the review required in EO 13800 to build a sustainable pipeline and address the expected shortfall in qualified cyber personnel  Congress should also consider expanding scholarship-for-service programs focused on attracting the next-generation cyber workforce  Sponsor clearances for students in college-level cybersecurity programs to speed access to qualified cyber personnel and encourage valuable internship programs A C T I O N R E Q U I R E D B Y NSC DHS and Congress Supporting Findings • The public and private sectors must compete for a limited pool of highly trained cyber experts creating a shortage of cybersecurity leadership and expertise The shortfall of qualified cyber experts is forecasted to reach 1 8 million unfilled positions by 2022 1 o • 1 The Federal Government’s numerous cyber workforce development programs are now being reviewed under EO 13800 and near-term action on the recommendations should be a priority of the Administration See Appendix C for detail Federal cyber experts have a limited understanding of unique private sector systems which limits their ability to provide technical assistance particularly in response to a cyber attack A focused effort is needed to develop both cyber expertise and operational system expertise across industry and government Center for Cyber Safety and Education Global Information Security Workforce Study 2017 NIAC Pre-Decisional 11 Establish a set of LIMITED TIME OUTCOME-BASED MARKET INCENTIVES that encourage owners and operators to upgrade cyber infrastructure invest in state-of-the-art technologies and meet industry standards or best practices A Incentives could include regulatory relief from frequent audits reporting and self-reports when industry standards are routinely met a limited-time tax credit to incentivize security system upgrades or grant and investment programs to fund upgrades or security investments without requiring a rate-based modification B Require implementation of the National Institute of Standards and Technology NIST Cybersecurity Framework to qualify for incentives for the most critical assets and recognize that small- and medium-sized businesses will need additional support to meet the requirements A C T I O N R E Q U I R E D B Y DOE DHS ODNI NSC and the SICC Supporting Findings • Cyber regulations are often blunt tools that are unable to keep up with dynamic risks in an arena where attack and defense capabilities change rapidly over months and years not decades o Prescriptive requirements result in a focus on compliance rather than maintaining best-inclass security However many experts noted that regulations are an effective government tool to drive a minimum level of cyber hygiene o Outcome-based requirements give companies the flexibility to best achieve or exceed objectives while allowing for variations in company structure size and resources • Outcome-based market incentives can encourage large-scale infrastructure upgrades directing company resources toward exceptional security rather than demonstrated compliance with minimum standards • The NIST Cybersecurity Framework is viewed as a foundational document for providing guidance and identifying the minimum best practices for cybersecurity NIAC Pre-Decisional 12 Streamline and significantly expedite the SECURITY CLEARANCE PROCESS for owners of the nation’s most critical cyber assets and expedite the siting availability and access of Sensitive Compartmented Information Facilities SCIFs to ensure cleared owners and operators can access secure facilities within one hour of a major threat or incident A Direct agencies to facilitate and prioritize Top Secret Sensitive Compartmented Information TS-SCI clearances for at least two key personnel at every organization operating the nation’s most critical cyber assets for which an attack could result in catastrophic effects to public safety economic or national security B Improve the transfer of clearances require clearances sponsored by any agency to be accepted by all other agencies and facilitate the transfer of clearance sponsorship as individuals move among agencies and to the private sector C Expand the number of SCIFs nationwide and ensure secure information can be shared simultaneously between SCIFs maintained by different agencies A C T I O N R E Q U I R E D B Y DHS ODNI NSC Federal Bureau of Investigation FBI Office of Personnel Management and all agencies that issue sponsor clearances Supporting Findings • Despite dedicated private sector clearance programs too few of the right individuals in private companies have clearances at the right level to receive timely cyber threat information and act on it Critical businesses need at minimum two cleared individuals to respond to potential threats • The Federal clearance process is time-consuming inefficient and difficult for the private sector to navigate Clearances can take more than a year to process • Federal agencies do not easily transfer clearances or universally reciprocate clearances issued by other agencies Individuals must frequently restart the lengthy clearance process • o Clearances appear to be position-specific and do not move with the individual Individuals who hold a clearance with one agency and move to another role or move from the Federal Government to private sector employment often cannot transfer their clearance to the new agency that must sponsor it and must often restart the entire clearance process from the beginning o This is inefficient duplicative and prevents previously cleared employees from acting to improve the cybersecurity of critical companies Clearances have limited value if private sector individuals cannot rapidly access secure facilities to receive sensitive intelligence on cyber threats Private sector personnel may have to travel more than an hour away to access SCIFs or even fly to DC to attend in-person briefings A fast-moving cyber incident will not allow time to share information at this speed NIAC Pre-Decisional 13 Establish clear protocols to RAPIDLY DECLASSIFY CYBER THREAT INFORMATION and proactively share it with owners and operators of critical infrastructure whose actions may provide the nation’s front line of defense against major cyber attacks A Engage and embed cleared private sector representatives from the most critical infrastructure assets in government intelligence and information sharing centers to help inform and prioritize information declassification B  Examine the Kansas Intelligence Fusion Center as a model for co-location and information sharing This fusion center has private sector representatives cleared to the TS-SCI level who are actively working on cyber issues side-by-side with the National Guard and other agency representatives  Consider significantly expanding the National Cybersecurity and Communications Integration Center NCCIC which provides a central location to coordinate public-private information sharing and response and increasing ISAC integration Expand the mission of intelligence agencies to proactively share intelligence with private sector owners and operators to support the defense of critical civilian infrastructure Establish protocols that require intelligence analysts and Federal response officials to rapidly share threat vectors and attack indicators—either with cleared individuals or through declassification—as early as possible A C T I O N R E Q U I R E D B Y NSC DHS ODNI FBI and the Intelligence Community Supporting Findings • The inability to rapidly declassify and share the less-sensitive elements of a potential threat like threat indicators or vulnerabilities leaves private companies in the dark for too long o Those with a high need to know—businesses who could immediately act to secure critical systems—are often some of the last to know o Our processes to share classified intelligence were designed for slower-paced threats and are insufficient as cyber threats escalate • Intelligence agencies do not have the clear mission or processes to proactively declassify information as a threat unfolds as they have not historically needed to treat private businesses as primary customers of threat data o Intelligence agencies have the authority to declassify and share information but often lack the clear mission While DHS has a clear mission to share with the private sector it often does not “own” the information and must work through other agencies to declassify and share • Building trusted relationships is at the core of effective information sharing Agencies and businesses must work as trusted partners in securing the nation from cyber threats and work proactively to understand operational and information needs NIAC Pre-Decisional 14 PILOT AN OPERATIONAL TASK FORCE OF EXPERTS IN GOVERNMENT AND THE ELECTRICITY FINANCE AND COMMUNICATIONS INDUSTRIES—led by the executives who can direct priorities and marshal resources—to take decisive action on the nation’s top cyber needs with the speed and agility required by escalating cyber threats A Establish a three-tiered task force that includes 1 senior executives in industry and government with the authority to set priorities and direct resources 2 operational leaders who work the issues and implement strategic direction and 3 dedicated full-time operational staff from both industry and government that dig in and solve complex issues This operational component is crucial if the task force is to be successful B Leverage the SICC to identify executives in the Electricity Financial Services and Communications sectors willing to participate in the pilot task force C Use the NIAC’s recommendations and findings as a starter agenda to provide critical areas for focus The task force should tackle persistent barriers to cyber coordination and information sharing such as legal and liability issues data privacy concerns fragmentation of authorities and cost allocation for improving the security of private networks D Use lessons learned and best practices from this pilot to expand the task force coordination approach to other sectors and assets A C T I O N R E Q U I R E D B Y DOE DHS ODNI NSC the SICC the Department of Defense DOD Treasury and the Department of Justice DOJ NIAC Pre-Decisional 15 Recommendation 8 pilots an approach for agile integrated action that we believe will be pivotal to achieving the level of coordination required to act on all recommendations The graphic below illustrates how this pilot could be implemented NIAC Pre-Decisional 16 Supporting Findings • Today’s fragmentation of Federal cybersecurity capabilities authorities missions roles and oversight is inefficient and precarious A bold new approach is needed • Solutions to intractable cyber issues cannot be designed or led by any one agency The NIAC identified persistent foundational coordination issues that will require a challenging reexamination of how agency missions are aligned and authorities are applied Executive leadership and direction is required • Key stakeholders in the Administration must champion cybersecurity with the private sector We need senior leaders to converge on national priorities establish a clear agenda and direct an operational team of cross-agency public-private staff to triage and make headway on the biggest needs o The operational task force would not be another advisory council or other passive coordination group It is intended to design and implement solutions • Senior-executives are crucial to driving action because of their ability to set strategic direction and priorities apply resources and exercise accountability • A pilot task force with the sectors facing the most urgent threats and that have high executive engagement i e Electricity Financial Services and Communications Sectors will be able to mobilize quickly tackle the most pressing issues and allow the format to be tested to determine if it can be applied more broadly across sectors o Senior executives in the Electricity Financial Services and Communications Sectors have formed the Strategic Infrastructure Coordinating Council SICC to serve as a focal point for government engagement and cross-sector coordination NIAC Pre-Decisional 17 USE THE NATIONAL-LEVEL GRIDEX IV EXERCISE NOVEMBER 2017 TO TEST the detailed execution of Federal authorities and capabilities during a cyber incident and identify and assign agency-specific recommendations to coordinate and clarify the Federal Government’s response actions where they are unclear A Invite executives and representatives from the Financial Services and Communications sectors to participate in exercise planning ownership and execution B Require key agencies to develop white papers in advance of the exercise that outline specifically how Federal authorities will be executed in extreme situations to support response Use the National Cyber Incident Response Plan NCIRP which outlines roles and responsibilities and identify potential gaps in processes and protocols C Test Federal decision-making protocols and procedures as it exercises specific authorities and capabilities during the exercise For example DHS has conducted extensive research into how to apply the Defense Production Act during an incident to prioritize resource allocation D Use the exercise to further validate and refine the results of the DOE DHS and DNI assessment—called for in EO 13800—of the Nation’s readiness for a prolonged power outage associated with a significant cyber incident E Direct specific recommendations from the GridEx after-action report to specific agencies for implementation The Administration should support and provide resources for agencies to implement the recommendations A C T I O N R E Q U I R E D B Y DOE DHS ODNI and NSC and the SICC Supporting Findings • • Our response to a large-scale cyber attack with physical consequences on critical infrastructure today is likely to be insufficient High-level Federal cyber incident response authorities are clear but the specific timing processes and coordination of resources is not well understood by Federal personnel or industry owners and operators o Several agencies have substantial emergency authorities during a major cyber attack but it remains unclear what triggers those authorities how they are applied who authorizes them and when o High-level cyber incident response roles are defined in the NCIRP but it remains unclear what triggers Federal assistance and what it will look like in practice The timing and resource needs for a cyber incident will be largely different than for physical disaster response Detailed policies procedures and Federal technical assistance and mutual assistance agreements must be developed and exercised Gaps and issues must be addressed in coordination NIAC Pre-Decisional 18 Establish an OPTIMUM CYBERSECURITY GOVERNANCE APPROACH to direct and coordinate the cyber defense of the nation aligning resources and marshaling expertise from across Federal agencies A Use the cyber task force see recommendation #8 to evaluate effective cyber governance models from other nations and recommend the best approach to centralize and elevate cyber governance and enable national-level coordination for public-private cyber defense Although the circumstances in the United States are different than in those nations we believe that better coordination at the senior levels of the U S government would improve operational control over individual Federal elements and help ensure an effective response to the cyber threat B Consider establishing a senior-level position or similar unit that can effectively coordinate and exercise operational control over individual Federal organizations This may require congressional action and broad public recognition of the urgency of the cyber threat—which experience shows may not come until after a catastrophic cyber incident occurs A C T I O N R E Q U I R E D B Y DHS ODNI NSC DOJ and DOD Supporting Findings • The substantial capabilities among Federal agencies are collectively insufficient to address sophisticated cyber threats because they are divided uncoordinated and often duplicative o There is a large amount of dedicated mission-oriented work being done by individual agencies There are 6 Federal cybersecurity centers 140 cyber authorities and capabilities across 20 agencies 4 tools and 8 assessment programs o This is indicative of both the enormous complexity of the problem and the fact that there are not and cannot be silver-bullet solutions • Existing structures and legislative authorities result in numerous agencies and dozens of Congressional committees with cybersecurity oversight yet limited national-level consensus on priorities for focused action • Innovative national governance models for cybersecurity show that effective coordination at speed is driven by a central authority that can coordinate cyber priorities for the nation align industry and government resources and provide national leadership for cyber defense Appendix D summarizes new governance models recently unveiled by Israel and the United Kingdom NIAC Pre-Decisional 19 Task the National Security Advisor to review the recommendations included in this report and within six months CONVENE A MEETING OF SENIOR GOVERNMENT OFFICIALS to address barriers to implementation and identify immediate next steps to move forward A In 12 months task the NIAC with tracking the status of implementing these recommendations to create a focused and planned opportunity to measure our progress to improving cybersecurity of the Nation’s most critical infrastructure assets A C T I O N R E Q U I R E D B Y National Security Advisor Supporting Findings • There is an urgent need to act Major attacks and watershed incidents—like the 9 11 attacks—have historically triggered a new level of strategic coordinated action driven by public demand and strong political will We have an opportunity to demonstrate foresight and leadership before a cyber attack that severely disrupts critical services • We believe a senior Administration official like the National Security Advisor can provide the authority and leadership to convene heads of government agencies and lead a rapid advancement in the Nation’s cyber capabilities with industry leaders NIAC Pre-Decisional 20 Moving Forward Fundamental Change The time to act is now As a Nation we need to move past simply studying our cybersecurity challenges and begin taking meaningful steps to improve our cybersecurity to prevent a major debilitating cyber attack The Working Group appreciates the Administration’s attention on key issues that were continuously reiterated during this study including the need to build and sustain a cyber workforce identify strategies to deter adversaries and to examine our readiness to respond to a major cyber attack on our electric grid National Vision and Leadership We envision a national strategy—championed by senior leaders—that will allow government and industry to harness capabilities to successfully deter and withstand aggressive cyber attacks Achieving a shared vision will require significant near-term and long-term commitments to ultimately achieve • Strong public support and political will to act in support of cybersecurity as a national priority • Strong leadership from the most senior levels of government and the private sector • Federal cyber authorities and capabilities are aligned coordinated and easily accessible across government and the private sector • Businesses receive incentives and technical assistance to meet basic standards for cybersecurity • The Nation is positioned to effectively protect and defend against cyber attacks mitigate the impact of cyber attacks and quickly respond and recover following an incident • The United States is a world leader in cybersecurity USA Inc —the concept of the public and private sector working seamlessly together like a unified business unit—has cemented its position as a world leader in cyber technology and cyber workforce Our Nation needs direction and leadership to dramatically reduce cyber risks The NIAC stands ready to continue to support the President in this area NIAC Pre-Decisional 21 Appendix A Study Methodology The private sector and Federal Government are extensively examining cyber risks in both individual and coordinated efforts Over the past few years a robust body of good work has been completed that has outlined the current cyber risk landscape the need to take action and what needs to be done In this crowded space the NIAC’s distinct value lies in its ability to provide insights from senior-level private sector owners and operators into how the government can best work with the private sector to secure the most critical infrastructure assets Charge to the NIAC The May 11 2017 Presidential Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure EO 13800 called for improving the cybersecurity of critical infrastructure at greatest risk by applying existing Federal authorities and capabilities On May 15 2017 the White House through the National Security Council NSC tasked the NIAC to review existing Federal authorities and capabilities and examine how they could be employed to assist and better support the cybersecurity of critical infrastructure assets that are at greatest risk of an attack that could reasonably result in catastrophic regional or national effects on public health or safety economic security or national security Study Approach To conduct this study the Council formed the Cyber Study Working Group made up of nine NIAC members to examine how existing Federal authorities and capabilities could be applied in the private sector To complete the study the Working Group • Built on the NIAC Cyber Scoping Study completed in February 2017 For that study the Working Group interviewed more than 20 past and present senior leaders in government and the private sector received four classified and four unclassified briefings and reviewed many of the recent U S strategies and expert reports on how to address cyber risk The scoping study identified three urgent cyber priorities that were affirmed by this current study 1 Triage today’s problems  Implement immediate and urgent fixes to address the most serious cyber risks to critical infrastructure Focus on the sectors and set of assets that if compromised would result in major economic safety and security consequences to the United States  Improve cyber hygiene across all critical infrastructure and consider some form of compliance  Improve information sharing mechanisms leading to machine-to-machine exchanges 2 Develop novel approaches for cyber resilience  Design next-generation cyber systems that are inherently secure resilient and selfhealing particularly those that control critical functions Develop solutions that make it extremely difficult and economically unattractive to extract value 3 Strengthen public-private partnership and leadership NIAC Pre-Decisional 22  Develop effective executive-level public-private mechanisms to strengthen leadership and efficient decision-making concerning critical cyber incidents and policy actions  Streamline reconfigure and clarify roles and responsibilities within the Federal Government • Focused on the leading-edge highly critical sectors of Electricity and Financial Services which have been cited by the NIAC and other entities such as the Homeland Security Advisory Council as vital because they underpin the operations of other critical infrastructure sectors As a result focusing on these sectors provided broad insights that can be applied in other critical sectors See Appendix C for more information • Leveraged the wealth of existing information and built on the body of extensive work examining the Nation’s cybersecurity For example the most recent and most comprehensive of which was the Commission on Enhancing National Cybersecurity CENC Report on Securing and Growing the Digital Economy published in December 2016 The CENC—comprised of 12 representatives from industry academia and former government officials—identified six imperatives 16 recommendations and 52 specific actions to move forward The recommendations address many of the challenges identified in this and other studies including cyber workforce development increasing research and development and better aligning and understanding Federal and private sector roles and responsibilities • Identified industry cyber needs and started with the assumption that Federal authorities and capabilities exist and could be applied to the private sector • Conducted interviews with 22 senior leaders and experts in government and the private sector including five individuals who were also interviewed during the NIAC Cyber Scoping Study Appendix B for a list of interviewees and report contributors In total the Working Group built on information from interviews with 38 senior leaders and experts between the two closely-linked studies • Reviewed list of more than 140 different Federal capabilities and related authorities provided to the Working Group in July to identify capabilities that aligned with industry needs and existing capabilities highlighted in interviews and research NIAC Pre-Decisional 23 Appendix B Acknowledgements Working Group Members Mike Wallace Co-Chair Former Vice Chairman and COO Constellation Energy Constance H Lau President and CEO Hawaiian Electric Industries Inc NIAC Chair Robert Carr Co-Chair Founder and Chairman Give Something Back Foundation and Founder and former CEO Heartland Payment Systems Tom Noonan Former General Manager Cisco Energy Services Jan Allman President CEO and General Manager Marinette Marine Corporation Ben Fowke Chairman President and CEO Xcel Energy Margaret E Grayson Consultant E2M LLC former President MTN Communications Government Services former President and CEO V-ONE Security Services Keith Parker General Manager and CEO Metropolitan Atlanta Rapid Transit Authority Beverly Scott Ph D CEO Beverly Scott Associates LLC former General Manager Massachusetts Bay Transportation and Rail and Transit Administrator for the Commonwealth of Massachusetts NIAC Vice Chair Working Group Support Saba Long Owner Obelisk Strategies Nathaniel T Millsap Jr Director of Industrial Security and Technology Marinette Marine Corporation Scott Seu Senior Vice President Public Affairs Hawaiian Electric Company Rivka Tadjer Chief of Staff Give Something Back Foundation Frank Prager Vice President Policy and Federal Affairs Xcel Energy Interviewees Scott Aaronson Executive Director Security and Business Continuity Edison Electric Institute EEI Gen Keith Alexander President and CEO IronNet former Commander U S Cyber Command and former Director National Security Agency NSA John Bear President and CEO Midcontinent Independent System Operator MISO William Terry Boston former President and CEO PJM and current NIAC member Michael Daniel former Special Assistant to the President and former Cybersecurity Coordinator Lt Gen Albert J Edmonds Chairman and CEO of Edmonds Enterprise Services Inc CEO of Logistics Applications Inc former Director Defense Information Systems Agency DISA and current NIAC member Daniel Ennis Center for International and Security Studies Fellow University of Maryland former Chief Tailored Access Operations NSA former Director Threat Operations Center NSA Nate Fick CEO Endgame Lt Gen Reynold Hoover Deputy Commander U S Northern Command NIAC Pre-Decisional 24 Interagency Working Group with representatives from more than a dozen Federal agencies Rob Joyce Assistant to the President for Homeland Security and Counterterrorism James Katavolos Senior Vice President Citigroup Henry Kenchington Deputy Assistant Secretary Cybersecurity and Emerging Threats Research and Development Division Office of Electricity Delivery and Reliability OE U S Department of Energy DOE Bob Kolasky Acting Deputy Under Secretary for the National Protection and Programs Directorate NPPD and Deputy Assistant Secretary for the Office of Infrastructure Protection IP U S Department of Homeland Security DHS Richard Ledgett former Deputy Director NSA Kevin Mandia CEO FireEye Jeanette Manfra Assistant Secretary for Cybersecurity and Communications NPPD DHS Tom McDermott Deputy Assistant Secretary for Cyber Policy Office of Policy DHS Bill Nelson President and CEO Financial Services Information Sharing and Analysis Center FS-ISAC Edward Reiskin Director of Transportation San Francisco Municipal Transit Authority SFMTA Lisa Walton Chief Technology Officer SFMTA Errol Weiss Senior Vice President Threat Analytics and Information Sharing Bank of America Lucia Ziobro Chief for Cyber Operational Engagement Federal Bureau of Investigation FBI Kristin Lovejoy CEO BluVector NIAC Cyber Scoping Study Interviews Oct 2016-Feb 2017 Scott Aaronson Executive Director Security and Business Continuity Edison Electric Institute EEI Michael Assante Lead Industrial Control Systems ICS and Supervisory Control and Data Acquisition SCADA Security SANS Institute and Co-founder of NexDefense Rich Baich Chief Information Security Officer Wells Fargo and Company Chair Financial Services Sector Coordinating Council FSSCC Alfred R Berkeley III Chairman Princeton Capital Management and former NIAC Chair Vice Chair and member John Carlson Chief of Staff FS-ISAC Vice Chair FSSCC R James Caverly Adjunct Research Staff Member Institute for Defense Analyses and former Director Partnership and Outreach Division IP DHS Darrell Darnell Senior Associate Vice President for Safety and Security The George Washington University former National Security Council NSC staff Caitlin Durkovich Director Toffler Associates and former Assistant Secretary IP DHS Tom Fanning Chairman President and CEO of Southern Company Chair of the Federal Reserve Bank of Atlanta Chairman of EEI and Co-Chair of the Electricity Subsector Coordinating Council ESCC Glenn Gerstell General Counsel NSA and former NIAC member Eric Goldstein Branch Chief Partnership and Engagement Office of Cybersecurity and Communications DHS former Senior Counselor to the Undersecretary NPPD DHS Patricia A Hoffman Principal Deputy Assistant Secretary and Acting Assistant Secretary OE DOE NIAC Pre-Decisional 25 Bob Kolasky Acting Deputy Under Secretary NPPD DHS Acting Assistant Secretary IP DHS Monica Maher Director for Cybersecurity NSC Richard Moore Associate Director for Security Policy and Plans U S Department of Transportation Stephanie Morrison former Director Critical Infrastructure Policy NSC Bill Nelson President and CEO FS-ISAC Brian Peretti Director Office of Critical Infrastructure Protection and Compliance Policy U S Department of Treasury Robert Stephan Colonel USAF Ret Executive Director Gryphon Scientific and former Assistant Secretary IP DHS Paul Stockton Managing Director Sonecon Senior Fellow Johns Hopkins Applied Physics Lab former Assistant Secretary for Homeland Defense U S Department of Defense Brian Tishuk General Counsel FS-ISAC Executive Director of the FS-SCC Ahsha Tribble Ph D Deputy Regional Administrator Federal Emergency Management Agency Region 9 and former NSC staff NIAC Cyber Scoping Study Briefings Classified Unclassified • National Security Agency NSA • NSA and U S Cyber Command • U S Cyber Command • Federal Bureau of Investigation • Office of the Director of National Intelligence ODNI • Mike Assante SANS Institute • Draper Lab • U S Cybersecurity and Emergency Response Team US-CERT Department of Homeland Security Study Support Resources Ginger Norris Designated Federal Officer NIAC IP DHS Deirdre Gallop-Anderson Alternate Designated Federal Officer NIAC IP DHS Beth Ward Nexight Group LLC Jack Eisenhauer Nexight Group LLC Jim Carey Nexight Group LLC Jennifer Ganss Nexight Group LLC Megan Wester BayFirst Solutions LLC Lindsay Kishter Nexight Group LLC NIAC Pre-Decisional 26 Appendix C Urgency of Cyber Threats to Critical Sectors Given the short-time frame for this study the Working Group focused on sectors facing urgent threats that exemplify the complexity and scale of the cyber challenge for the Nation’s critical infrastructure The electricity and Financial Services Sectors are not only interconnected but also underpin all other sectors The Homeland Security Advisory Council Cybersecurity Subcommittee stated in its 2016 report that these sectors along with the Communications Sector face rapidly growing cyber threats and because of other sectors’ reliance on them could be attractive targets for a cyber attack 2 A large-scale cyber attack on one of these sectors could cause cascading effects across multiple sectors threatening public health and safety as well as economic and national security 1 Increasing Sophistication and Intent of Cyber attacks Over the past 25 years the technical knowledge needed to launch an attack has decreased Malicious cyber tools and exploits can be easily found on the Internet and may be used by lone actors organized criminal and terrorist groups or nation-states At the same time the sophistication of cyber attacks has increased For example the Stuxnet attack first discovered in 2010 disrupted Iranian nuclear facilities through a series of events the malware infiltrated Windows systems through “Experts agree that the cyber threat is USB drives then autonomously spread to programmable logic so grave because barriers to entry are controllers that ultimately destroyed 984 uranium enrichment extremely low while potential rewards centrifuges 3 Stuxnet showcases an early case of successfully are great ” - NSA General Counsel Glenn targeting industrial control systems ICS and illustrates how a Gerstell Keynote address at Duke Law’s cyber attack can have very serious physical consequences Center on Law Ethics and National Security 2017 Conference Not only are attacks more sophisticated attributing attacks to specific actors is difficult if the cyber intrusion is even detected As more devices become Web-enabled or connected to a network the number of cyber intrusions increases The U S Department of Homeland Security DHS Industrial Control Systems Cyber Emergency Response Team ICS-CERT reported 290 cyber attacks on critical infrastructure control systems in fiscal year 2016 4 In the second installment of its Quadrennial Energy Review published in January 2017 the U S Department of Energy DOE stated “In the current environment the U S electric grid faces imminent danger from cyber attacks absent a discrete set of actions and clear authorities to inform both responses and threats Widespread disruption of electric service because of a transmission failure initiated by a cyber attack at various points of entry could undermine U S lifeline networks critical defense infrastructure and much of the economy it could also endanger the health and safety of millions of citizens ” 5 HSAC Final Report of the Cybersecurity Subcommittee Part I-Incident Response 2016 Zetter “An unprecedented look at Stuxnet the world’s first digital weapon ” 2014 4 NCCIC ICS-CERT Year in Review 2016 5 DOE The Second Installment of the QER January 2017 2 3 NIAC Pre-Decisional 27 2 Ability to Attack Physical Systems through Cyber Means All businesses face the threat of cyber attacks on their business networks customer accounts communication systems Websites and proprietary data Many critical infrastructure companies however face additional threats to their operational technology OT systems—often called ICS or supervisory control and data acquisition SCADA —which operate physical processes such as the generation processing and delivery of power water fuels and chemicals and the controls for communication and transportation Cyber attacks on OT can potentially disrupt vital services damage critical equipment threaten human health and safety and trigger disruptions in other sectors Cyber-connected OT devices have significantly improved automation and efficiency in the monitoring and measurement of critical functions but these new efficiencies also introduce vulnerabilities Traditionally OT security—particularly in the Electricity Sector—has relied on obscurity and specialization in keeping threat actors from disrupting ongoing operations 6 An individual utility’s system was highly customized to meet the needs of its customers and might only be compatible with components from a specific vendor these characteristics limited an attacker’s ability to find and execute exploits against grid components Unlike the central SCADA or IT systems OT systems are not automatically updated with service packs new releases and bug fixes In reality the OT devices are often running the same software as when they were installed 10-15 years ago at a time when physical separation form the network IT systems was considered secure 7 Operational Technology ≠ Information Technology Web-enabled sensing and measuring technologies have enabled the critical systems to become more reliable and automated but have also created more vulnerabilities that differentiate OT from IT • Compromise of OT can disable operations disrupt critical services to customers and damage highly specialized equipment • OT must be able to survive a cyber incident while sustaining critical functions • Many OT systems must operate in real-time with 24 7 availability and are unable to go offline for patching or upgrades • OT components may be very simple devices and may not have enough computing resources to support additional cybersecurity capabilities • OT components may be widely dispersed and located in publicly accessible areas where they are subject to physical tampering Upgrading replacing or patching network components could result in an interruption of service and even a brief interruption can have cascading effects on how other sectors function These systems also cannot simply be turned off when an attack is detected OT security technologies require not only focusing on detecting attacks but maintaining functionality during them Figure 1 is a schematic that highlights the interdependencies between sectors and the SCADA controls that are integral to the operations of electricity fuels water and transportation If one sector fails the products and services they provide to other sectors may be disrupted as well 6 7 DOE Electric Grid Security and Resilience Establishing a Baseline for Adversarial Threats 2016 Fowke “Testimony before the U S Senate Committee on Energy and Natural Resources Subcommittee on Energy ” 2017 NIAC Pre-Decisional 28 Figure 1 Interdependencies Compound Cyber Risks 8 The U S Electricity Sector consists of over 3 300 facilities—a mix of publicly- and privately-owned businesses or municipalities—responsible for the generation transmission and distribution of electricity throughout the country These systems are all interconnected and a disruption in one small utility can potentially cascade into a widespread and long-term outage In 2015 a major cyber attack caused widespread disruption to power services throughout Ukraine resulting in 225 000 customers without power In this attack three electric distribution companies and several substations in Ukraine were targeted by readily available malware tools 9 Long-term planning and coordination contributed to the success of this extensive cyber attack investigations determined that the affected entities were breached about nine months prior through spear-phishing emails 10 This was one of the first examples of a targeted and sophisticated cyber attack that disrupted electricity delivery In addition to causing power disruptions cyber attacks on the Electricity Sector can damage highly specialized and costly equipment Recovering from system or equipment failure—particularly in the bulk power system—requires a careful and time-consuming restoration process which potentially keeps customers stranded in the dark for a long period The Financial Services Sector consists of investment institutions insurance companies credit and financing organizations and the infrastructure that enables these businesses to function 11 These organizations DOE The Second Installment of the QER 2017 DOE The Second Installment of the Quadrennial Energy Review 2017 10 DOE Electric Grid Security and Resilience Establishing a Baseline for Adversarial Threats 2016 11 DHS “Financial Services Sector” Webpage Last updated July 6 2017 8 9 NIAC Pre-Decisional 29 ranging in size from small businesses to multinational corporations are responsible for millions of dollars in assets In 2016 the chair of the Securities and Exchange Commission cited cybersecurity as the biggest risk to the sector 12 Later that year the Bangladesh Central Bank’s network was infiltrated by hackers who were able to obtain log-in credentials to the Society for Worldwide Interbank Financial Telecommunications Network SWIFT Access to the network which allows financial institutions to share information enabled the hackers to steal over $80 million 13 While the SWIFT attack shows the inherent risks to individual financial entities future sophisticated attacks could result in larger-scale and longer-term disruptions to the economy Such compromises to the data of major financial institutions can erode consumer confidence Financial Services Sector disruptions can also have cascading impacts on other sectors that require financial data systems for day-to-day operations For example in 2012 several financial institutions large and small withstood coordinated distributed denial-ofservice DDoS attacks 14 3 Defining and Unifying Public and Private Sector Roles Throughout our Nation’s history we have developed well-established roles for government and the private sector to manage various kinds of physical risks For example if there is a threat of an attack through a missile or bomb the Federal Government has a clearly defined role to step in for the common defense of the Nation For cyber threats of a similar scale the private sector is the first line of defense and the role of the government to defend critical systems it does not own is unclear “Even though the Internet is now ubiquitous in our lives cyber remains the only domain where we ask private companies to defend themselves against Russia China Iran and other nation states ”— Penny Pritzker former Secretary of Commerce September 27 2016 Keynote address at the U S Chamber of Commerce Cybersecurity Summit It is widely agreed that the Federal Government bears the responsibility of protecing the United States from a major nation-state attack or an attack that could have major public safety economic or national security implications But the traditional roles and responsibilities become less clear in the cyber realm particularly the shared responsibility between government and industry as cyber attacks become more sophisticated and the potential consequences increase As it becomes harder and more expensive to protect systems from cyber attacks attacks begin to outpace the capabilities of any individual company and the government has more of a role to play How these roles are shared remains a challenge Repeatedly throughout the study the Working Group heard that the Federal Government should exercise its authority to deter adversaries The United States has deterrence power as part of its diplomatic tools It must find a way to extend deterrence capabilities into the cyber domain to make it clear to nation-states and other adversaries that there are consequences for attacks in the same way there would be in a traditionally physical attack Lambert “SEC says cyber security biggest risk to financial system ” 2016 Security Scorecard 2016 Financial Industry Cybersecurity Research Report 14 DHS Financial Services Sector-Specific Plan 2015 12 13 NIAC Pre-Decisional 30 Shared Need for Cyber Workforce The Federal Government and the private sector have both identified the shared need for a larger and more skilled cyber workforce This talent shortage is expected to grow over the next few years The Center for Cyber Safety forecasted the workforce shortage will reach 1 8 million unfilled cyber positions by 2022 15 In 2016 the Federal Cybersecurity Workforce Strategy included a four-pronged government-wide approach to increasing cyber jobs by expanding the workforce through education and training increasing recruitment and outreach improving employee retention through developmental opportunities and identifying specific cybersecurity workforce gaps 16 The Working Group learned from interviews that there are numerous programs already in place tackling this issue including the National Science Foundation’s CyberCorps Scholarship for Service Defense Information Systems Agency Pathways Program and the National Initiative for Cybersecurity Careers and Study An assessment of the scope and sufficiency of the Nation’s cybersecurity workforce and education efforts is already underway to meet requirements of EO 13800 17 The results of the assessment are expected later this year and the Working Group has great interest in learning more about the recommendations for growing and sustaining the Nation’s cybersecurity workforce 18 4 Examples of Success As the comprehensive dataset of more than 140 different Federal capabilities and related authorities illustrates there is an impressive depth of available Federal capabilities available today including capabilities that play a crucial role in cyber defense and information sharing National Cybersecurity and Communications Integration Center The National Cybersecurity and Communications Integration Center NCCIC serves as a Federal civilian interface for multi-directional and cross-sector information sharing The NCCIC includes four branches NCCIC Operations and Integration NO I United States Computer Emergency Readiness Team US-CERT Industrial Control Systems Cyber Emergency Response Team ICS-CERT and National Coordinating Center for Communications NCC 19 The Electricity Information Sharing and Analysis Center E-ISAC and Financial Servives Information Sharing Analysis Center FS-ISAC both have representatives at the NCCIC allowing for better collaboration and coordination of information sharing Information Sharing and Analysis Centers ISACs were frequently identified as successful mechanisms for sharing threat information and working collaboratively within sectors and with government partners Electricity Information Sharing and Analysis Center The E-ISAC is a division of the North American Electric Reliability Corporation NERC that gathers and analyzes security information coordinates incident management and communicates mitigation strategies with stakeholders within the electricity industry across interdependent sectors and with government partners 20 The E-ISAC works in collaboration with DOE and the Electricity Subsector Coordinating Council Center for Cyber Safety and Education Global Information Security Workforce Study 2017 The White House “Strengthening the Federal Cybersecurity Workforce ” Press release 2016 17 The White House Executive Order—Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure 2017 18 NICE NICE Webinar Series 2017 19 NCCIC “NCCIC ” 2017 20 E-ISAC “About ” 2017 15 16 NIAC Pre-Decisional 31 ESCC to serve as the primary security communications channel for the Electricity Sector and enhances its ability to prepare for and respond to cyber and physical threats vulnerabilities and incidents 21 The EISAC’s success is built on trusted relationships All information shared with the E-ISAC is protected from the Federal Energy Regulatory Commission FERC NERC and the Compliance and Enforcement Program via signed legal agreements NERC corporate policy and physical and logical separation from NERC 22 Financial Services Information Sharing and Analysis Center The FS-ISAC is often cited as a successful model that provides member-to-member information sharing as well as providing various levels of information to arm companies with the information they need to take action It has almost 7 000 members in more than 30 countries including banks credit unions payment processors broker-dealers third party service providers and insurance companies The FS-ISAC uses a traffic-light protocol to share different levels of information based on classification It is also working to establish the Energy Analytic Security Exchange EASE This new intelligence sharing community for utilities and energy grid companies is intended to provide members with real-time and “near real-time intelligence the ability to monitor risks to extended supply chains and access to cross-industry intelligence ” 23 The FS-ISAC is also working to form a more targeted special interest group for the financial institutions deemed most critical for national and economic security By taking the lead in this area the Financial Services Sector is working to improve the cyber capabilities and reduce costs for these entities and provide a forum for them to engage more intensely with U S Government agencies Ultimately this group could be expanded beyond the Financial Services Sector to include participation of all assets deemed most critical to national and economic security Cybersecurity Risk Information Sharing Program DOE’s Cybersecurity Risk Information Sharing Program CRISP was also cited as a successful example of an information sharing initiative for rapidly collecting analyzing and disseminating threat information among participating utilities The hardware for capturing network data was first developed by DOE in partnership with its National Labs with the intent of automating data collection and analysis The data collection is fully automated and analyzed incorporating input from DOE and the Intelligence Community The analyses are then distributed as alerts or mitigation measures to participating utilities While the hardware and analytical capabilities were first developed in the public sphere CRISP is managed and operated by the E-ISAC The program’s success is underlined by the fact that it initially faced a number of barriers and resistance from both the private and public sectors e g compliance with privacy laws classification levels Utilities participating in CRISP serve over 75 percent of U S electricity customers CRISP’s machine-to-machine threat information sharing platform can also be adapted to enable company-to-company information sharing E-ISAC “About” Webpage July 2017 E-ISAC “E-ISAC Brochure ” June 2017 23 FS-ISAC “FS-ISAC Launches New Energy Sector Sharing Community” Press Release February 15 2017 21 22 NIAC Pre-Decisional 32 Appendix D National Cyber Governance United Kingdom and Israeli Models The Working Group repeatedly heard in interviews that the U S Federal Government is not organized to effectively deploy existing cyber capabilities and authorities The United Kingdom UK and Israel were cited as models of nations that faced major cyber threats and challenges which triggered a reorganization of how these governments approached cybersecurity Below is a brief overview of what those countries have in place should the United States decide to move forward with a fundamental restructuring of cyber authorities Overall there are three key takeaways 1 The national government has established one central point of federal cyber authority 2 Cyber offense including attribution and strike-back capabilities is identified as a clear responsibility that government plays in deterring cyber adversaries 3 Cyber defense and cyber technology leadership are inextricably linked 1 Cyber Efforts in the United Kingdom National Cyber Security Strategy 2016-2022 In November 2016 the United Kingdom published its plan to make the UK more secure and resilient in cyberspace The strategy includes three main objectives 1 defend against evolving cyber threats and effectively respond to incidents 2 deter and disrupt hostile action and take offensive actions if needed 3 develop the cybersecurity industry R D and talent needed 24 It also included a £1 9 billion investment The strategy established that the government is ultimately responsible for assuring the country’s cyber resilience and that the UK would not accept the risks created by businesses not taking the necessary steps to manage cyber threats 25 National Cyber Security Centre The National Cyber Security Centre NCSC was launched in October 2016 and officially opened in February 2017 “to be the authority on the UK’s cyber security environment sharing knowledge addressing systemic vulnerabilities and providing leadership on key national security issues ” The NCSC is a public-facing organization with reach back to the Government Communications Headquarters GCHQ the UK equivalent of the National Security Agency NSA and is intended to provide a unified source of threat intelligence 26 The NCSC replaced three cyber organizations—the Centre for Cyber Assessment CCA Computer Emergency Response Team UK CERT UK and CESG the GCHQ’s information security arm Cyber-related responsibilities were also shifted from the Centre for the Protection of National Infrastructure CPNI 27 HM Government National Cyber Security Strategy 2016-2022 2016 Ibid 26 HM Government “National Cyber Security Centre ” 27 Ibid 24 25 NIAC Pre-Decisional 33 Office of Cyber Security and Information Assurance The Office of Cyber Security and Information Assurance OCSIA helps determine cybersecurity priorities provides strategic direction and coordinates the government cybersecurity program OCSIA also supports education and awareness initiatives for the country works with the private sector to exchange information and promote best practices in cybersecurity ensures that cyber capabilities are maintained and improved as needed The office coordinates with the NCSC 28 Existing Regulations General Data Protection Regulation An EU regulation intended to strengthen and unify personal data protection including the export of personal data outside the EU This replaces the data protection directive from 1995 and will become effective in May 2018 It requires business to have capabilities to protect personal data and requires personal data breaches be reported with fines resulting from breaches an additional possibility The Information Commissioner’s Office ICO and NCSC are working to ensure UK organizations can thrive under the directive 29 The Directive on security of network and information systems NIS Directive An EU directive that establishes minimum requirements that high-risk organizations and digital service providers should have for cyber protection to ensure these groups build comprehensive cyber risk management programs It aims to improve cooperation among EU countries in cyber incidents 30 2 Cyber Efforts in Israel The National Cyber Bureau was created to advance the capabilities outlined in Government Resolution No 3611 of 2011 The Bureau reports to the Prime Minister PM and provides guidance and policy coordination to the PM and across the government Resolution 3611 also established a national Computer Emergency Response Team CERT The Bureau is also charged with encouraging cooperation among academia industry and government entities to improve cyber defense of national critical infrastructures 31 Below are the four main functions of the Bureau 32 1 Defending against Cyber Threats Develop a national defense strategy and establish cross industry or industry-specific regulation develop a national cyber situation assessment and cyber threat reference 2 Promoting the Cyber Defense Industry Establish Cyber R D programs and encourage international companies to invest in Israel 3 Developing Academia and Human Capital In Israel the civilian cybersecurity presence extends from a number of private companies to education and training that encourages young people to pursue work in cybersecurity This builds upon a national culture that is focused on security and a nearly universal recognition that cyber threats are both imminent and a high priority HM Government “Office of Cyber Security and Information Assurance ” HM Government Information Commissioner’s Office “Overview of the General Data Protection Regulation ” 30 European Commission “Digital Single Market ” 31 Israeli Prime Minister’s Office “Mission of the Bureau ” 32 Israeli Government Resolution No 3611 of the Government of August 7 2011 28 29 NIAC Pre-Decisional 34 4 International Cooperation Develop relationships with state partners with similar cyber goals – promote information sharing R D etc In 2015 Resolution 2444 was approved which established a National Cyber Defense Authority allowing the National Cyber Bureau to focus on strategy whereas the Authority would focus on operational objectives to improving cyber protection 33 • The purpose of the Authority is to “direct operate and execute as needed all defensive and operational efforts at the national level in cyberspace based on a systemic approach to allow a full and constant defensive response to cyber attacks including the handling of cyberspace threats and cyber events in real time formulation of a current situation assessment gathering and research of intelligence and work with the special institutions ” 34 Challenges One of the major criticisms of these recent organizational changes is that the roles and responsibilities of the resulting organizations have not been clear 35 These criticisms have primarily come from heads of other Israeli security agencies but are also highlighted in a report from the Knesset’s Israel’s version of Congress Foreign Affairs and Defense Committee 36 Since the National Cyber Authority is subordinate to the National Cyber Bureau there are concerns this structure could hamper the Authority’s work with improving cyber security for civilian groups Other conclusions cited in the report are that the Authority should avoid becoming yet another intelligence gathering agency any regulations put forth by the Authority must take into account and involve all relevant defense and civilian parties and that the structure of cyber leadership should be reexamined periodically over the next five years 37 Chachko Elena “Cyber Reform in Israel at an Impasse A Primer ” 2017 Even Shmuel “Structuring Israel’s Cyber Defense ” 2016 35 Chachko Elena “Cyber Reform in Israel at an Impasse A Primer ” 2017 36 The Knesset “Foreign Affairs and Defense Committee” 2016 37 Even Shmuel “Structuring Israel’s Cyber Defense ” 2016 33 34 NIAC Pre-Decisional 35 Appendix E References Adamsky Dmitry “The Israeli Odyssey toward its National Cyber Security Strategy ” The Washington Quarterly 40 no 2 113-127 June 14 2017 https twq elliott gwu edu sites twq elliott gwu edu f iles downloads TWQ_Summer2017_Adamsky pdf Carberry Sean D “Fate of Trump cyber order still unclear ” FCW The Business of Federal Technology April 11 2017 https fcw com articles 2017 04 11 trump-cyberorder-murky aspx Alkhalisi Zahraa “Saudi Arabia warns of new crippling cyber attack ” CNN January 26 2017 http money cnn com 2017 01 25 technology saudiarabia-cyber attack-warning Center for Cyber Safety and Education Global Information Security Workforce Study 2017 https iamcybersafe org research_millennials Atlantic Council Overcome by cyber risks Economic benefits and costs of alternate cyber futures September 2015 http publications atlanticcouncil org cyberrisks Behr Peter and Blake Sobczak “White House-New cyber order draft keeps focus on critical grid companies ” E E News May 4 2017 https www eenews net energywire 2017 05 04 stor ies 1060054017 Bell Greg Tony Buffomante Ken Dunbar and Cliff Justice “Technology Al Adds a New Layer to Cyber Risk ” Harvard Business Review April 13 2017 https hbr org 2017 04 ai-adds-a-new-layer-to-cyberrisk Boyd Aaron “Civilian Cybersecurity Strategy coming this summer ” Federal Times July 14 2015 http www federaltimes com story government cybe rsecurity 2015 07 14 civilian-cybersecuritystrategy 30138103 Boyd Aaron “Initial meeting lays out how commission will enhance cybersecurity ” Federal Times April 15 2016 http www federaltimes com story government cybersecurity 2016 04 15 cybercommission-first-meeting 83080592 Brown Jared T Presidential Policy Directive 8 and the National Preparedness System Background and Issues for Congress Congressional Research Service October 21 2011 https fas org sgp crs homesec R42073 pdf Burley Diana L “Testimony Before the United States of Representatives Committee on Science Space Technology Subcommittee on Research and Technology Hearing on Strengthening U S Cybersecurity Capabilities ” February 14 2017 http docs house gov meetings SY SY15 20170214 1 05554 HHRG-115-SY15-Wstate-BurleyD-20170214 pdf Center for Strategic and International Studies CSIS “CSIS Cyber Policy Task Force ” Accessed January 13 2017 https www csis org programs technologypolicy-program cybersecurity csis-cyber-policy-taskforce Center for Strategic and International Studies CSIS From Awareness to Action A Cybersecurity Agenda for the 45th President Accessed July 18 2017 https csisprod s3 amazonaws com s3fs-public publication 170110_Lewis_CyberRecommendationsNextAdministr ation_Web pdf Center for Strategic and International Studies CSIS “Significant Cyber Incidents List ” Accessed July 18 2017 https csis-prod s3 amazonaws com s3fspublic 170519_Significant_Cyber_Events_List pdf HJ4 k1Bt7x zleLsdr9m6SQbkWHtuNJ39 Center for Strategic and International Studies CSIS Cyber Policy Task Force Testimony of Iain Mulholland Strengthening U S Cybersecurity Capabilities February 14 2017 http docs house gov meetings SY SY15 20170214 105554 HHRG-115-SY15-WstateMulhollandI-20170214 pdf Center for Strategic and International Studies CSIS Cybersecurity Commission A Human Capital Crisis in Cybersecurity Technical Proficiency Matters November 2010 https csis-prod s3 amazonaws com s3fs-public legacy_files files publication 101111_Evans_HumanCapital_Web pdf Center for Strategic and International Studies CSIS Cybersecurity Commission Cybersecurity Two Years Later 2011 https www csis org analysis cybersecurity-two-years-later Center for Strategic and International Studies CSIS Cybersecurity Commission Securing Cyberspace for the 44th Presidency 2008 https csis prod s3 amazonaws com s3fs-public legacy_files files media csis pubs 081208_securingcyberspace_44 pdf NIAC Pre-Decisional 36 Center for Strategic and International Studies CSIS Cybersecurity Commission Twenty Critical Controls for Effective Cyber Defense Consensus Audit Guidelines 2009 https csis-prod s3 amazonaws com s3fspublic legacy_files files publication Twenty_Critical_C ontrols_for_Effective_Cyber_Defense_CAG pdf Chachko Elena “Cyber Reform in Israel at an Impasse A Primer ” Lawfare April 27 2017 https www lawfareblog com cyber-reform-israelimpasse-primer Chappell Bill “We’re No 3 U S Infrastructure Education Faulted In Global Competitiveness Index ” NPR September 28 2016 http www npr org sections thetwoway 2016 09 28 495796271 were-no-3-u-sinfrastructure-education-faulted-in-globalcompetitiveness-index Columbus Louis “Roundup of Internet of Things Forecasts and Market Estimates ” Forbes November 27 2016 https www forbes com sites louiscolumbus 2016 11 27 roundup-of-internet-ofthings-forecasts-and-market-estimates2016 #6c7f7dc2292d Commission on Enhancing National Cybersecurity CENC “Briefing on Current Federal Initiatives for the Federal Governance Sub-Committee ” Washington D C August 3 2016 https www nist gov sites default files documents 2017 01 19 commission_pre paratory_working_group_meeting_august_3_2016_cle an_final pdf Commission on Enhancing National Cybersecurity CENC “Meeting Minutes ” American University Washington College of Law Washington D C September 19 2016 https www nist gov sites default files documents 2016 11 15 sept_19_2016_a mer_univ_meeting_minutes pdf Commission on Enhancing National Cybersecurity CENC “Meeting Minutes ” Conference Calls July 7 2016 – November 21 2016 Commission on Enhancing National Cybersecurity CENC “Meeting Minutes ” New York University School of Law-Vanderbilt Hall New York NY May 16 2016 https www nist gov sites default files may_16_2016_nyc_meeting_minutes pdf Commission on Enhancing National Cybersecurity CENC “Meeting Minutes ” University of Houston Houston TX July 14 2016 https www nist gov sites default files commission_on_enhancing_nationa l_cybersecurity_mn_09072016 pdf Commission on Enhancing National Cybersecurity CENC “Meeting Minutes ” University of Minnesota Minneapolis MN August 23 2016 https www nist gov sites default files documents 2 016 11 15 aug_23_2016_univ_minnesota_meeting_m inutes pdf Commission on Enhancing National Cybersecurity CENC “Meeting Minutes ” U S Department of Commerce-Commerce Research Library Washington D C April 14 2016 https www nist gov sites default files documents cybercommission Meeting_ Minutes_April_14 pdf Commission on Enhancing National Cybersecurity CENC “Panelist Statements ” New York University— School of Law New York NY May 16 2016 https www nist gov sites default files may_16_panelist_statements pdf Commission on Enhancing National Cybersecurity CENC “Panelist Statements ” University of California Berkeley Berkeley CA June 21 2016 https www nist gov sites default files documents 2 016 09 12 june21_panelist_statements pdf Commission on Enhancing National Cybersecurity CENC “Panelist and Speaker Statements ” University of Houston Houston TX July 14 2016 https www nist gov sites default files july14_paneli st_statements pdf Commission on Enhancing National Cybersecurity CENC “Panelist and Speaker Statements ” University of Minnesota Minneapolis MN August 23 2016 https www nist gov sites default files documents 2016 08 25 august23_panelist_statements pdf Commission on Enhancing National Cybersecurity CENC “Panelist and Speaker Statements ” American University Washington D C September 19 2016 https www nist gov sites default files documents 2016 09 23 dc_commission_panelist_and _speaker_statements pdf Commission on Enhancing National Cybersecurity CENC “Meeting Minutes ” University of California Berkeley Berkeley CA June 21 2016 https www nist gov sites default files june_21_2016_ucb_meeting_minutes pdf NIAC Pre-Decisional 37 Commission on Enhancing National Cybersecurity CENC 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before the U S Senate Committee on Energy and Natural Resources Subcommittee on Energy hearing to Examine Cybersecurity Threats to the U S Electrical Grid and Technology Advancements to Minimize the Threat ” March 28 2017 https www energy senate gov public index cfm files serve File_id 40A50EA7-75FA4CEB-9A5A-3FE9074F4B77 Franzetti Andres “In the Lame Duck How Congress Makes Cybersecurity A Non-Partisan Priority ” Forbes November 14 2016 http www forbes com sites realspin 2016 11 14 inthe-lame-duck-how-congress-makes-cybersecurity-anon-partisan-priority #5920c93b3654 Friedman Sam and Adam Thomas “Demystifying cyber insurance coverage ” Deloitte University Press February 23 2017 https dupress deloitte com dupus-en industry financial-services demystifyingcybersecurity-insurance html Gambrell Jon “Saudi Arabia warns destructive computer virus has returned Updated ” Phys Org News January 24 2017 https phys org news 201701-saudi-arabia-destructive-virus html Gerstell Glenn “Confronting the 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Control Systems Cyber Emergency Response Team ICS-CERT “About the Industrial Control Systems Cyber Emergency Response Team ” Accessed July 24 2017 https ics-cert us-cert gov AboutIndustrial-Control-Systems-Cyber-EmergencyResponse-Team NIAC Pre-Decisional 39 Industrial Control Systems Cyber Emergency Response Team ICS-CERT ICS-CERT Annual Assessment Report FY 2016 Accessed July 19 2017 https ics-cert uscert gov sites default files Annual_Reports FY2016_Industrial_Control_Systems_Assessment_Sum mary_Report_S508C pdf Clinton Larry and David Perera eds The Cybersecurity Social Contract Implementing a Market-Based Model for Cybersecurity Internet Security Alliance September 2016 Israeli Government Resolution No 3611 of the Government of August 7 2011 Advancing National Cyberspace Capabilities Accessed July 17 2017 http www pmo gov il English PrimeMinistersOffice DivisionsAndAuthorities cyber Documents Advancing %20National%20Cyberspace%20Capabilities pdf Israeli Prime Minister’s Office 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