Avoiding Compliance Risk with Better Access Management

Networks have become large, complex entities that are increasingly difficult to manage and control. Security, audit, risk and compliance professionals know that their organizations rely on them for effective risk management, control and governance processes that are essential to the safety of their network environment. Yet compliance and security are more challenging than ever before as additional layers are added to this environment.

One of the challenges lies in the fact that there is an ongoing, huge access gap in network security and compliance - and it has been residing within the environment for more than 20 years. This tool, known as the Secure Shell (SSH) protocol, grants privileged access to all types of production environments.

A Problem Gaining Attention
The problem is propagated by a lack of awareness at the management level. Network, system and database administrators are aware of the SSH key access in terms of granting them access to do their jobs. Unfortunately, it's an elevated access that is not being managed and governed and has no management visibility. As organizations attest to compliance and indicate that they have effective access controls and can attest to authorized access at all times to production, they are totally missing the boat in terms of attesting to SSH keys access.

Consider how you grant critical application access to vendors and administrators; that privileged access going into production with SSH keys is not being controlled by any means of logging, auditing or review. The point of privileged access is to obtain approval to elevate your access to do a certain function, to audit and check your work, and then sever the session and review it after the fact. Unfortunately, those steps and the control of privileged access fail when you don't have true governance over SSH keys.

More professionals are becoming aware of this access gap, chiefly through practitioner guidance and industry events discussing the protocol and, unfortunately, by means of large security breaches (such as the SONY breach) stemming from poorly managed SSH key environments.

Material Weakness and Invisible Threats
Now that this huge risk regarding elevated, direct access to production that is not audited, logged, controlled or governed has come to light, what can organizations do? Auditors must take action to assess the risk, govern it, minimize it and take control over SSH keys. Failure to act is likely to have several negative consequences.

One of the consequences would be the spectacular failure of an audit. Not having control over 30 percent of your production access could be construed as material weakness to your environment, from a controls perspective. And if you talk about a financial institution that is publically traded, and they fall under the Sarbanes-Oxley umbrella, this is a huge problem. From a SOX perspective, when a CFO or CEO signs off on attestations, they are saying they have complete visibility and control over access. However, the reality is that they have no visibility or control over their production due to poor or non-existent SSH key management.

Another consequence of poorly managed SSH key environments is that it creates an open door for threats that you don't even have visibility into. For instance, a malicious insider could be leveraging uncontrolled, unaudited privileged access that is not monitored or logged and you wouldn't be able to tell. By the same token, if you are being breached by an attacker who is leveraging back doors or exploits in this environment, the same thing would happen. You would have no visibility into the data that is being compromised or potentially compromised, and by law you must notify and report accordingly. So, what would your reported evidence look like?

Best Practices
To ensure SSH access is authorized and that the access falls within governance guidelines, organizations must adopt best practices, leverage automation, establish ongoing monitoring and auditing, and govern all access equally.

Because this situation warrants immediate attention and action, ISACA has recently released a new guidance document, SSH: Practitioner Considerations. In collaboration with industry experts, practitioners and ISACA subject matter experts, the white paper provides an excellent overview of what SSH is, its background, assurance considerations and practitioner impacts and suggested controls.

The document offers the following best practices to manage SSH keys and mitigate risk:

• Ownership and accountability:Define roles and responsibilities so that everyone knows who owns SSH key management.
• Usage procedures: Institute recurring access reviews, document and disseminate security policies and standards, and implement required IT controls.
• Configuration management: Set up and deploy hardening configuration, and periodically review the configuration. Consider automated tools to manage the configuration and apply integrity control checks and monitoring over critical files.
• Provisioning: Take an inventory of keys and usage tracking as part of the overall provisioning of users and accounts.
• Automation and standardization: Automation is critical for the success of SSH key deployments. Standardization is required, and access restrictions are key.

Toward Greater Compliance
ISACA warns that organizations are at risk of incomplete attestation regarding access compliance if they do not take SSH keys into account. The organizations goes on to say that SSH key environments that are poorly managed can result in not only audit infractions but data breaches as well. Use the best practices recommended above to remove these unnecessary risks by taking control of your SSH key management.