According to the Pareto Principle, for many phenomena, 80 percent of the consequences stem from 20 percent of the causes. Application of the principle to fraud prevention efforts related particularly to automated systems seems increasingly apropos given the deluge of intrusions, data thefts, worms and other attacks which continue unabated, with organizations of all kinds losing productivity, revenue and more customers every month. ACFE members report having asked the IT managers of numerous victimized organizations over the years what measures their organization took prior to an experienced fraud to secure their networks, systems, applications and data, and the answer has typically involved a combination of traditional perimeter protection solutions (such as firewalls, intrusion detection, antivirus and antispyware) together with patch management, business continuance strategies, and access control methods and policies. As much sense as these traditional steps make at first glance, they clearly aren’t proving sufficiently effective in preventing or even containing many of today’s most sophisticated attacks.
The ACFE has determined that not only are some organizations vastly better than the rest of their industries at preventing and responding to cyber-attacks, but also that the difference between these and other organizations’ effectiveness boils down to just a few foundational controls. And the most significant within these foundational controls are not rooted in standard forms of access control, but, surprisingly, in monitoring and managing change. It turns out that for the best performing organizations there are six important control categories – access, change, resolution, configuration, version release and service levels. There are performance measures involving each of the categories defining audit, operations and security performance measures. These include security effectiveness, audit compliance disruption levels, IT user satisfaction and unplanned work. By analyzing relationships between control objectives and corresponding performance indicators, numerous researchers have been able to differentiate which controls are actually most effective for consistently predictable service delivery, as well as for preventing and responding to security incidents and fraud related exploits.
Of the twenty-one most important foundational controls used by the most effective organizations at controlling intrusions, there were two used by virtually all of them. Both of these controls revolve around change management:
• Are systems monitored for unauthorized changes in real time?
• Are there defined consequences for intentional unauthorized changes?
These controls are supplemented by 1) a formal process for IT configuration management; 2) an automated process for configuration management; 3) a process to track change success rates (the percentage of changes that succeed without causing an incident, service outage or impairment); 4) a process that provides relevant personnel with correct and accurate information on all current IT infrastructure configurations. Researchers found that these top six controls help organizations help manage risks and respond to security incidents by giving them the means to look forward, averting the riskiest changes before they happen, and to look backward, identifying definitively the source of outages, fraud associated abnormalities or service issues. Because they have a process that tracks and records all changes to their infrastructure and their associated success rates, the most effective organizations have a more informed understanding of their production environments and can rule out change as a cause very early in the incident response process. This means they can easily find the changes that caused the abnormal incident and remediate them quickly.
The organizations that are most successful in preventing and responding to fraud related security incidents are those that have mastered change management, thereby documenting and knowing the ‘normal’ state of their systems in the greatest possible detail. The organization must cultivate a ‘culture’ of change management and causality throughout, with zero tolerance for any unauthorized changes. As with any organizational culture, the culture of change management should start at the top, with leaders establishing a tone that all change must follow an explicit change management policy and process from the highest to the lowest levels of the organization, with zero tolerance for unauthorized change. These same executives should establish concrete, well-publicized consequences for violating change management procedures, with a clear, written change management policy. One of the components of an effective change management policy is the establishment of a governing body, such as a change advisory board that reviews and evaluates all changes for risk before approving them. This board reinforces the written policy, requiring mandatory testing tor each and every change, and an explicit rollback plan for each in the case of an unexpected result.
ACFE studies stress that post incident reviews are also crucial, so that the organization protects itself from repeating past mistakes. During these reviews, change owners should document their findings and work to integrate lessons learned into future anti-fraud operational practices.
Perhaps most important for responding to changes is having clear visibility into all change activities, not just those that are authorized. Automated controls that can maintain a change history reduce the risk of human error in managing and controlling the overall process.
So organizations that focus solely on access and reactive resolution controls at the expense of real time change management process controls are almost guaranteed to experience in today’s environment more security incidents, more damage from security incidents, and dramatically longer and less-effective resolution times. On the other hand, organizations that foster a culture of disciplined change management and causality, with full support from senior management, and have zero tolerance for unauthorized change and abnormalities, will have a superior security posture with fewer incidents, dramatically less damage to the business from security breaches and much faster incident identification and resolution of incidents when they happen.
In conducting a cyber-fraud post-mortem, CFE’s and other assurance professionals should not fail to focus on strengthening controls related to reducing 1) the amount of overall time the IT department devotes to unplanned work; 2) a high volume of emergency system changes; 3) and the number and nature of a high volume of failed system changes. All these are red-flags for cyber fraud risk and indicative of a low level of real time system knowledge on the part of the client organization.