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	<title>Chakraborty Software &#187; Privacy &amp; Security Law</title>
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	<description>Information Security Consulting Services</description>
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		<title>Evaluating Bespoke Trading Applications</title>
		<link>http://www.chakraborty.ch/management/evaluating-bespoke-trading-applications/</link>
		<comments>http://www.chakraborty.ch/management/evaluating-bespoke-trading-applications/#comments</comments>
		<pubDate>Wed, 28 Jul 2010 11:17:22 +0000</pubDate>
		<dc:creator>john</dc:creator>
				<category><![CDATA[Forensics]]></category>
		<category><![CDATA[Management]]></category>
		<category><![CDATA[Politics]]></category>
		<category><![CDATA[Privacy & Security Law]]></category>

		<guid isPermaLink="false">http://www.chakraborty.ch/?p=179</guid>
		<description><![CDATA[A planned Black Hat talk on High-Frequency Trading (HFT) vulnerabilities was recently pulled from the 2010 Black Hat conference, ostensibly at the request of one of the authors' clients who probably felt that the planned disclosures hit a little close to home.]]></description>
			<content:encoded><![CDATA[<p>A planned <a href="http://blogs.forbes.com/firewall/2010/07/26/talk-on-high-speed-trading-hacks-pulled-from-security-conference/" target="_blank">Black Hat talk on High-Frequency Trading</a> (HFT) vulnerabilities was recently pulled from the <a href="http://www.blackhat.com/" target="_blank">2010 Black Hat conference</a>, ostensibly at the request of one of the authors&#8217; clients who probably felt that the planned disclosures hit a little close to home.</p>
<p><a href="http://en.wikipedia.org/wiki/High-frequency_trading" target="_blank">HFT</a> is a hot topic in circles ranging from regulatory and compliance discussion forums, over smaller traders, to conspiracy wingnuts.  Despite the fact that it&#8217;s just one technological tool among many to give exchange participants an edge over competitors, I tend to side with the conspiracy theorists, especially insofar as it&#8217;s an approach to transactions that by its very definition gives an edge to larger market actors &#8212; thus skewing the idea of a &#8220;fair market&#8221;.  Various individuals have claimed that this goes so far as to allow participants to manipulate prices using fake orders, but I don&#8217;t know enough about trading technology to comment on this.</p>
<p>Due to the very technologically intricate and detailed nature of HFT platforms, very few people understand how they work &#8212; and overtaxed regulators and security &amp; compliance organizations thus are left in the dust when it comes to ensuring that such solutions do not present a security and operational risk, not just to the companies who run them, but to overall market stability.  Remember, complexity is almost always bad if you can&#8217;t reliably understand it with a reasonable grasp of the subject matter.</p>
<p>The article has one particular paragraph that rings very true:</p>
<p style="padding-left: 30px;"><em>While applications are combed for typical application vulnerabilities like SQL injection or cross-site scripting, they&#8217;re not examined for operational vulnerabilities: A rogue trader could, for instance, change a single variable to allow far more risky trades than a bank or its clients intend&#8211;the sort of trick that Société Générale trader Jerome Kerviel may have used to make unauthorized trades in 2008 that cost the firm $7 billion.</em></p>
<p>Yeah, basically.  Many of the people who use these toys are very bright autodidacts, creating customer tools for exotic, structured products.  Even off-the-shelf software is frequently written using what I like to call &#8220;functional programming&#8221; &#8212; i.e. a very smart person with a Visual Basic book coding a solution to an operational requirement without paying attention to best practices that may, in any case, be outside of the scope they care about.  Investment firm management is likely to turn a blind eye to even obvious flaws in such software, due to the fact that traders (a) bring in massive amounts of revenue and (b) are increasingly the only people who understand certain market types.</p>
<p>The rise in black pools and other off-exchange trading will only increase the latter phenomenon; I&#8217;ve seen trading floors where it was pretty common for one person to be responsible for a particular exotic product; frequently, this person might even have been the one who helped create the actual market.  Remember, you can trade pretty much anything, as long as you have a willing counterparty&#8230;</p>
<p>How do you deal with such issues as a security professional?  To many who are not trained in the black arts of financial transactions, much technological innovation in modern markets is the driving force behind an increased complexity that regulators cannot hope to oversee effectively.  Analyzing security issues in such tools also becomes difficult, even from the inside, even when a company is willing to implement controls &#8212; the line between legitimate exploitation of a weaker player&#8217;s market position and an actual security intrusion blurs to the point where traditional technical vulnerability analysis is no longer an option.</p>
<p>I don&#8217;t have a solution, beyond an innate distrust of anything I don&#8217;t understand in detail, but I believe that companies&#8217; willingness to reduce their exposure to security issues stemming from overly complex trading software is  more a philosophical than a policy or technical question &#8212; how far are we willing to go to exploit loopholes in the spirit of market regulation?  Are we willing to sacrifice potential high risk + high profit combinations in order to remain in more staid trading areas?</p>
<p>And most importantly, if management won&#8217;t listen, as a security guy, can you sufficiently CYA to avoid being caught up in a potential technical or regulatory failure of one of your employer&#8217;s systems that&#8217;s just too intricate to reliably review for risk?</p>
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		<title>Shenanigans For Good</title>
		<link>http://www.chakraborty.ch/exploits/shenanigans-for-good/</link>
		<comments>http://www.chakraborty.ch/exploits/shenanigans-for-good/#comments</comments>
		<pubDate>Sun, 21 Feb 2010 22:33:53 +0000</pubDate>
		<dc:creator>john</dc:creator>
				<category><![CDATA[Exploits]]></category>
		<category><![CDATA[Politics]]></category>
		<category><![CDATA[Privacy & Security Law]]></category>

		<guid isPermaLink="false">http://www.chakraborty.ch/?p=166</guid>
		<description><![CDATA[A colleague of mine recently posted a link to an information warfare-related article on an Iranian activism site.  Like-minded Iranian friends, affiliated with the Green movement, seemed to have as a goal to disseminate information about how to counter censorship in Iran by distributing tools, news, and other means of helping dissidents avoid having their communication muzzled and detected by the mullahs.]]></description>
			<content:encoded><![CDATA[<p>A colleague of mine recently posted a link to an information warfare-related article on an <a href="http://en.irangreenvoice.com/article/2010/feb/19/1236" target="_blank">Iranian activism site</a>.  Like-minded Iranian friends, affiliated with the <a href="http://en.wikipedia.org/wiki/Green_Movement" target="_blank">Green movement</a>, seemed to have as a goal to disseminate information about how to counter censorship in Iran by distributing tools, news, and other means of helping dissidents avoid having their communication muzzled and detected by the mullahs.</p>
<p>This particular article lists examples of electronic warfare by regime-friendly groups such as the &#8220;Iranian Cyber Army&#8221;, recently suspected of numerous attacks against organizations seen as hostile to the Iranian government.  Ironically, <a href="http://news.bbc.co.uk/2/hi/8453718.stm" target="_blank">these included Chinese search engine baidu.com</a> in retaliation for some perceived slight by the Chinese government &#8212; this shortly after several Chinese organizations have become increasingly implicated in online hits against U.S. and other Western government and corporate targets; a recent report in The Associated Press / The Guardian <a href="http://www.guardian.co.uk/world/feedarticle/8954390" target="_blank">mention</a> the Chinese universities Shanghai Jiaotong and Lanxiang Vocational Institute as sources of the &#8220;<a href="http://siblog.mcafee.com/cto/operation-%E2%80%9Caurora%E2%80%9D-hit-google-others/" target="_blank">Aurora</a>&#8221; attacks against Google and others.  On a humorous side note, if 1337 xenophobic script kiddies friendly with one totalitarian regime are now going after 1337 xenophobic script kiddies friendly with another totalitarian regime, it might become difficult to figure out who&#8217;s on whose side&#8230;</p>
<p>That said, there&#8217;s not much an outsider with technological know-how can do to help victims of censorship and repression in any country beyond providing them with the education and means to get around official repression of communication with each other and with the outside world, and to avoid being detected by government thugs while doing so.  A friend of mine, when asked to to provide help and information about censorship avoidance to an Iranian group, took a very cautious line, making it very very clear that he was reluctant to offer anything that carried even the slightest possibility of someone being arrested, tortured, or even killed if they were found using it.  I take a bit of a different view &#8212; solutions like PGP, TOR, Haystack, anonymous remailers, or SSL enabled CGI proxies, combined with private browsing available on most newer browsers, are powerful stuff, and with a modicum of care on the part of their users, can conspire to throw a hefty wrench into the surveillance machinations of dictatorial spooks.  The best anyone can do is to make users at risk of brutal crackdowns aware of what could possibly go wrong, give them a good head-start on how to use their new toys, and let them be adults about making an educated choice.  After all, in the case of the Iranian protesters, these are people who&#8217;re willing to go out on the street and be shot at for what they believe in.</p>
<p>So much for &#8220;passive&#8221; assistance &#8212; giving people better anonymous / encrypted communications tools and the knowledge on how to effectively use them.  What about active help, though?  Beyond the usual low-level stupidity found in IRC channels (e.g. background noise of the &#8220;www.bobsautodetailing.com pwn3d by H4X0RZ 4 ALLAH AGAINST 4m3r1kkkAH&#8221; variety), attacks on the infrastructure of Western countries and organizations from Russian, Iranian, North Korean, Chinese, and other groups, presumably with at least some tacit blessing from their governments, are pretty common.  Botnets designed to carry out probes and hits on infrastructure, launch DDoS attacks, create economic sabotage, steal sensitive data, and other bad things, are pretty common in the wild.</p>
<p>Cybercrime legislation in most developed countries is designed to pursue and allow prosecution of even casual probes by unauthorized persons.  Whether one agrees with laws or enforcement tactics or not, the goal is to keep anyone, no matter what motivates them, from generally screwing things up by spying, stealing, or vandalizing.  Unless it specifically takes into account <em>intent</em>, the law doesn&#8217;t differentiate between amateurs or professionals &#8212; it&#8217;s all a crime.  Why?   Partially because attacking a person/host/company/government via a network is the technologically easiest, least physically risky way of getting to the goodies, and because it&#8217;s often impossible to differentiate between the casual hacker and the much-vaunted bugaboo of organized cybercriminals and government-sponsored electronic espionage.  The idea, I suppose, is that tolerating any intrusion means that the world economic system as we know it will grind to a standstill (or at least your job and mine will be made that much more difficult.)  Maybe, maybe not, but without such laws as a deterrent, I&#8217;m sure the barriers to causing grief to legitimate business would be a lot lower.</p>
<p>But what of aiding and abetting attacks against distasteful regimes or their allies / henchmen?  A few years ago, the idea of <a href="http://www.google.com/search?name=f&amp;hl=en&amp;q=counter-hacking" target="_blank">counter-hacking</a>, or ethical hacking aimed at taking out threats either by sabotaging those responsible or by &#8220;cleaning&#8221; affected infrastructures when unsuspecting owners could not or would not, was in high discussion.  Most security professionals in my circle of acquaintances seemed to be roundly against this concept, due to the potential for a slippery slope, and for unacceptable collateral damage &#8212; plus, what good is it to have and enforce laws against illicit intrusion when the &#8220;good guys&#8221; themselves are guilty of violating them, even if they are perfectly well-meaning?</p>
<p>Given how hungry my non-technical Iranian friends were for any information about &#8220;passive&#8221; tools as those described above, I&#8217;d imagine groups in opposition to the government (supposedly there&#8217;s now a &#8220;<a href="http://www.jpost.com/International/Article.aspx?id=167963" target="_blank">Green Cyber Army</a>&#8220;) would imaginably be equally happy for any assistance from sympathetic types in the West.  As someone strictly in favor of the rule of law, I can&#8217;t condone any illegal actions of the sort these guys are indubitably carrying out, but anything that helps cause grief for kiddies hacking in the service of thugs is ok in my book.  A few dozen clicks to waste here and there to waste the bad guys&#8217; bandwidth, a Metasploit download mirror, or an open proxy or TOR gateway probably wouldn&#8217;t violate the spirit of the law.  Wink wink.</p>
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		<title>Data Protection Goes South</title>
		<link>http://www.chakraborty.ch/privacy/chilean-data-protection/</link>
		<comments>http://www.chakraborty.ch/privacy/chilean-data-protection/#comments</comments>
		<pubDate>Sat, 11 Nov 2006 01:06:57 +0000</pubDate>
		<dc:creator>john</dc:creator>
				<category><![CDATA[Identity Theft]]></category>
		<category><![CDATA[Privacy]]></category>
		<category><![CDATA[Privacy & Security Law]]></category>

		<guid isPermaLink="false">http://www.chakraborty.ch/blog/?p=18</guid>
		<description><![CDATA[Before arriving in Chile, where I&#8217;m spending a year with my girlfriend, I did a bit of research on the information security and compliance landscape in South America. I came up with a single short law in Chile governing the security and integrity of information&#8211;&#8221;Ley 19628&#8243;, dating back to 1999. Ut-oh. On 28 August 1999, <a href='http://www.chakraborty.ch/privacy/chilean-data-protection/'>[...]</a>]]></description>
			<content:encoded><![CDATA[<p><img alt="cedula-small.JPG" id="image17" src="http://www.chakraborty.ch/wp-content/uploads/2006/11/cedula-small.thumbnail.JPG" /> Before arriving in Chile, where I&#8217;m spending a year with my girlfriend, I did a bit of research on the information security and compliance landscape in South America.  I came up with a single short law in Chile governing the security and integrity of information&#8211;&#8221;Ley 19628&#8243;, dating back to 1999.   Ut-oh.</p>
<blockquote><p><em>On 28 August 1999, Chile adopted privacy protective legislation. Law 19628 provides a set of detailed guidelines, principles and rules relating to the gathering, use, processing, storage and export of personal data. To be legal, all the above acts require the person’s written consent. The law does not create a data protection authority. Its application is monitored by ordinary courts. Personal data registrars are bound to respect professional secrecy rules. Data subjects are entitled to access and correct the data relating to them and to claim compensation where loss or damage is suffered as a result of the use or disclosure of such data. Infringement of the legislation entails administrative, civil and penal liability. Special provisions apply on financial, commercial, banking and medical data. </em></p></blockquote>
<p>Gotta love the absence of a data protection officer.  The law also does not specify penalties like the UK Data Protection Act or Swiss law.  To be fair, I think the Argentines also only have something basic on the books.</p>
<p>Why is this fun?  Well, like everyone here, we are in possession of a &#8220;cedula de etrangeros&#8221;, or a &#8220;papers pliss&#8221; kind of mandatory national ID card.  The &#8220;RUT&#8221;, which I can only assume was originally some sort of pension information, serves as a universal identifying number.  All government agencies are tied into the database containing these &#8212; companies also have these, as well as some contracts.  It&#8217;s used it for taxes, pensions, passoprts, etc. etc. etc.</p>
<p>(Yes, that is a Cedula above; the smudged bit is my RUT, and I&#8217;m not going to put you through the agony of my ugly mug more than once on this page.)  So, what&#8217;s the deal?</p>
<p>The RUT isn&#8217;t just used by the government, but by your bank, insurance and other organizations as an ID.  Sounds good, except that it&#8217;s also your supermarket loyalty ID, your video club membership number, and your identifier for anything you can possibly imagine&#8211;it&#8217;s given openly over the phone, the Internet (often via unencrypted authentication elements even in SSL-protected pages), to the pizza delivery guy, you get the idea.  As it turns out, everyone who asks for your RUT (i.e. everone) has full access to the RUT database (or whatever it&#8217;s called).</p>
<p>Bills of participating enterprises are payable online via two websites, one of which, when I logged in (using my RUT as user ID, with a 6-digit numeric password, no more are possible, and it only works under IE, let me check out my entire phone history for the month.  What&#8217;s interesting is that at first I typed in the wrong phone number &#8212; and got someone else&#8217;s entire call history, along with their name, address and, you guessed it, RUT.</p>
<p>At risk of sounding like I&#8217;m scoffing &#8212; I&#8217;m not, just incredulous &#8212; this is in an environment where I&#8217;m asked to put two pen dashes across the face of a signed check &#8220;for security&#8221; because, as we all know, once you&#8217;ve written over a check, it can&#8217;t be forged.  When confronted with the incongruity of this, at least two people I spoke with responded with some variation on &#8220;but this is South America / Chile.&#8221;  It could never happen here.</p>
<p>In absence of enough time to put together a properly thought-through post, I&#8217;ll leave it to you, dear reader, to come up with your own conclusions as to the potential for identity theft once someone cottons onto the fact that English (and extremely poor Dutch and German) aren&#8217;t the only language in which a lot of gullible, not-terribly-technical people do business online.</p>
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