cybersecurity – Waterfall Security Solutions https://waterfall-security.com Unbreachable OT security, unlimited OT connectivity Thu, 07 May 2026 12:20:30 +0000 en-US hourly 1 https://wordpress.org/?v=6.9.4 https://waterfall-security.com/wp-content/uploads/2023/09/cropped-favicon2-2-32x32.png cybersecurity – Waterfall Security Solutions https://waterfall-security.com 32 32 Webinar: Everything You Know About OT Security Is Wrong https://waterfall-security.com/ot-insights-center/ot-cybersecurity-insights-center/webinar-everything-you-know-about-ot-security-is-wrong/ Tue, 05 May 2026 11:42:52 +0000 https://waterfall-security.com/?p=39442 Discover why common OT security assumptions are wrong

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Webinar: Everything You Know About OT Security Is Wrong

Misconceptions about OT security run deep and some of them sound reasonable until you test them against how industrial environments actually work.

Why Common OT Security Assumptions Are Wrong

Wed. May 27 @ 11am New York 

Does this sound familiar?

“Air gaps give a false sense of security.”

“Information is the asset – protect the CIA, or AIC, or IAC of the information.”

“If only we could patch, encrypt, AV, and IAM our OT systems just like we do our IT systems, then OT would be secure.”

“The real OT problem is all that brown-field equipment.”

“We have no budget for OT security.”

“IT and OT teams just don’t get along.”

“The first things we need are visibility and an asset inventory.

And so on…

Common wisdom in OT security is uncommonly mistaken. What’s really going on? Shoe factories are very different from passenger rail switching. Dramatically different worst-case consequences drive important differences between IT and OT security.

IT protection is preoccupied with espionage, while sabotage is the bigger threat in OT. Intrusion detection takes time, depends on human judgment, and by the time a human responds, the physical damage in an OT environment may already done.

Encryption and patching add complexity, uncertainty and cost enormously more in OT than they do in IT.

In this webinar we look at widespread misconceptions about OT security, at their root causes, and at more sensible approaches for teams making architecture and investment decisions today.

Webinar Key Takeaways:

• Why common OT security assumptions break down in practice
• How to present OT security to drive better results across your teams
• How consequence changes the way OT threats should be assessed
• Where IT security approaches fall short in industrial environments
• More defensible approaches to OT security decisions and designs

Who Should Attend?

• OT/ICS engineers
• IT security teams taking on OT security
• CISOs with critical infrastructure assets in their portfolio
• Plant managers evaluating security and investment

About the Speaker

Picture of Andrew Ginter

Andrew Ginter

Andrew Ginter is the most widely-read author in the industrial security space, with over 35,000 copies of his three books in print. He is a trusted advisor to the world's most secure industrial enterprises, and contributes regularly to industrial cybersecurity standards and guidance.

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Webinar: 13 Ways To Break “Secure” OT Remote Access Systems https://waterfall-security.com/ot-insights-center/ot-cybersecurity-insights-center/webinar-13-ways-to-break-secure-ot-remote-access-systems/ Sun, 29 Mar 2026 10:58:06 +0000 https://waterfall-security.com/?p=39061 Explore 13 ways attackers can break OT remote access systems, show which SRAs are most vulnerable and which are most deserving of the “secure” title

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Webinar: 13 Ways To Break “Secure” OT Remote Access Systems

and the questions you should be asking your OT SRA vendor...

 

AVAILABLE NOW – STREAM THE RECORDING

How much security do “secure” remote access solutions really provide? We’re laying all the cards on the table.

In this webinar, we’ll explore 13 ways attackers can break OT remote access systems, show which SRAs are most vulnerable & which are most deserving of the “secure” title.

We’ll finish with the questions you should be asking vendors to understand how exposed their solutions are.

13 Ways to break secure OT reote access systems

Understanding attacks is essential to designing robust defenses. One way to compare the strength of competing OT SRA solutions is to compare the attacks those solutions defeat reliably, vs the attacks they do not defeat. 

In this webinar, we cover a lucky 13 ways to break “secure” remote access systems, and look at which kinds of systems are vulnerable to each kind of attack.

We finish with questions to ask “secure” OT remote access vendors to understand how exposed their solutions are to these kinds of attacks. 

In this session we cover VPNs, jump hosts and DMZ’s, and we look at the more modern cloud / broker / rendezvous architectures, as well as more deterministic, hardware-enforced solutions. 

The 13 Attacks We’ll Be Covering: 

1) Shoulder surfing attacks – how attackers capture credentials without hacking

2) Social engineering users – exploiting human behavior to gain access

3) Password guessing & brute-force attacks – why weak credentials still succeed

4) Help desk social engineering – bypassing security through support teams

5) Rogue OT remote access (SRA) – unauthorized remote connections into OT networks

6) Exploiting outdated encryption – breaking legacy crypto protocols still supported

7) Malware passing through VPNs – how threats propagate inside trusted remote connections

8) Malware hiding in file transfer & clipboards – hidden risks in everyday remote workflows

9) Session hijacking & stealing logged-in cell phones – taking over active authenticated sessions

10) Exploiting known vulnerabilities – patching gaps and N-days lead to breaches

11) Stealing cookies to hijack browser sessions – compromising web-based remote access and password vaults

12) Zero-day exploitation in OT remote access – how unknown vulnerabilities are weaponized

13) Bypassing remote access entirely – when attackers go straight through the firewall

Access our deep dive into modern attack vectors and discover the critical questions you should be asking your OT 'Secure' Remote Access vendors.

About the Speaker

Picture of Andrew Ginter

Andrew Ginter

Andrew Ginter is the most widely-read author in the industrial security space, with over 35,000 copies of his three books in print. He is a trusted advisor to the world's most secure industrial enterprises, and contributes regularly to industrial cybersecurity standards and guidance.

Register Now

Share

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Ships Re-Routed, Ships Run Aground https://waterfall-security.com/ot-insights-center/ot-cybersecurity-insights-center/ships-re-routed-ships-run-aground/ Tue, 06 Jan 2026 09:38:29 +0000 https://waterfall-security.com/?p=38185 “Everyone” has heard of the 5-week shutdown of Jaguar Land Rover by a cyber attack. That attack is the obvious headline for Waterfall's up-coming webinar “Top 10 OT Cyber Attacks of 2025” that I'm currently researching.

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Ships Re-Routed, Ships Run Aground

Picture of Andrew Ginter

Andrew Ginter

Ships Re-Routed, Ships Run Aground

“Everyone” has heard of the 5-week shutdown of Jaguar Land Rover by a cyber attack. That attack is the obvious headline for Waterfall’s up-coming webinar “Top 10 OT Cyber Attacks of 2025” that I’m currently researching. But – is this attack the most interesting of 2025?

Here are a couple other incidents for consideration:

While details of the investigations into these events have not been published, on the surface the three incidents seem evidence of the importance of evaluating residual risk when we design automation and cybersecurity systems.

GPS Spoofing

A bit of background first: GPS Spoofing (as opposed to simpler GPS jamming) is when false geolocation signals are transmitted, either directionally to affect a specific target, or broadcast in a region to affect indiscriminately all nearby receivers. GPS satellite signals are comparatively weak, and it does not take a very powerful transmitter to overwhelm legitimate signals. GPS spoofing has become fairly common in kinetic conflict areas such as the Middle East (the Red Sea in particular), the North/South Korean border, the Black Sea and Baltic Sea, Northern Europe, and anywhere near Ukraine and western Russia. All of which means that anyone who cares about where they are in these and other regions really cannot rely exclusively on GPS.

Rerouting Tankers

The original report of the teenager’s hack of ship routes included graphics with the appearance of an Electronic Chart Display and Information System (ECDIS), which is a shipboard system that regulators allow as a substitute for paper charts. ECDIS display the position and heading of vessels automatically, pulling information from the ship’s GPS, other location systems, as well as Automatic Identification System (AIS) broadcasts from nearby ships detailing those ships’ location, speed, heading and other navigational data. Some (all?) these ECDIS can also steer ships by auto-pilot, once a route is entered. While the news report’s ECDIS-looking graphic was entitled “Maritime traffic in the Mediterranean” and subsequent reports claimed the teenager in fact hacked into one or more ECDIS, these reports may not be accurate. It seems more plausible, to me at least, that the individual hacked into a shore-side system that managed route planning for multiple ships, rather than hacked into multiple ships at sea and modified their shipboard systems to bring about the diversions.

Assessing Residual Risks & Consequences

Managing cyber risk to physical operations involves more than blindly deploying a bunch of OT security controls, dusting our hands off, and walking away. It’s easy to say “Hah! They should have had two factor!” or some such, but 2FA isn’t going to help with GPS spoofing is it?

Once we’ve deployed an automation or security system, we need to evaluate residual risk – what’s left over? The right way to do this is not just to produce a list of missing patches in our PLC’s. The right way is to look at a representative spectrum of credible attacks – attacks that are reasonable to believe may be leveled against us, the system, or someone much like us or the system, within our planning horizon. Evaluate these credible attacks against our defensive posture and determine what are credible consequences – what consequences are reasonable to expect when a credible attack hits us? And when those consequences are unacceptable (eg: ship runs aground, oil tanker is diverted into environmentally sensitive waters), we need to change something.

For example, given the prevalence of GPS spoofing in many regions, and the prevalence of GPS jammers in many more, it seems reasonable to me that anyone (operating a ship, an aircraft, or a locomotive) who needs to know their precise position or even the precise time needs multiple, independent sources of that information. And we need alarms to sound when those independent sources disagree materially, and we need manual or other fall-back procedures when we detect such disagreement.

Another example – given the importance of a big vessel’s route, it seems reasonable that when the route changes for any reason, the captain should be notified of the change, and the change logged in an indelible / WORM ship’s log. It also seems reasonable that captains or acting captains are trained to examine unexpected route changes to make sure they make sense – not just because of potential attacks, but because of potential errors and omissions of shipboard or on-shore personnel. Note: I’m not an expert on shipboard systems – for all I know all this happens already and is how the teenager’s hack was detected? One can hope.

Reasonable Responses to Credible Threats

When we make decisions about other people’s safety, we have ethical and often legal obligations to make reasonable decisions. For that matter, when we make decisions about other people’s money, especially large amounts of it, we have similar obligations. OT security is more than OT putting our head in the sand and saying “Ship route planning is an IT system.” It is more than IT putting their head in the sand and saying “Not running aground is the captain’s responsibility.” Every business has an obligation to make reasonable design, training and other decisions about the safety of the public and workers, and reasonable decisions about the large amounts of money invested in physical processes like large ships.

More generally, we study attacks to understand what is reasonable to defend against. And we study breaches and defensive failures to try to understand whether our own management processes would really have prevented analogous breaches and failures.

About the author
Picture of Andrew Ginter

Andrew Ginter

Andrew Ginter is the most widely-read author in the industrial security space, with over 35,000 copies of his three books in print. He is a trusted advisor to the world's most secure industrial enterprises, and contributes regularly to industrial cybersecurity standards and guidance.
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New CISA, CCCS et al Alert | Advice on Pro-Russian Hacktivists Targeting https://waterfall-security.com/ot-insights-center/ot-cybersecurity-insights-center/new-cisa-cccs-et-al-alert-advice-on-pro-russian-hacktivists-targeting/ Tue, 06 Jan 2026 08:49:25 +0000 https://waterfall-security.com/?p=38047 The most recent CISA, CCCS et al alert / advice on pro-Russian hacktivists targeting critical infrastructures is a lot of good work, with one or two exceptions.

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New CISA, CCCS et al Alert | Advice on Pro-Russian Hacktivists Targeting

Picture of Andrew Ginter

Andrew Ginter

New CISA, CCCS et al Alert Advice on Pro-Russian Hacktivists Targeting

The most recent CISA, CCCS et al alert / advice on pro-Russian hacktivists targeting critical infrastructures is a lot of good work, with one or two exceptions. The alert documents poorly resourced hacktivists connecting with ICS gear over the Internet and hacking it. That gear tends to control critical infrastructures in the smallest, poorest and weakest of critical infrastructure installations – infrastructures most in need of simple, clear advice.

To its credit, the guide documents threats and tactics, and provides advice to both owners / operators and device manufacturers. However, the guide misses the mark in the section “OT Device Manufacturers.” I find this language very misleading:

“Although critical infrastructure organizations can take steps to mitigate risks, it is ultimately the responsibility of OT device manufacturers to build products that are secure by design.”

And,

“By using secure by design tactics, software manufacturers can make their product lines secure “out of the box” without requiring customers to spend additional resources making configuration changes, purchasing tiered security software and logs, monitoring, and making routine updates.”

When I read these words, the message I get is “If device manufacturers would only do their job better, then critical infrastructure owners and operators could ignore security and go forth to connect as much of their control systems as they wish to the Internet.”

This is of course nonsense.

We can configure “secure” products into hopelessly insecure systems, just as we routinely (with a bit of care) configure “insecure” ICS products into “secure” systems. That manufacturers should “take ownership of security outcomes” does not mean they can or should ever take sole ownership of such outcomes. A sentence or two to this effect would help readers better understand the relative responsibilities of manufacturers vs. owners & operators.

By analogy, automobile manufacturers can build all the seat belts, turn signals and rear-view mirrors they want into their vehicles, owners and operators still need to be taught to use these features to improve their driving safety. More specifically, owners and operators of the smallest, poorest and most vulnerable critical infrastructures need to hear that it is never reasonable for them to deploy safety-critical nor reliability-critical HMIs on the Internet, no matter what “secure” by design features have been built into these products.

And again, while I commend these organizations for doing the work of putting out the alert / guidance, a second feedback is that their advice to owners and operators missed the mark. It is not that the advice is wrong – it   the wrong audience. The advice is appropriate for larger “medium-sized” infrastructures with a larger workforce, some of whom are knowledgeable in basic computer and cybersecurity concepts. The hacktivist attacks we’re talking about are targeting the smallest, poorest and least well-defended of critical infrastructures globally. These are organizations that uniformly suffer from STP Syndrome – Same Three People.

There is nobody no staff in these organizations who will understand the carefully phrased, completely general and abstract language of the guide’s 8 major recommendations and 17 sub-recommendations. These smallest organizations need the simplest advice possible. Eg:

  • Don’t connect any of your OT systems on the Internet. Ever.
  • Don’t enable remote access into any of your OT systems. Ever.
  • Auto-update all of your ICS firewalls, and religiously replace these devices every 3 years, because let’s face it, some time after that the manufacturer is going to stop providing updates, and when they do, you’re not going to notice are you?
  • Lock the doors to rooms containing your OT gear, and change the locks annually to control who has access to the space, because again, let’s face it, you’re going to lose track of who has those keys aren’t you?
  • Make sure you have backups and spare equipment to restore those backups into when your main equipment breaks, or when that gear is hacked irrecoverably.
  • Buy insurance from a reliable provider who can send someone who knows what they’re doing to your site when you have an emergency, to clean up the mess and restore your systems.

Again – I commend these organizations for making the effort. Securing the smallest, least-capable critical infrastructures is a hard problem to solve. This document is much better than nothing but would benefit from clearer and stronger guidance targeting owners and operators of the smallest critical infrastructure control systems, not just manufacturers of the control devices in those systems.

About the author
Picture of Andrew Ginter

Andrew Ginter

Andrew Ginter is the most widely-read author in the industrial security space, with over 35,000 copies of his three books in print. He is a trusted advisor to the world's most secure industrial enterprises, and contributes regularly to industrial cybersecurity standards and guidance.
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We can’t – and shouldn’t – fix everything – Episode 147 https://waterfall-security.com/ot-insights-center/ot-cybersecurity-insights-center/we-cant-and-shouldnt-fix-everything-episode-147/ Wed, 17 Dec 2025 14:47:15 +0000 https://waterfall-security.com/?p=38027 We know there are problems in our security systems, but we can't and shouldn't fix everything. What do we fix? Who decides? How do we explain what's reasonable to people who do decide? Kayne McGladrey, CEO In Residence at Hyperproof, joins us to explore risk, communication, and a surprising role for insurance.

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We can’t – and shouldn’t – fix everything – Episode 147

We know there are problems in our security systems, but we can't and shouldn't fix everything. What do we fix? Who decides? How do we explain what's reasonable to people who do decide? Kayne McGladrey, CISO in Residence at Hyperproof, joins us to explore risk, communication, and a surprising role for insurance.

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“We have new intel. The threat has changed, the probability has changed, the impact has changed, whatever it might be. Do we still feel good about our previous judgment of this?” – Kayne McGladrey

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Medical Device Cybersecurity Is Tricky – Episode 146 https://waterfall-security.com/ot-insights-center/ot-cybersecurity-insights-center/medical-device-cybersecurity-is-tricky-episode-146/ Thu, 11 Dec 2025 14:21:50 +0000 https://waterfall-security.com/?p=37991 Yes the device has to be safe to use on patients, and yes it has to produce its results reliably, but patient / data confidentiality is also really important. Naomi Schwartz of Medcrypt joins us to explore the multi-faceted world of medical device cybersecurity - from MRI's to blood sugar testers.

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Medical Device Cybersecurity Is Tricky – Episode 146

Yes the device has to be safe to use on patients, and yes it has to produce its results reliably, but patient / data confidentiality is also really important. Naomi Schwartz of Medcrypt joins us to explore the multi-faceted world of medical device cybersecurity - from MRI's to blood sugar testers.

For more episodes, follow us on:

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“I would estimate that somewhere between 30 and 50% of medical devices that are submitted to FDA today qualify as a cyber device per the Food, Drug and Cosmetic Act.” – Naomi Schwartz

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Hardware Hacking – Essential OT Attack Knowledge – Episode 145 https://waterfall-security.com/ot-insights-center/ot-cybersecurity-insights-center/hardware-hacking-essential-ot-attack-knowledge-episode-145/ Wed, 26 Nov 2025 01:46:31 +0000 https://waterfall-security.com/?p=37609 If you can touch it, you can hack it, usually. And having hacked it, you can often more easily find exploitable vulnerabilities. Marcel Rick-Cen of Foxgrid walks us through the basics of hacking industrial hardware and software systems.

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Hardware Hacking – Essential OT Attack Knowledge – Episode 145

If you can touch it, you can hack it, usually. And having hacked it, you can often more easily find exploitable vulnerabilities. Marcel Rick-Cen of Foxgrid walks us through the basics of hacking industrial hardware and software systems.

For more episodes, follow us on:

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“Security doesn’t stop at the network interface and also the PCB, the hardware level should be taken into consideration. And in general, I think OT security needs more curious minds that are looking under the hood.” – Marcel Rick-Cen

Hardware Hacking – Essential OT Attack Knowledge | Episode 145

Please note: This transcript was auto-generated and then edited by a person. In the case of any inconsistencies, please refer to the recording as the source.

Nathaniel Nelson
Welcome listeners to the Industrial Security Podcast. My name is Nate Nelson. I’m here with Andrew Ginter, the Vice President of Industrial Security at Waterfall Security Solutions, who’s going to introduce the subject and guest of our show today. Andrew, how’s it going?

Andrew Ginter
I’m doing very well. Thank you, Nate. Our guest today is Marcel Rick-Cen. He is the founder and lead instructor at Fox Grid International. And our topic is hardware hacking, picking apart the hardware, finding the vulnerabilities, arguably essential attack knowledge. We need to understand how we’re going to be attacked if we’re going to design effective defenses. So that’s that’s the topic for today.

Nathaniel Nelson
Then without further ado, here’s your conversation with Marcel.

Andrew Ginter
Hello, Marcel, and welcome to the podcast. Before we get started, can I ask you to introduce yourself, please? Tell our listeners a little bit about your background and about the good work that you’re doing at FoxGrid.

Marcel Rick-Cen
Yeah, thank you, Andrew. Hi, everyone. My name is Marcel Rick-Cen, and if I would introduce me in one sentence, I am an automation engineer turned OT security nerd. To my background, I have a master’s in automation engineering.

I have global experience in commissioning automation systems, as well as programming, planning, industrial operations. Now, during my day job, I am an OT and IIoT security consultant and a product owner of our in-house OT remote access solution.

During my nighttime, I am a hacker, or if you want to put it more formal, I am an independent OT security researcher that looks at what makes and breaks OT devices. Coming from that, I also founded FoxGrid, where I want to teach industrial cybersecurity and safety to newcomers.

Andrew Ginter
Thank you for that. And our topic is hardware hacking. Can we start with an example? You’ve got a couple of reports out. Can you pick one? Can you tell us about, a concrete example of what what is that?

Marcel Rick-Cen
Yeah, let’s talk about hardware hacking that led to a CVE that I found last year, where I found hard-coded root credentials hidden deep in the device’s firmware memory.

Andrew Ginter
Okay, so you know can you can you go a little deeper? What was the device? How’s it supposed to work? And you know how important is what you found?

Marcel Rick-Cen
So the device is a remote access gateway that machine builders usually built into the electric cabinet, so which connects the machine to the service provider.

In case there’s an unplanned interruption or any other operational bug or coming up, the service provider can directly connect over the cloud portal to this Edge device and start troubleshooting.

Andrew Ginter
So if I may, this is something that’s used in manufacturing. When you say the manufacturer, you mean someone who’s building a robot, someone who’s building a stamping machine, someone who’s building, I don’t know, a conveyor. Is is is that the use case here?

Marcel Rick-Cen
This basically can be used in any operation, from your maybe water treatment plant to your manufacturing to your building automation. Like there are really no limits. This really a network connection from the service engineer’s laptop directly into the heart of the device or into the heart of the operation.

Andrew Ginter
Okay, so it’s not just used for for like a robot, for a manufacturer of equipment. It might also be used by a service provider, by the know the engineer who’s responsible for for you know occasionally coming in and servicing oh parts of a water treatment system. it’s It’s used to access systems as well as devices is is what I’m hearing.

Marcel Rick-Cen
Yes, correct. So this acts as the gateway tu the machine or operational network.

Andrew Ginter
Okay, and so you found the default credentials. Does that mean that any fool who wants to can connect to the cloud, connect into this thing? Or how would you use those default credentials?

Marcel Rick-Cen
Luckily, the attack vector is really narrow. These default credentials, they grant root access to the device, and you only can get root access when you are physically connected to the device. So luckily, the cloud attack surface or the cloud is not exposed to this vulnerability.

Nathaniel Nelson
Okay. Andrew, I don’t know if I just missed it, but what is the actual device that we’re talking about here?

Andrew Ginter
It is an Ixon device, I-X-O-N. I forget the exact name of it, but its it’s physically it’s a little device about you know six inches square and an inch thick. And in my understanding, it’s a remote access device. You can connect into it from the cloud. Who uses this?

The sense I have is that it’s used in manufacturing. If you’re building a a laser cutter or a stamping machine, you might build one of these into the thing so that when the customer calls you up and says, your machine isn’t working, something is worn out.

You can remote into it, do the diagnostics and say, I think it’s this part, replace this part, see if if if the problem is solved. Because, moving parts wear out. Friction is the is the enemy of moving parts.

Andrew Ginter
But, when I asked the gentleman, Rick, he said, yeah, manufacturers of physical equipment use it so they can maintain the equipment or diagnose the equipment remotely.

But It’s remote access. A service provider, an engineer who’s responsible for keeping the automation running at a dozen small water utilities in the geography, might well buy a half dozen of these and drop one of them into each water system to access the HMI and the automation and whatnot.

So it’s remote access. The sense I have is it is used frequently engineers. manufacturers of equipment that’s used in manufacturing, but it could be used by service providers as well.

Nathaniel Nelson
And I think it’s the remote access thing that has me a little bit confused here. We’re talking about hard-coded credentials as vulnerability, something I’m rather used to in the IT space, right? Like a public repository or a server that’s been incorrectly configured will leak credentials to the web that then hackers could use to get in. And we’re talking about a romantic remote access device And yet, I think he mentioned there that you can only actually exploit this vulnerability if you have local physical access to the machine. So can you help me explain that gap?

Andrew Ginter
We go into this in sort of more detail later in the interview, but let me let people know kind of what’s happening. There are basically two user interfaces to the device.

One is the remote access user interface with users configured and blah, blah, blah. That’s not where the vulnerability is. The other interface is if you touch the device and you connect to it, I don’t know, I was a little weak on the details. If you connect through the USB port or if you connect, pins, you’re to electrically to pins sitting bare on the on the on the circuit board, if you open the device up, you can get access to the operating system of the device.

And it’s the operating system credentials that were leaked. So in order to use those credentials, they don’t work on the remote user interface. They work locally when you’re when you’re able to physically touch the device and plug stuff into it.

The CVE was 2024-577990. It was given 5 or a 5.9 or something like this, not a 10. This is not a remote code execution vulnerability. You can’t do this remotely. You have to be local. It’s a local escalation of privilege for vulnerability.

Nathaniel Nelson
And that explanation makes a lot of sense to me, but why is it that Like, how can you even leak credentials to somebody who’s physically using a computer, right? Like any credentials on my computer that get leaked to me doesn’t matter because I’m the user. So what I suppose I’m asking attack scenarios, are we worried about with this vulnerability?

Andrew Ginter
Actually, we didn’t go into that, but as far as I know, the scenario is that you’re there locally touching the device. Now, normally, you look at the device, it’s got network ports, it’s got one of the ports is is connected out to to the world, you come in remotely, it does its thing.

There is no other supported user interface. But if you touch the device, you can get in there, you can tamper with the the firmware, you can tamper with stuff, you can you could presumably create credentials that you could use remotely. You’d need a little bit of skill to do that, but you could brick the device. So it’s, again, if you’re standing there with a hammer, you could also brick the device.

This is why it was given a lower priority. Yes, technically it’s a vulnerability. It’s not a really alarming one. What’s interesting is how did you find it? Because the way that he found it, the technique is what he teaches at Fox Grid. You can also use to find more interesting stuff.

Andrew Ginter
Okay, so so this is something that is is is a local vulnerability. It’s not a remotely exploitable thing, which, yeah, is is lower priority. But still,

What I wanted to ask you about is, we’ve never had someone one on the show who picks things apart like this, or maybe we did once about three years ago, but it’s been a long time.

You know, can you talk about the process? How did you find this? How does one pick these things apart? What is, what does that mean

Marcel Rick-Cen
Yes, absolutely. If I would just describe it to you maybe in a pub or over coffee, this really is like hardware and digital scavenger hunt because you have to look at so many things. You also go down a rabbit hole, see it’s the wrong way, turn around, and then keep digging.

And to find this, I just needed tools for about 30 euros. So a multimeter screwdriver, prying tools, a USB logic analyzer, and USB U-RAT interface was all I needed to find this vulnerability.

Andrew Ginter
So, I mean, can you give me a little more detail? Those are the parts I’ve never used a logic analyzer. I mean, How technical is that? Do I need to be an engineer to use a logic analyzer? How did, how did you go about this? What, can you, can you tell us a story? what did you start with? What do you do next? What does that mean? And, a blind alley went down. How did, how did it work?

Marcel Rick-Cen
Yeah, I can walk you through the all the six or seven steps that led to root access from opening up to the device until I was greeted with the root banner, okay? And before anyone gets started with hardware hacking and picking a device, or before anyone gets started with taking a device apart, here are four electrical safety rules that you should follow because your own life is more important than your curiosity.

And never ever open wall-plugged devices because if they’re directly plugged into the socket, this means that hazardous voltage is inside the PCB, inside the device, and there’s the risk that you can touch a live wire and that’s you risk well you risk an electric shock. Therefore, use devices that have external power adapters only so that the voltage conversion happens outside the area where you’re working with. Also avoid mixing power sources. This is important, for example, if you really go into firmware extraction and of course preventing short circuits because this will fry your PCB and then you have a very expensive brick.

But if you stick to these rules, you can open up the device and first start with the hardware reconnaissance where you just take a look on what chips are on there. And many industrial embedded devices, they run on a so-called system on chip and they have somewhere close to the system on chip the flash memory firmware chip.

So this is basically where the brains and all information are stored and once a is and once the system is powered on, the system on chip pulls the firmware information from the firmware memory chip. If you identified these, then you take a look around the board, are there any debug interfaces and on this device I found a so-called UART debugging interface.

So with these, we can move to the next steps. And first we do some electrical measurements just to prevent that our USB, USB UART and USB signal analyzers get fried because they are very sensitive to voltage. And first things first, we first confirmed the common electrical ground on the debug interface we identified. Once we identified the common ground, we know where we well connect the ground wire of our USB logic analyzer. Then UART interface usually has two more pins, RX and TX, which stands for receive and transmit.

And then we turn on the power and then measure these pins against the electrical common ground. And in most cases, we will find a voltage range between three volts and five volts, which means these devices are communicating on the so-called transistor-transistor logic level. When this is identified, we can move on with the logic analyzer. Power off the device, connect the logic analyzer, we connect the logic analyzer’s ground to the board’s ground, and then the RX and TX wire.

Although, The Rx and Tx pin are already labeled and we only could connect to the Tx. It’s always good to connect to all pins that we have a full picture of what’s going on. Because, Andrew, at this board, this was easy mode. The pins are already labeled, but that’s not always the case. Sometimes you just have a three, four, five pins sticking out, and you don’t know what they mean.

Then you also do the same procedure. You measure for the electric common ground and then start measuring the voltage levels, and this gives you at an idea if you can find logical signals going on.

Andrew Ginter
So thanks for that. I mean, that’s giving giving us some insight into the the mechanics of of dealing with a device. I mean, I’m um’m a software guy. I never have to worry about electrocuting myself if I bring up a compiler on my laptop. But let me ask, you’ve talked about two sort of devices here that that seem to ring a bell with me. There’s the UART, which – so quick question. Is the UART USB or is it RS-232?

Marcel Rick-Cen
This is an RS232 connection to USB. So this basically converts the signal, converts this logic serial signals to USB so that your machine, your computer can work with that.

Andrew Ginter
Nate, real quick here, I had a a very short sort of interaction with with Rick there asking about the difference between USB and RS-232. For anyone who didn’t quite track that, RS-232 is a very old hardware signaling protocol. I mean, I remember using RS-232 back in the day to to connect, this was 30 years ago, to connect to 300 bits per second modems, okay? Ancient, ancient technology.

Why would there be such an ancient interface on this modern device? Is roughly what I asked him. and He said there isn’t. What there is, is a USB port. It turns out that what he connected to the TX and RX he connected to were signaling USB. And when he looked at the signals, he discovered that the messages coming across the USB were RS-232 over USB.

So he looked around, he said, well, I have a a dongle that can can take USB and gives me RS-232 and he connected to it and there he can see the messages coming across. So that’s what’s going on there. It’s a USB connector on the device that connector on the device but the signaling RS-232 over USB.

Andrew Ginter
The other one that that that struck me, and again, I’m a software guy, you mentioned the flash chip. to me, if I get what’s on the flash, I can start looking at instructions, I can start running my disassembler. Is it possible to to sort of go under the nose of the device and just read the flash chip? Or do you have to go through the front door? Do you have to go through the CPU in order to get access to the flash?

Marcel Rick-Cen
No you don’t, you also can basically perform a chip off of the flash chip and then read out the contents with a programmer. This is also possible, but at but at the time of my research I didn’t have such equipment here, so I went through the front door.

Andrew Ginter
Okay, that’s fair. So please carry on. you’re You’re talking about the UART. I interrupted you finish Finish the story here. how how are we How did you get in?

Marcel Rick-Cen
Okay, the logic analyzer revealed that indeed a logical data is transmitted over the TX pin. So this means we can connect our USB UART interface and open a serial console to that.

Andrew Ginter
That’s fair. I didn’t realize that USB was, I mean, I knew USB was serial. That’s what it means, universal serial bus.

Andrew Ginter
But I guess I never put two and two together that you could just, I don’t know, connect an RS-232 to it.

Marcel Rick-Cen
Well, you always need this interface device that you plug between that you plug into your USB socket and then on the other end of the device you can connect to the target device. So once the USB UART interface is connected and I started the terminal on, and I started the serial console on my Linux machine, then I powered up the device again I and could see the boot log flashing in front of the screen.

You know, it was a basic Linux boot lock, and at the very end, there was a login prompt to log into this device. And this is really where it got interesting, and here my curiosity was really on fire because I really wanted to get into this device and I started to look at the boot lock itself first.

Here I learned that the firmware memory is partitioned into several partitions and if you look at the common IoT hardware hacker courses, then they always tell you to go for the rootfs file system because that’s where all the binaries are stored of this Linux device.

But there was another partition that was interesting for me. This was the so-called factory partition. Scrolling further up in the boot lock, there was also a brief prompt to press space bar to enter the bootloader. But Andrew, the timing for this was so narrow that it was almost impossible to hit the timing right to enter the bootloader.

You you can imagine I was jamming the, I was hammering the space bar like a lunatic. And then maybe at the fourth or fifth time I succeeded to get the timing right and then I was presented with the next option to choose the operation. And here a very interesting option was presented to me by pressing the number four, I would be able to enter the boot command line interface.

And this was something what I was interested in and wanted to go, but with this narrow timing, I turned to chat GPT asking it, it this way is there a way that I can automate the key presses and can send a space bar press and a number four press at rapid speed? The AI gave me a five-line shell script code which uses an onboard tool of Kali Linux to send spacebar and number 4’s.

And this immediately landed me into the boot shell. And the boot shell of this device is based on the uBoot bootloader. And all the hardware hackers out there that are familiar with uBoot would immediately see that this is already a very stripped down and secured restricted version of uBoot. There was almost no way of manipulating the device, but they left in the so-called SPI command, which enabled me to read the content of the factory partition.

So that’s what I did. I issued the command to read the factory partition and then its and then it printed out the content of the factory partition in the hexadecimal format. And here’s something really strange occurred to me that the data was not always represented in two hexadecimal digits. that hexadecimal data always needs to have two digits.

If not, the data gets misaligned and then gets corrupted. So the problem I was facing here is that some digits were, or some data was represented with single digits, missing the second digit. So the data was not usable for me. Then I used another script to align the data and then convert the text hexadecimal data back into binary hexadecimal data.

And then I was able to view the binary data and the ASCII interpretation of that. And here’s something really interesting stood out. There were basically three strings of data that at first made not really sense to me but somehow felt familiar. And suddenly I realized this is the information which is also printed on the device’s label on the side. Suddenly I could see that in this partition of the factory, the version number, the serial number, the device version, and the login password for the web management surface for the web management interface was stored.

But there was another string that also kept me guessing and puzzling for quite a while, but this unknown string had the same characteristics as the web login password. It had 10 characters, capital and lowercase letters, and numbers. And I tell you, this had to be another password. So I restarted the device again, and at the very end of the boot process, I was prompted for the login once more. I entered the username root and entered This data I found inside the memory and this gave me root access to the device.

Nathaniel Nelson
Andrew, it’s not that anything that Marcel said at any point there wasn’t clear, but we’ve now gone a while and he’s expressed a lot of technical steps. Can you just give me the big picture summary, what we’re talking about here, what he achieved and why it’s important?

Andrew Ginter
Absolutely. He, he real quick, managed to connect to the boot shell with the space for script constantly blasting. And he got in and discovered there was almost nothing he could do there, but he could look at this one tiny partition. And he managed to get the data, decode the data. And he looked at it and said, this looks like a serial number.

It looks like a password. And so he said, well, let’s try it. And he reboots the device again. He doesn’t do the space for this time. He lets it completely boot. And it comes up and says, OK, I’m ready. Log in. You want to log in? And he said, yeah, let’s log in as root. And it says, well, what’s the root password? And he says, well, here’s the string that I saw in the partition. He enters it, and he’s in.

And now he’s in as root.

Andrew Ginter
Cool. So it’s not like you looked at the file system and said, oh here’s files. Look, there’s a file with the name password. it It wasn’t nearly that obvious.

Marcel Rick-Cen
No it was very well hidden, but I think also on purpose because there’s nothing written in this memory area before or after this partition. You really just find the version number, the serial number, the web management password, and well, the root password. So somewhere in production when the device gets, so to speak, gets the breath of life and the data for the label, At this moment, the data must be flashed into this firmware memory chip.

Andrew Ginter
Okay, so so this is a very small partition then. We’re not talking tens of megabytes. We’re talking tens of kilobytes.

Marcel Rick-Cen
Yeah, it was very small indeed.

Andrew Ginter
Okay, cool. So you found the vulnerability. And then I assume, there’s something called a responsible disclosure process. I assume you contacted the vendor, you contacted the government.

Marcel Rick-Cen
Right

Andrew Ginter
What was the next step there?

Marcel Rick-Cen
So the next step was to contact the security contact of this company and luckily I was already in contact with him on LinkedIn. So on a Sunday morning I sent him a screenshot of, hey Mr. XYZ, I got root access to your OT gateway.

And within two hours, he replied and said, okay, this is very concerning. Please send your findings and everything you have to our security email address and we will look into this first thing Monday morning.

then I wrote a quick report attached to screenshots and the proof of concept video. And around Monday lunchtime, they replied, said, yes, this root password is uniquely generated per device and inserted here during production. But since everything is uniquely, they kind of hinted at that they are accepting the risk so that the probability of this being exploited is rather low. They also said if machine builders, integrators, operators stick to their security requirements, they do not see really a risk of this being exploited.

Andrew Ginter
Okay, so the vendor said, it’s a low priority because, people are expected to have physical security. No fool off the street can come in take one of these devices, walk away with it, pick it apart, bring it back. That’s not a realistic threat. Do you agree with that?

Marcel Rick-Cen
Yes, totally, I agree with that. From all my experience on the shop floor and in the field, you cannot just walk up to an electric cabinet, take out a device, screw it open, extract the root credentials, in and then put it back in with a backdoor you implanted, right? This would hopefully catch some attention.

Andrew Ginter
Okay. and can you Can you finish the the the thought? I mean, you wound up with a CVE for this. you’ve You’ve interacted with a vendor, then then what? how do you How do you finish the process?

Marcel Rick-Cen
Then I contacted Mitre to file a CVE, also reported the things I found and the implications for this and after two months the CVE was assigned.

Andrew Ginter
And at that point, you’re able to disclose publicly. Is that right?

Marcel Rick-Cen
Yes.

All that being said, there is a tiny, tiny risk that you may receive the backdoor device, but then someone really must be targeting your operations. They need to know that you are operating such device. And if you’re expecting a new shipment, they could intercept the shipment, open up the device, extract the root credentials, implant the backdoor, pack it back up and ship it forward to your operations. So for that, if you are operating something critical, or if you’re operating, or if you’re having critical infrastructure and operations, you should definitely opt for temper detection and protection. You know, some devices, they have this little sticker on there, warranty void if removed.

Andrew Ginter
So fascinating stuff, at least at least to me. I’d always wondered, how some of this this hardware hacking was done. But, as far as I know, you don’t get paid to do the hardware hacking unless, I don’t know, there’s a bounty or something. You know, how does this relate to to making a living for you?

Marcel Rick-Cen
Yeah, no, this is not my day job and I also don’t get paid to find these vulnerabilities. Let’s just say this is a very expensive hobby. I’ve been in the I’ve been in the domain of automation systems for half of my life and after my work, I’m still interested, especially in what makes and breaks these devices.

And that’s also how my trainings got born. I took all the experience I made from, well, breaking these devices and turned them into training.

Andrew Ginter
Okay, and this is what you do at FoxGrid. Can you go a little deeper? I mean, if I if I sign up for one of these courses, what are you going to lead me through?

Marcel Rick-Cen
If we stay with hardware hacking, you could sign up to Industrial Embedded Systems Hardware Penetration Testing, where you will also go through these six or seven steps from investigating the PCB to hopefully getting root access. But this course has a unique approach because if you look at the IoT hardware hacking courses, you usually hack some IoT camera or home router, but it’s almost impossible to hack an industrial device because there is an entry barrier problem.

First of all, this hardware is really expensive. You usually pay $500 or more, and it’s risky because you can brick it and then you wasted $500. To get around this, I built a custom firmware for a cheap ESP8266 microcontroller that mimics the behavior of an industrial device and introduces the student to the same challenges I faced.

Andrew Ginter
Okay, so that’s the hardware hacking. Have you got other courses?

Marcel Rick-Cen
Yes, I have my flagship course, Practical Offensive Industrial Security Essentials, which gives students from diverse backgrounds, whether they’re automation engineers, IT professionals, or total newcomers, an holistic introduction to industrial cybersecurity.

Of course, there are some gaps that needs to be filled, but anyone with so anyone with enough curiosity will get through this course. or will have success with the course and then get a holistic understanding of industrial cybersecurity.

Andrew Ginter
So if I can take you sort of on a side trip real quick here. throughout this interview, I have been surprised by you personally. I mean, I had always had a stereotype in mind for people who found vulnerabilities, who hacked stuff, hardware, software, whatever. the the The stereotype that I had in mind was sort of somebody with a big ego, somebody with an ego saying to themselves, I’m smarter than you are. I can find these problems. You, and you you the vendor, have have messed it up.

I always thought you needed a that kind of attitude to be able to go in and tackle know the vendors defenses in and incorporated the product I always thought you needed attitude but what’s coming across from you is something different can you talk about who what do you need sort of in your brain in your personality to be successful here?

Marcel Rick-Cen
Well, to make it short, you just need curiosity and persistence. I think people with a big ego, they are more successful in finding more vulnerabilities But like I said earlier, this is more an expensive hobby for me, so I do not really have the pressure to find vulnerability after vulnerability. For me, it’s more, well, being on this scavenger hunt to go away that, or find a way to operate the device it was not intended to, and then really find a way in. And to be honest, I also have a whole box of scrap electrical, scrap OT devices where I did not find a vulnerability.

So this is where we come back to the expensive hobby. So I think if someone is, understanding a bit of the domain these devices are operated in and have enough curiosity and then persistence to stick to it, they can definitely find some vulnerabilities or if not, well, they can at least learn a lot about the devices, how they operate and how they interact with other devices in the OT domain.

Nathaniel Nelson
So Andrew, we’ve been talking hardware vulnerabilities.

Nathaniel Nelson
It seems relatively serious, but bring it to a practical level for me. If I’m running industrial site and I discover ah a hard coded issue in one of my gateways, and am I running around red alarms ringing? To patch immediately or am I more focused on the systems and data flows around it that enable sort of legacy technologies to occasionally have vulnerabilities like this? How would you interpret it in the grand scheme of things?

Andrew Ginter
Well, in the grand scheme of things, there’s sort of a couple of different questions. let’s let’s Let’s pick it apart. What we’ve been talking about primarily is how to find these vulnerabilities. Once you’ve found a vulnerability, now you’ve got to ask the question, A, can I patch the system? Because if it’s a vulnerability in your safety system, well, I’m sorry, the testing cost of the new version is going to be prohibitive.

It’s just really hard to patch some things. Other things are easier to patch. So can I patch it? Second question is, do I need urgently to patch it? And that’s sort of a different skill set. It’s one skill set to find the vulnerability. It’s a different skill set to say, well, how would an attacker, so it’s an imagination thing. Imagine how would an attacker use this against me?

And, we talked about two scenarios for this vulnerability. One is physically walking up and stealing the device and taking it apart and putting it back, which seems not a very credible threat because you’re going to be discovered. The second scenario was, someone with much more resources discovers that you’ve just ordered 50 of these, intercepts the shipment, bribes the driver to go take a long coffee break, breaks into, five or 10 or 15 of these devices, inserts malware, packages them all up again. Again, is that a credible threat? It’s a credible threat for some people – very high value targets. Is it a credible threat for a small bakery? probably not. So, first step is find it. Second step is figure out, can I even patch it? Third step is how would a bad guy exploit this?

Are there credible threats? Is there a third scenario that we haven’t imagined? So it’s a, it’s a, a question of imagination and studying what people have done in the past. And then, the the the decision, part part of it is, how easy is this to exploit? So we’re talking about devices generally. We’re also talking about cloud connected devices, because a lot of the devices that Marcel is focused on, that he teaches you about is industrial internet devices. They’re connected out to the cloud.

So that’s more internet internet connected, more internet exposed. But really what he looked at here was an OT, cloud remote access device. It’s arguably the most exposed piece of technology in the OT network. It’s the technology that gives internet-based users access to the OT system. So normally you would set these things on automatic update. Why? What if they blue screen? Well, nobody cares if they blue screen. It’s inconvenient if they blue screen. If the bad guys get in, they can work whatever they want, sabotage on your OT network. So, um, normally people pay a lot of attention to defects in their, to, to vulnerabilities in their OT remote access.

This one, we just, we couldn’t imagine a credible attack scenario for mere mortals. Um, it might not be that worry that that big to worry about, but generally speaking, this is the kind of device you want people like Marcel picking apart the most thoroughly, because this is the device that has to be the most thoroughly protected.

Andrew Ginter
Well, thank you so much. I mean, I learned something this episode. Before we let you go, can I ask you to sum up for our listeners? What should we take away from this? what What’s important to to to know about this stuff and and how do we use it going forward?

Marcel Rick-Cen
Okay, looking at the vulnerability I found, this was a prime example that just one part of security was completely overlooked. When you look at the device from a network perspective, you see a very fortified device.

But security doesn’t stop at the network interface and also the PCB, the hardware level should be taken into consideration. And in general, I think OT security needs more curious minds that are looking under the hood. For example, if you’re an engineer, you already understand the industrial processes.

And here I just can recommend you to level up your cybersecurity skills. And this this is exactly what I’m doing with FoxGrid. This platform exists to teach industrial security in an affordable and practical way. The flagship course, practical offensive and Practical Offensive Industrial Security Essentials, comes with an open source lab where you not only learn about penetration testing tools, but also how you can use them on simulated industrial controllers. And that way, you also can understand how your real devices would behave under such conditions. So for the next steps, if you’re curious, check out Fox Grid for resources and connect with me on LinkedIn. And of course, keep pushing OT security forward.

Nathaniel Nelson
So that seems to just about do it for your interview, Andrew, with Marcel Richtsen. Do you have any final thoughts that you’d like to share before we leave today?

Andrew Ginter
I guess so. I mean, I had always been curious, how people do this stuff. What surprised me about the the interview here was that I actually followed what he did. I kind of understood it. I thought it’d be harder than that. And I suppose it could be if you have to, if you don’t have a small amount of information to look at, it if you got to look at the entire firmware and start, I don’t know, disassembling megabytes of firmware looking for vulnerabilities.

That would strike me as harder. This seemed really straightforward. I don’t know if I don’t know if I’m curious enough about how this stuff works that I would do the work myself, but I sure wouldn’t mind another two or three guests like this to to walk us through how they did the hard work so that we can satisfy our curiosity.
-14:48

<insert bit from the end of the commentary>

Andrew Ginter
And beyond my curiosity, I agree with Marcel, we need people tracking down vulnerabilities. That’s, it’s because that’s the good way to persuade vendors to invest more in security, to, make these devices more secure to begin with is to point out afterwards, they’ve got problems. And, the next time around, hopefully they will be more careful. The bad way is to wait for the bad guys to find the vulnerabilities and exploit them and take advantage of us. So, we need more of the good guys. we need more more technical, curious people out there fighting the fight. So, thank you to Marcel.

Nathaniel Nelson
Well, thanks to Marcel for satisfying our curiosity. And Andrew, as always, thank you for speaking with me.

Andrew Ginter
It’s always a pleasure. Thank you, Nate.

Nathaniel Nelson
This has been the Industrial Security Podcast from Waterfall. Thanks to everyone out there listening.

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The post Hardware Hacking – Essential OT Attack Knowledge – Episode 145 appeared first on Waterfall Security Solutions.

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Managing Risk with Digital Twins – What Do We Do Next? – Episode 144 https://waterfall-security.com/ot-insights-center/ot-cybersecurity-insights-center/managing-risk-with-digital-twins-what-do-we-do-next-episode-144/ Mon, 20 Oct 2025 15:17:50 +0000 https://waterfall-security.com/?p=36741 How can we USE this information to make useful decisions about next steps to address cyber risk? Vivek Ponada of Frenos joins us to explore a new kind of OT / industrial digital twin - grab all that data and work it to draw useful conclusions.

The post Managing Risk with Digital Twins – What Do We Do Next? – Episode 144 appeared first on Waterfall Security Solutions.

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Managing Risk with Digital Twins – What Do We Do Next? – Episode 144

Asset inventory, networks and router / firewall configurations, device criticality - a lot of information. How can we USE this information to make useful decisions about next steps to address cyber risk? Vivek Ponnada of Frenos joins us to explore a new kind of OT / industrial digital twin - grab all that data and work it to draw useful conclusions.

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“Lots of people have different data sets. They have done some investment in OT security, but they’re all struggling to identify what’s the logical next step in their journey.” – Vivek Ponnada

Managing Risk with Digital Twins – What Do We Do Next? | Episode 144

Please note: This transcript was auto-generated and then edited by a person. In the case of any inconsistencies, please refer to the recording as the source.

Nathaniel Nelson
Welcome listeners to the Industrial Security Podcast. My name is Nate Nelson. I’m here with Andrew Ginter, the vice president of industrial security at waterfall security solutions, who’s going to introduce the subject and guest of our show today.

Andrew, how’s it going?

Andrew Ginter
I’m very well, thank you, nate. Our guest today is Vivek Ponnada. You might remember him from an episode a little while ago. He was the co-lead on the top 20 secure PLC coding practices document that came out a year ago, two years ago.

Today, he’s the Senior Vice President growth and strategy at Frenos. And our topic is digital twins for managing risk. And it sounds like a bunch of marketing buzzwords, you know, digital twins, managing risk, but they’ve got some real technology behind this. So I’m looking forward to this.

Nathaniel Nelson
Then without further ado, here’s you with Vivek.

Andrew Ginter
Hello, Vivek, and welcome to the show. Before we get started, can I ask you to say a few words about yourself for our listeners and about the good work that you’re doing at Frenos?

Vivek Ponnada
Sure, thanks Andrew. Hey everyone, my name is Vivek Ponnada. I am the SVP of Growth and Strategy at Frenos. I’ve been in the OT security space for quite some time. Back in the day, I was a gas turbine controls engineer for GE, then I became a controls and cybersecurity solutions upgrade sales manager for them.

I initially covered power and utilities and then of course added oil and gas. I’m based in houston so that was a natural thing. Before joining Frenos worked at nozomi networks as the regional sales director for three years so I’ve been in the OT security space for quite some time and I am happy to be on this podcast.

And at Frenos, we’re doing something cool. We’re doing an attack path analysis and risk assessment at scale, bringing autonomous risk assessments to a space that’s been lacking this kind of approach. So we’re looking forward to our conversation discussing more about that.

Andrew Ginter
Thanks for that. And our topic today is risk, which a lot of people find boring. I mean, people new to the field tend to want to focus on attacks. Attacks are interesting. Attacks are technical. It’s not until they have failed to secure funding as a manager of, you know, their security team for the last 10 years that they start being interested in risk, which is the language and the decision-making of business.

We’re going to talk about risk. You’re talking about, you know, we’re going to talk about digital twins, which is a real buzzword nowadays, but, you know, this is our topic.

And you’ve mentioned, you know, risk assessments, you’ve mentioned attack path analysis. You know I look forward to looking looking into all of this. You know to me, risk is is fascinating. It’s how we make progress. It’s how we shake the money loose.

But you know before we start, can we can we can you before we dig into it, can we start at the beginning? What is the problem, the risk problem that that you know we’re trying to address here?

Vivek Ponnada
Yeah, great question, Andrew. The past 10 plus years in OT security has been, let’s find out what we have, right? So lots of people start figuring out that they need asset inventory solutions. So the likes of Dragos, Nozomi, Claroty have been the forefront of that kind of an approach. So network security monitoring leading to passive asset discovery and vulnerability identification.

So now 10 plus years into this people have a lot of datasets. They have several sites, especially the ones that they would consider important to their production. They’ve installed sensors. They have lots of information.

Now they’re asking what next, right? The real use case is risk identification and risk mitigation as you mentioned, but there’s a struggle. We’ll struggle out there with different data sets not able to figure out what the actual risk is for them to address next. So that’s the problem we’re trying to solve.

We are trying to aggregate information, provide contextual analysis of what’s the riskiest path to a crown jewel or what might be the logical way to isolate and segment because not every risk can be mitigated by just patching your vulnerability for whatever reason that that’s the the main problem.

The conclusion is that lots of people have different data sets. They have done some investment in OT security, but they’re all struggling to identify what you do with that information what’s the logical next step in their journey.

Andrew Ginter
So that makes sense. I mean, it’s one thing to sketch, this is what, the nist cybersecurity framework says a complete security program should look like.

It’s another thing to say, I’ve only got so much budget this year and a comparable amount, hopefully next year. What do I do this year? What do I do next year? What’s sort of most important to do first? That’s that’s a really important question.

How does a person figure that out? What what’s the decision path there?

Vivek Ponnada
Yeah, that’s the real question. Lots of people in the past used to say over isolated or we are segmented. Where we have a DMZ between it and ot. A lot of these assumptions have not been validated.

In other cases where they have different data sets, it’s not very clear what the what the next problem that they could solve is, right? So everybody like you said has limited budget or resources.

So the honest question is, hey, where we should focus next? It’s not very clear. People have done linear projects, right? They’ll pick a firewall project or a segmentation project or a vulnerability management program.

And all these are are good, but overall not fixing the immediate problem or not solving the immediate problem first, right? So the commonly requested feature of many of these tools like dragos, nozomi or other vendors has been, hey, can you please tell me what my riskiest asset is or what my riskiest path is?

And they have not been able to do it because that’s not in in their and their current portfolio, is that contextual summarization, right? So let’s say you have an asset at the purdue model level two, for example, that is talking to another asset at level three, and then there’s a DMZ about that with some kind of firewall rules, isolating it, and if someone has a real world knowledge of this network and and that’s what we are talking about right a digital twin that’s kind of replicating the network and you analyze if that firewall rule and if that path is possible to get to level two or maybe they have other compensated controls in the path allowing them to say yep my level two is secure this network this location is not reachable easily or it takes a lot of complicated daisy-chaining of attacks to get to then that would be a an identification of what the what the risk is and if you need to address something.

The common consensus has been one, of course, you can really assess these in real time in the production environment, right? So you need to build something that’s a replica of that network.

And then you analyze all these scenarios to see if that asset that you deem important or that network that you deem is a is it critical for your environment.

Is reachable or not reachable from the outside or from any other attack vector that you choose, right? They assume breach could be your corporate enterprise network it could be a wireless network or it could be anything else that you deem as a as an attack vector and to assess in this digital replica or digital twin if that asset can be reached.

So that’s what in general most people have been asking for that’s been missing in the currently available set of tools.

Andrew Ginter
So Nate, Vivek’s answer there was a little abstract. Let me let me be a little more concrete. He’s saying, look, a lot of people in the last 10 years have deployed Dragos and Nozomi and Industrial Defender and you name it, asset inventory tools.

And in a large organization, these tools come back and say, you have 10,000, you might have 50,000 industrial control system assets. Okay.

And many of them are poorly patched because they’re deep down in areas where you can’t, it’s really hard to patch them. Patching them is dangerous. You have to test these patches, blahh blah, blah, blah.

So you’ve got 107,000 vulnerabilities in these 50 odd thousand assets. Okay. And they’re arranged into 800, 2000, whatever subnetworks.

And the networks are all interconnected. Right. So now you’re you’re you’re you’re scratching your head going, and the question is, what do I do next with my security?

And one of the things the asset inventory folks have done is they’ve allowed you to go through these assets, understand what they are, and assign a criticality to them. These are the safety instrumented systems. They’re really important.

Nothing touches them. These are the protective relays. They prevent damage to equipment and so on. And so what he’s saying is you can’t just look at the list of assets and vulnerabilities and figure out what to do next.

You need a model. And so this is what he’s talking about, a digital twin that is looking at attack paths and looking at which assets are really important and telling you which really important have assets have really short and easy attack paths.

That’s probably what you need to focus on next.

Nathaniel Nelson
Yeah, and I fear this is one of those things where everybody else in the world knows something that I don’t, but like, what is a digital twin?

Andrew Ginter
You know… That word is a marketing buzzword and it means whatever the marketing team wants it to mean. The first time I heard the word was in a presentation a few years ago at s4.

The sales guy from ge got up and did a sales pitch, in my opinion, a very smooth, a very, what’s the right word, cleverly scripted sales pitch. But he basically said a digital twin is a computer model of a physical system.

And you the ge at the time had technology, they probably still have it, that will, let’s say you’ve got a chemical process. It’s going to it’s got a physical emulator built in. It can simulate the chemistry.

It’s got emulators built in for all of the ge PLCs in the solution, for all of the ge ihistorian and other components. It’s got a complete simulation. And whenever the physical the measurements coming out of the physical world, they correlate against the measurements that should be coming out based on the simulation.

Whenever there’s a material discrepancy, they would say, oh, that’s potentially a cyber attack. Investigate this. Something has gone really weird here and would take all sorts of automatic action to correct it.

It was amazing in principle, yet I’ve heard dozens of other vendors use the term digital twin to mean other things. The best definition that I’ve heard is, look, your cell phone, Nate, your cell phone is a digital twin of you.

What does that mean?

It’s not, probably not, a biological simulation of your body, though some apps kind of do that. They’re measuring heartbeat and whatnot.

It is an enormous amount of different kinds of information about you. Somebody who steals this your cell phone, steals all that information, knows an enormous amount about you.

And so, I like that definition because it’s much broader than the very specific original definition that I heard at s4 from ge. A digital twin can be anything that is a lot of detailed information.

And so, I can’t remember if it’s on the recording or not, but I remember asking Vivek, is your digital twin that kind of physical simulation? And he’s going, no, no, no. It’s a network simulation. It’s a different kind of digital twin than the physical simulation that some people talk about. And they use it for different purposes. So, again, it’s a marketing buzzword, but it means, generally speaking, a system that has a lot of information that uses and analyzes and, does good things with a lot of information about another thing, like my cell phone does for me.

Andrew Ginter
So that makes sense in the abstract. I mean, you folks do this. You’re building this technology. You’ve got this this digital twin concept. Can you talk about what you folks have? I mean, maybe give us an example of deciding what to patch next and using this this digital twin and sort of give us some insight into into what data you have, what data you need, and and how you use that to make these decisions.

Vivek Ponnada
Yeah, great question, Andrew. Patching has been a significantly challenging problem to solve in ot, as you’re well aware, right? In it, if it’s vulnerable, you apply a patch and there’s a limit of downtime impact, but you run with it.

In ot, of course, it’s not practical because a patch might not be available, an outage window might not be available, and of course, there’s production, downtime issues to deal with, so patching has been really hard.

With what we’re doing though, it’s actually highlighting what to patch and what might be skipped for the moment. Right so when we’re doing this attack path analysis and we come up with a mitigation prioritization score and we say that, hey, this particular network is easy to get to, the complexity of the attack is pretty pretty low.

In just one or two hops from the enterprise network, I’m able to get to this asset and this is vulnerable. And we do provide other options besides patching right we’ll say maybe segmentation or adjusting the firewall role might be a way to go in some cases but if you do decide that patching is relevant and and our recommendation provides that you’ll see that if something is not on that attack path, right? So it might be another asset in the vicinity, but the complexity the attack of that to that asset is much, much higher, then you could deprioritize patching that asset, even if those two assets we’re talking about have the exact same vulnerability, right?

So if something is on the attack path and it’s easier to execute an attack to that asset, maybe you want to prioritize that more than another asset that’s exactly the same vulnerability, but it’s not on a critical attack path, if you will.

And so getting to it is harder. So you would want to deprioritize that compared to the other ones.

Andrew Ginter
All right, so so you used the word reachable. Is that loosely the same as or connected to the concept of pivoting, where an adversary takes over a an asset and a computer, a PLC, something, and uses the compromised cpu, basically, to attack other things, pivot through a compromised device to attack other things, and then repeat, use the newly compromised things to attack other things?

Eventually, you find, let’s say, computers that have permission to go through a firewall into a deeper network, and now you can use that compromised computer to reach through the firewall. Is this what reachable means? Reachable by a pivoting path?

Vivek Ponnada
It certainly could be right so pivoting would be jumping from one host or one asset to another right or from one network to another.

The concept of living of the land means that you have ownership of an asset and you’re using native functionality and eventually get to another asset from there because you have a direct connection or to a firewall for example. And so reachable essentially means that you’re able to get to that asset.

Now how you get to that asset or network is it because know firewall rule has any any for example that allowed you to just get there or in another case you were able to use rdp or some kind of insecure remote access to get there or in other cases maybe a usb right somebody plugged in the usb and now you have access to that asset. So lot of these scenarios are very much dependent on what the end user is trying to evaluate the risk for.

So if they are for example heavily segmented and their primary mediations are all segmentation and firewall based then they would want to know if those firewall rules are working according to plan or if the last time there was an exception that that poked a hole in their firewall now they are allowing access from level 4 to their critical networks, not realizing that their firewall has as a hole.

In other cases, they might have assumed that rdp was disabled in this level 3 device in this workstation, but it is actually enabled. And so now suddenly someone from outside of their enterprise network is able to get to that level 3 and now once you’re there, they could do a lot more, right, further exploration. So reachable essentially means that you’re able to get to a network that’s of interest from another area that’s your starting point.

Andrew Ginter
So, Nate, I remember a couple of episodes, a year and a half, two years ago, robin berthier was on from network perception. He was doing, it sounded like a bunch of similar stuff.

He wasn’t, I don’t think they were taking the output of, drago’s tools, but I could be wrong. What I remember was that he was taking firewall configurations and putting sort of a reachability, what’s reachable from where, map together for large complex OT networks, and would issue alarms, would issue alerts when sort of reality deviated from policy. You could say policy is this, safety instrumented systems never talk to the internet.

That’s a reasonable policy. And he would ingest hundreds, sometimes thousands of firewall configurations and say and router configurations and come back with an alert saying, these three devices over here are safety systems and they can reach the internet. So that what he was doing. What we’re talking here, what seems to me to be different here, but I could be wrong, is we’re talking here about pivoting paths, not only paths.

Sort of network configuration, not not just reachable not not just reachability, but the difficulty of pivoting as well.

Nathaniel Nelson
Yeah, and and is the reason why pivoting becomes relevant in a discussion about PLC security because these devices make for such efficient means of, that they connect your maybe, let’s say, lesser it t assets to more important safety critical systems. So PLCs sort of seem like a natural point at which an attacker would move through.

Andrew Ginter
Sort of. PLCs tend to be the targets of pivoting attacks in ot, sophisticated attacks, because they’re the ones that control the physical world. You want to reach the PLC to cause it to misoperate the physical process.

Pivoting through PLCs is possible in theory, and it’s a little bit more possible in practice when the PLC is based on a popular operating system like a stripped-down windows or a stripped-down linux.

But a lot of PLCs are just weird. They just their operating system, their code does one thing. It does the PLC thing. In theory, you could break into the PLC and give it new code.

But if I want to if I want to pivot through a PLC to a windows device, what am I going to how am I going to get into the windows device? I might want to get into it with a remote desktop. There is no remote desktop client on a PLC. It doesn’t exist.

And so pivoting through PLCs, you the attacker might, depending on the version of the PLC, might have to do an enormous amount more work to get pivoted through a PLC.

And so if the only way into, a let’s say, a safety system target is a really critical system, is to pivot through three different PLCs, pivoting through firewalls each time, that’s going to be really hard to do.

Whereas if, I remember a presentation from from dale peterson at s4 last year, year before, where he he was talking about network segmentation. He says, network segmentation, firewalls are almost always the second thing that industrial sites do to to launch their security program.

And I’m going, excuse me, excuse me, what’s but second thing? What’s the first thing? I thought firewalls were the first thing everybody does. “Andrew,” he says, “the first thing is to take the passwordless hmi off of the internet. That’s the first thing you have to do.” and I’m going, yep, you’re you’re right.

And a tool like this will be able to look at you and say, here’s my network. If I want to go from the bad guys into this hmi, it’s on the internet. It has no password.

That’s your number one. It’s it can tell you that. Not just policy, but it it it says, and the safety systems back there, you’ve got to pivot through three PLCs.

That’s going to be really hard to do. You might have some other security you might want to deploy in between. So this is the the concept of of pivoting that, I found very attractive in this this tool, measuring the difficulty of an attacker from the internet reaching a a target inside of a a defensive posture.

Andrew Ginter
That’s interesting. We’ve had guests on the show talking about attack paths. These, these are tools that, build a model of the system and, count all of the ways that an attacker can get from where they are into a consequence that we want to avoid. Um,

And it’s not just count them, but evaluate, let’s call it the difficulty. Mean, risk talks about the classic approximation for risk is likelihood times frequency.

Sorry, likelihood times consequence or impact, if you wish. And, likelihood is a really murky, difficult concept for high consequence attacks. And so what a lot of people do is they substitute likelihood with difficulty. And they They try to evaluate how difficult are really nasty, attacks with really nasty consequences.

It sounds vaguely like you’re doing this. You’re you’re You’re talking about attack paths. You’re talking about difficulty. Is this Is this where you’re going? The one thing you haven’t mentioned is consequence.

Vivek Ponnada
Yeah, that’s a good point because we are doing something unique in that we are allowing user to evaluate in this digital to in this digital replica how an adversary might be not only pivoting but exploiting different components to get to their crown jewels right the way we’re doing that is showcasing different views of TTPs that are well documented with all the IOCs and the threat intel that we aggregated so if it’s a power customer for example they could use a volt typhoon view to see how a volt typhoon actor might be able to leverage initial access to credential exploitation to other kind of exploits within within the environment and there might be a manufacturing customer with a whole different set of interesting TTPs that they want to evaluate But the idea behind this is you figure out what the generally documented TTPs are for a certain type of adversary and how they might you go about from your your starting point, which is initial access or the starting point of your threat analysis to all the way to the crown jewels. And in doing so, you’re making assumptions, right? Because, we’re not in this production environment. We’re not actually exploding something, but you’re evaluating the different scenarios where you say, OK, I have this Windows workstation and I’m going to use RDP, right? I’m going to exploit something there.

What if RDP was disabled? So these days people have some datasets where they can export from an EDR tool and provide open ports and services, right? Then we know, for example, upfront that and some of these services like SMB or whatever that you think is typically exploited by the TTP or the threat actor of choice or or interest is exploding and you disable that, you now know that at least that path is closed, right?

In other cases, The attack path might show three or four different types of exploits to be able to get to that ground jewel or the ground jewel network.

Then that that layer of difficulty or the complexity of the daisy chaining is much higher compared to another network or another attack path. That is trivial, right? So it uses native credentials and it only takes one hop in the attack path to get to that asset or network, then for example, that the previous one was more complex to even get to, right?

But the end of the day, all this conversation so far is about, how difficult it is to get to that ground jewel network or the ground jewel asset right not talking about what the attacker might do once they get there because that part is the impact or the consequence here we actually have a an automatic assessment based on the types of PLCs or types of controllers or the types of assets we see in general based on our threat intel and our initial assessment.

But an end user that’s running this tool or a consultant that’s running this tool can adjust that. Right So there’s a manual way for them to say, hey this network is of a higher priority for me compared to this other network.

Show me what the impact of getting to this network is for me because this is higher for me. So to to be fair, we’re not doing quantification yet in this In this tool we’re limiting ourselves at the moment to how easy or difficult it is to get to a particular crown jewel network and what the adversary might be able to do in that kind of a network. Right So it’s it’s one of those interesting aspects of that analysis where you’re not doing the analysis of what an attacker would do once they get to a crown jewel because that’s a whole different ballgame compared to you’re trying to break the kill chain break the path way before that so you’re you’re assessing or analyzing what are all the attack paths and how easy or difficult it is to get to the crown jewels that you’re trying to protect.

Andrew Ginter
Good going. I mean, I have maintained for some time, and and it’s easy for me to do because I’m on the outside. I don’t have to do the work. But I’ve maintained for some time that risk assessments, part of a risk assessment should be a description of the simplest attack or three that remain credible threats in the defensive posture, threats able to bring about unacceptable consequences. There’s always a path that will let you bring about, an attacker bring about an unacceptable consequence. The question is how difficult it is.

And so to me, the risk assessment should include a description of the simplest such attack or, attacks, plural. Um,

So that’s that’s sort of one. Is this kind of what you’re doing? Can can you give me the next level of detail on on what you’re looking at and and how you’re making these decisions?

Vivek Ponnada
Yeah, definitely. So the problem like you described is that there might be some open ports or services that are vulnerable.

However, if those ports are closed or those services are disabled, then that problem is solved, at least for the moment, right? Unless there’s another vulnerability discovered on the particular asset. So what we’re doing is we’re ingesting information from the various sources that they have.

In other cases, provide options to add that in the tool so that you have the contextual information as to what attacks are possible with what’s relevant in that environment, right?

And in the past, people did this using questionnaires, asking people or evaluating and subject matter experts, using a tabletop or something like that. But the beauty of our frameworks platform is that you’re actually able to do this in an automated fashion and at scale, because if you have like a typical customer, or dozens of end-user sites and hundreds or even thousands of networks, you’re not actually able to analyze the risk of each network of each asset down to the level of what’s possible with the given ports and services or install software or not install software in that environment, right?

But if you’re able to ingest all this information right from the IP addresses and different types of assets and the vulnerabilities tied to them to the ports and services that are enabled or disabled or in other cases, making a an exception to say hey I’m disabling this using some kind of application whitelisting or some kind of segmentation.

All the information at scale can be analyzed and you can get a a view that shows a realistic and more or less validated attack path versus someone that’s just looking at a piece of paper or a complex network in a manual fashion.

So this this is where I think the big difference is in that we’re looking at the attack complexity and the attack path at scale with whether it’s tens or so of sites or thousands of networks and able to decipher what the context is for exploitation or just lateral movement or or whatever the path might be to get to your crown jewels.

Andrew Ginter
So you’ve mentioned a couple of times at scale, you’ve mentioned a couple of times the potential for ingesting information about a lot of assets and networks. The asset inventory tools out there produce that knowledge already. I’m guessing you’re interfaced with them.

Can you talk about about that? How do you get data? How do you get the data about the system that that you’re going to analyze?

Vivek Ponnada
Yeah, that’s a great question. Yeah, we definitely can ingest information from a variety of sources. So the platform can ingest information both offline. So drag and drop a CSV or an XML file or any kind of spreadsheet.

And we also have API hooks to be able to automatically ingest information from The likes of Dragos / Nozomi / Claroty, which are the OT security product vendors. We can also ingest information from CMDBs or any kind of centralized data depositories like Rapid7 or Tenable.

In other cases, the customers might have just spreadsheets from the last time they did a site walk. We can ingest that too. So we’re not restricted on ingest ingesting any specific type of format. We have a command line tool that can ingest other sources as well.

But the basis, the digital twin starts with the firewall and the config file. So we ingest information from the likes of Fortinet, Cisco, Palo Alto, you name it.

Then ingest information from these IT or OT tools. At the end of the day, the more information that’s provided, the fidelity of the data is higher. But the and beauty of the platform is that if you don’t have any kind of information,

We can not only create mitigating controls and options within the platform, but we also built an extension of the Frenos platform called Optica, where you can quickly leverage existing templates, for example, Dell servers or Cisco routers or Rockwell PLCs.

Within a few minutes, you can drag and drop and build a template, which you then import into Frenos. To replicate what might be in the system already. So long story short, any kind of asset information, vulnerability information out there, we can ingest.

And if there is none or there’s limited visibility in certain sections or location, we can build something that’s very similar so that the customers can have a view for what the risk is in a similar environment.

Andrew Ginter
And you mentioned a couple of times, I remember here, compensating controls. I mean, the compensating control everybody talks about is more firewall rules, more firewalls, more firewall rules, keep the bad guys away from the vulnerable assets that we can’t patch because, we can’t afford to shut everything down and test everything again.

Can you talk about compensating controls? What other kinds of compensating controls might your your system recommend?

Vivek Ponnada
That’s a great question because as we were discussing earlier in OT, not everything is fixable because a patch might not be available or an outage window is not available, right? So historically, most people have used a combination of allow listing or deny listing or some kind of ports and services disabled or, to your point, firewall rules and segmentation have a place in that as well.

Overall, the key is to figure out what the attack path is and in how or which fashion you can break that attack path. So if the consideration is from level 4 through a DMZ or firewall and the firewall rule was any any or something that was allowing too much, and maybe too many protocols or something that could be disabled, you can start there as a preference. Right If that’s not possible or that’s not a project you can take the next thing could be hey I’m leveraging this kind of SMB or other exploit at that level 3 device before going to level 2.

Let’s look at what this service was on that particular asset right so you can disable that so within the tool we built in almost 20 or so different options for combinations of all these compensating controls and that are historically used in OT right so it could be a combination of firewall rule or a service or port disabled or or in other cases it could be disconnecting them to put in a different segment Again, this is not new, right? This is how historically OT has been able to mitigate some of the risk.

We’re just bringing that to the forefront to see or show you what other things can be done to break the attack path versus strictly talking about vulnerability management and fixing the problem by applying a patch, which is not practical as we talked about.

Andrew Ginter
Compensating controls are are tricky Nate, making we identify a vulnerability a weakness in a defensive posture there’s a new vulnerability announced from some piece of software that we use on some PLC or safety system or who knows what deep into our architecture the what do we do about that is an open is a question everybody asks sort of the consensus that’s building up is that, if that system is exposed to attack, then we have to put compensating measures in.

If it’s not exposed or if it’s, really hard to reach, maybe we don’t need to change anything in the short term until our next opportunity to to do an upgrade or, a planned outage or something.

And a tool like this one, like the Frenos tool, is one that can tell us how reachable is it, how exposed is this, compare that to our risk tolerance. Are we running a passenger rail switching system? Are we running a small bakery?

Different levels of exposure are acceptable in different circumstances. So having the tool give us a sense of how exposed we are is useful in making that that decision, are we gonna patch or not? And if we have to do something, it’s useful to have a list of compensating controls and sort of the list that that I heard Vivek go through, but they’re probably gonna add to this if they haven’t already.

You can change permissions. If you got a file server that sharing files is the problem and the bad guys can put a nasty on the file server, change permissions so that it’s harder to do that.

Turn off services, programs that are running on, Windows ships with, I don’t know, 73 services running. Most, industrial systems don’t need all of these services. They would have been nice to turn them off ages ago if you haven’t already turned them off and there’s a vulnerability in one of these services and you’re pretty sure you’re not using it, you can turn it off.

Add firewall rules that make it harder to reach the system. Add firewall rules that say, fine, if I need to reach the system for some of the services, but I don’t think I ever need to reach this service from the outside, even if I need to use it on the inside, add a firewall rule that blocks access to that service on that host from the outside.

None of this is easy. Every change you make to an important system have the engineering team has to ask the question is this how likely is it that I’m i’m messing stuff up here how likely is it that I’m introducing a problem that’s gonna that’s gonna bite me with a really serious consequence how how likely is it that the cure is worse than the than the disease here so compensated controls aren’t easy but what I see this tool doing is giving us more information about the vulnerable system about how reachable is that vulnerable system. What are the paths that are easiest to get to that vulnerable system? If I can turn off, I don’t know, remote desktop halfway through the attack path and make the attack that much more difficult, now you have to go through, I don’t know, PLCs instead of Windows boxes.

That’s useful knowledge. This is all useful knowledge. We we need as much ammunition as as we can get when we’re making these difficult decisions about shoot, I have to change the system to make it less vulnerable. What am I going to change without breaking something?

Andrew Ginter
Well, thank you so much for joining us, Vivek. Before I let you go, can I ask, can you sum up for our listeners, what are the most important points to to take away from this new technology? And I don’t know, what can they do next?

Vivek Ponnada
Yeah, for sure. So the quick summary is we’re trying to solve a problem that’s been around for a decade plus. Lots of customers do not have a risk assessment in place. They’re not quite sure where they stand currently.

So some of them are early in their journey with this lack of information. They still need to figure out where they have to invest their next dollar or next hour of resource. And in other cases they had spent the past three or five years in developing an OT security program.

A lot of information available, lots of alerts, but again they’re not so sure how they are compared to maybe their industry peers or how they are compared to where they should be in their security posture management.

So what Frenos is able to do is to both leverage their existing data sets and missing information by providing something that’s a replica of their environment showcase where they should be focusing on in terms of breaking the attack paths highlighting not just where they currently stand but also where they were compared to yesterday so overall this is what most executives have been asking before investing in OT security where do we stand currently how good are we compared to an existing known

Attack vector or campaign if you will and then how good can we be currently as in today because the risks are not staying constant so how do we keep up with it so the outcome of the frameworks platform is both a point in time assessment if you like and also continuous posture management because you’re able to validate what compensating controls and preventive measures that you are deploying or or implementing and if they’re going well or not

So conclusion is that we are a security posture management and visibility company that’s able to bring out the best in your existing data sets and provide you gaps and the gap analysis and and help you figure out where to invest your next dollar or resource on what site or what location.

And if you’d like to know more, hit me up on LinkedIn. My email is Vivek at Frenos.io or happy to connect with you on LinkedIn to take it from there. If you’d like more information, know hit up on our website, Frenos.io as well. You’ll see all the information about our current use cases, the different products and services we have to offer. So looking forward to connecting with more of you.

Nathaniel Nelson
Andrew, that just about does it for your interview with Vive Banada. Do you have any final word to take us out with today?

Andrew Ginter
Yeah. This topic is timely. the topic of risk-based decision-making. I mean, this too is coming into effect in a lot of countries, particularly In Europe, the regulation in every country is different, but the directive says you have to be making risk-based decisions.

And I’m sorry, a risk assessment is… Should be much more than a list of unpatched vulnerabilities. A list of unpatched vulnerabilities does not tell you how vulnerable you are.

It’s just a list of vulnerabilities. To figure out how much trouble you’re in, you need a lot more information. You need information about how which assets are most critical. You need information about how reachable are those critical assets for your adversaries.

And when new vulnerabilities are announced a arise that simplify the pivoting path that simplify reachability of a critical asset for your adversaries you need advice as to that’s what you need to fix next and here are your options for fixing that so I see this kind of of tool as as uh step in the right direction. This is the kind of information that that a lot of us need in not just the world of NIST-2, in the world of managing risk, managing reachability.

You know We’ve all segmented our networks. What does that mean? You can still reach, bang, bang, bang, pivot on through. Well, then, What does that mean? This kind of tool tells us what that means. It gives us deeper visibility into reachability and and vulnerability of the critical assets, risk, opportunity to attack. You know I don’t like the word vulnerability. Too often it means software vulnerability. This talks about This kind of tool exposes attack opportunities and tells us what to do about them. So to me, that’s that’s a very useful thing to do.

Nathaniel Nelson
Well, thank you to Vivek for highlighting all that for us. And Andrew, as always, thank you for speaking with me.

Andrew Ginter
It’s always a pleasure. Thank you, Nate.

Nathaniel Nelson
This has been the Industrial Security Podcast from Waterfall. Thanks to everyone out there listening.

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I don’t sign s**t – Episode 143 https://waterfall-security.com/ot-insights-center/ot-cybersecurity-insights-center/i-dont-sign-st-episode-143/ Wed, 10 Sep 2025 08:31:45 +0000 https://waterfall-security.com/?p=35976 Tim McCreight of TaleCraft Security in his (coming soon) book "I don't sign s**t" uses story-telling to argue that front line security leaders should not be accepting multi-billion dollar risks on behalf of the business. We need to escalate those decisions - with often surprising results when we do.

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I don’t sign s**t – Episode 143

We don't have budget to fix the problem, so we accept the risk? Tim McCreight of TaleCraft Security in his (coming soon) book "I Don't Sign S**t" uses story-telling to argue that front line security leaders should not be accepting multi-billion dollar risks on behalf of the business. We need to escalate those decisions - with often surprising results when we do.

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“It always comes down to can I have a meaningful business discussion to talk about the risk? What’s the risk that we’re facing? How can we reduce that risk and can we actually pull this off with the resources that we have?” – Tim McCreight

Transcript of I don’t sign s**t | Episode 143

Please note: This transcript was auto-generated and then edited by a person. In the case of any inconsistencies, please refer to the recording as the source.

Nathaniel Nelson
Hey everyone, and welcome to the Industrial Security Podcast. My name is Nate Nelson. I’m here as usual with Andrew Ginter, the Vice President of Industrial Security at Waterfall Security Solutions, who is going to introduce the subject and guest of our show today. Andrew, how’s going?

I’m very well, thank you, Nate. Our guest today is Tim McCrate. He is the CEO and founder of TaleCraft Security, and his topic is the book that he’s working on. The working title is We Don’t Sign Shit, which is a bit of a controversial title, but he’s talking about risk. Lots of technical detail, lots of examples, talking about who should really be making high-level decisions about risk in an organization.

Nathaniel Nelson
Then without further ado, here’s your conversation with Tim.

Andrew Ginter
Hello, Tim, and welcome to the podcast. Before we get started, can I ask you to say a few words for our listeners? You know, tell us a bit about yourself and about the good work that you’re doing at TaleCraft.

Tim McCreight
Hi folks, my name is Tim McCreight. I’m the CEO and founder of TaleCraft Security. This is year 44 now in the security industry. I started my career in 1981 when I got out of the military, desperately needed a job and took a role as a security officer in a hotel in downtown Winnipeg, Manitoba.

Shortly after I was moved into the chief security officer role for that’ that hotel and others and had an opportunity to move into security as a career path. And I haven’t looked back I decided I also wanted to learn more about cybersecurity.

Holy smokes, in ’98, ’99, I took myself out of the workforce for two years, learned as much as I could about information systems, and then came back for the latter part of my career and have held roles as a chief information security officer in a number of organizations. So I’ve had the pleasure and the honor of being both in physical and cybersecurity for the past 40 some years.

Andrew Ginter
And tell me about TaleCraft

Tim McCreight
It’s a boutique firm with two of our lines. Our first line is that it’s new skills from the old guard, and we are here to help give back and grow.

And it’s our opportunity to provide services to clients focusing on a risk-based approach to developing security programs. We teach security professionals how to tell their story and how to use the concepts of storytelling to present security risks and ideas to executives.

And finally, we have a series of online courses through our TaleCraft University where a chance to learn more about the principles of ESRM and other skills that we’re going to be adding to our repertoire of classes in the near future.

Andrew Ginter
And our topic is your new book. You know, I’m eagerly awaiting a look at the book. Can I ask you, you know before we even get into the the content of the book, how’s it coming? When are we going to see this thing?

Yeah Well, thank you for asking. i had great intentions to publish the book, hopefully this year. and Unfortunately, some things changed last year. i I was laid off from a role that I had and I started TaleCraft Security.

So sadly, my days have been absorbed by the work that it takes to stand up a business get it up and running. And my hats off to all the entrepreneurs out there who do all of these things every day. I’m new to this. So understanding what you have to do to stand up a business, get it running, to market it, to run the finances, et cetera, it has been like all consuming. So The book has unfortunately taken a bit of backseat, but I’ve got some breathing room now. I’ve got into a bit of a rhythm.

Tim McCreight
It’s a chance for me to get back to the book and start working through it. And and it’s to me, it’s appropriate. It’s a really good time. If I’m following the arc of a story, this is the latter part of that story arc. So I get a chance to help fill in that last part of the story, my own personal story, and and to put that into the book.

Andrew Ginter
I’m sorry to hear that. I’m, like said, looking forward to it. We have talked about the book in in the past. Let me ask you again, sort of big picture. You know, I’m focused on industrial cybersecurity. I saw a lot of value in the the content you described us as being produced. But can you talk about, you know, how industrial is the book?

We’re talking about risk. We’re talking about about leadership, right? How industrial does it get? I know you you do ah you do a podcast. You do Caffeinated Risk with Doug Leese, who’s a big contributor at Enbridge. He’s deep industrial. How industrial are you? How industrial is this book?

Tim McCreight
It spans around 40 years of my career and starting from, you know, physical security roles that I had, but also dealing with the security requirements for telecommunications back in the eighties into the nineties, getting ready for, and and helping with the security planning for the Olympics in the early two thousands, working into the cyberspace and understanding the value of first information security, then it turned into cyber security, then focusing on the OT environment as well, when I had a chance to work in critical infrastructure and oil and gas.

And then finally, you know the consistent message throughout the book is this concept of risk and that our world, when we first, you know when we first began this idea of industrial security back in the forties, bringing it up to where we need to be now from a professional perspective and how we view risk.

I do touch and do speak a little bit about the the worlds that I had a chance to work in from an industrial perspective. The overarching theme though is really this concept of risk and how we need to continue to focus on risk regardless of the environment that we’re in.

And some of the interesting stories I had along the way, some of the, honest to God, some of the mistakes I made along the way as well. I’ve learned more from mistakes than I have from successes.

And understanding the things that I needed to get better at throughout my career. I’m hoping that folks, when they do get a chance to read the book, that they recognize they don’t need to spend 40 some years to get better at their profession. You can do it in less time and you can do it by focusing on risk, regardless of whether you’re in the IT, the OT or the physical space.

Andrew Ginter
So there’s, there is some, some industrial angle in there, but, like I said, industrial or not, I’m i’m fascinated by the topic. I think we’ve, I’ve, beaten around the bush enough. The title, the working title is, is “We Don’t Sign Shit.” What does that mean?

Tim McCreight
I came up with “We Don’t Sign Shit.” And it’s I have a t-shirt downstairs in my office so that that I got from my team with an oil and gas company I worked with. And and Doug Lease was in the team as well.

And it really came down to this, the principle that for years, security was always asked to sign off on risk or to accept it or to endorse it or my favorite, well, security signed off on it, must be good.

Wait a second. We never should have. That never should have been our role. We never should have been put in a position where we had to accept risk on behalf of an organization because that’s not the role of security. Security’s role is to identify the risk.

Identify mitigation strategies and present it back to the executives so that they can make a business decision on the risks that we face. So in my first couple of weeks, when I was at this oil and gas organization, we had a significant risk that came across my desk and it was a letter that I had to sign off on. a brand new staff member came in and said, “Hi boss, I just need to take a look at this.”

I’m like, “Hi, who are you? What team do you work on? And what’s the project you’re working on?” When I read this letter, I’m like, are you serious that we’re accepting a potential billion dollar risk on behalf of this organization? Why?

And like, “Well, we always do this.” Not anymore. And we went upstairs. We got a hold of the right vice president to take a look at this to address the risk and work through it. And as I continued to provide this type of coaching and training to the team there, I kept bringing up the same concept. Look, our job is not to sign shit.

That’s not what we’re here for. We don’t sign off on the risk. We identify what the risk is, the impacts to the organization, what the potential mitigation strategies are. And then we provide that to executives to make a business decision.

So when I did leave the organization for another role, they took me out for lunch and I thought it was pretty cool. The whole team got together and they created this amazing t-shirt and it says, “Team We Don’t Sign Shit.” So it worked, right? And that mindset’s still in place today. I have a chance to touch base with them often. Ask how they’re doing. And all of them said the same thing is that, yeah, it’s that mindset is still there where they’ve embraced the idea that security’s role is to identify the risk and present opportunities to mitigate, but not to accept the risk on behalf of the organization.

That was the whole context of where I I took this book is, wouldn’t it be great if we could finally get folks to recognize, no, we don’t sign shit. This isn’t our job.

Nathaniel Nelson
So Andrew, I get the idea here. tim isn’t the one who signs off on the risk. He identifies it and passes it on to business decision makers, but I don’t yet see where the passion for this issue comes from, like why this point in the process is such a big deal.

Andrew Ginter
Well, I can’t speak for Tim, but I’m fascinated by the topic because I see so many organizations doing this a different way. In my books, the people who decide how much budget industrial security gets should be the people ah making decisions about are these risks big enough to address today? Is this, is this ah a serious problem because they’re the ones that are are you know they have the the business context they can compare the the industrial risks to the the other risks the business is facing to the other needs of the business and make business decisions

When you have the wrong people making the decisions, you risk, there’s a real risk that you make the wrong decisions because the the people executing on industrial cybersecurity do not have the business knowledge of what the business needs. They don’t have the big picture of the business and the people with the big picture of the business do not have knowledge, the information about the risk and the mitigations and the costs. And so each of them is making the wrong decision. When you bring these people together and the people with the information convey it to the people with the business knowledge, now the people with the business knowledge can make the right decision for the business.

And again, the industrial team execute on it. If you have the wrong people making the decision, you risk making the wrong decision.

Andrew Ginter
So let me ask, I mean, you take a letter into an executive, you you you do this over and over again in lots of different organizations. How do how is that received? How do the executives react when you do that?

Tim McCreight
So, I mean, my standard approach has always been, and and I use this as my litmus test is if the role I play as a chief security officer or CISO, and you’re asking me to accept risk, I come back. And the the first question I’m going to ask is if this is the case and you’re asking me to do this on, I’m going to say, no, invariably the room gets really quiet.

People start recognizing, oh, he’s serious. Yeah. Cause I have no risk tolerance when it comes to work. I would be giving everybody like paper notebooks and crayons and I want it back at the end of the day So I don’t have any tolerance for risk. But to test my theory is when I ask executives, if you’re saying that my role is to sign off on this, then I’m not going to, does that stop the project?

It never does. So the goal then is to ensure that the executives understand it’s their decision, and it’s a business decision that has to be made, not a security decision because my decision is always going to be, I start with no and I’ll negotiate from there.

But when we look at what the process is that i’ve I’ve provided and others have followed is I’ll bring the letter with the recommendations to the business for them to review and to either accept the risk, sign off on it, or to find me an opportunity to reduce the risk.

That’s when I start getting attention from the executives. So it moves from shock to he’s serious to, okay, now we can understand what the risk is. Let’s walk through this as a business decision. That’s when you start making headway with executives is taking that approach.

Andrew Ginter
So, I mean, that that sounds simple, simple but in in my experience, what you said there is actually very deep. I mean, i’ve I’m on the end of a long career as well, and I’ve never been a CISO. And in hindsight, I come to realize that, bluntly, I’m not a very good manager.

Because when someone comes to me, it doesn’t matter, so any anyone outside the the my sphere of influence my scope of responsibility saying, hey, Andrew, can you do X for me?

Whenever one of my people comes to me with an idea saying, hey, we should do Y, my first instinct is, what a good idea. Yeah, yeah.

Whereas I know that strong managers, their first instinct is no. And now whoever’s coming at us with the request or with the idea has to justify it, has to give some business reasons.

Again, so that’s, this is this is deep. It’s a deep difference between between you and and people like me.

Tim McCreight
Yeah well, and it is, and there’s, don’t get me wrong. There’s an internal struggle every time when I’ve worked through these types of requests where I, I want to help people too, but, but I understand that the path you got to take and how you have to get business to understand it, accept it and move forward with it. It’s different, right? This is why some great friends of mine that I’ve known for years, and they were technical, they’re technically brilliant. They have some amazing skills. Like, honest to God, I stopped being a smart technical person long time ago, and I’ve relied on just wizards to help move the programs forward.

And, I’ve chatted with them as well, and then they’re similar to you, Andrew. they’ve They’ve got great technical skills. They’ve been doing this for a long time. And, one of the one of the folks I chatted with, they’re just like, I can’t I can’t give myself the lobotomy to get to that level. I’m like, oh, my God. Okay, fair enough.

And I get it, but the way I’ve always approached this, it’s different, right? So I i take myself out of the equation of always wanted to help everybody to how can I ensure that I’m reducing the risk?

And if I can get to those types of discussions and have them with executives, for me, that’s where I find the value. So all of the work I’ve done in my career to get to this space, the amazing folks that I’ve met along the way, the teams that I’ve helped build, the folks I still call on to, to to mentor me through situations,

It always comes down to, can I have a meaningful business discussion to talk about the risk? And then it takes away some of the emotional response. It takes away that immediate, I need to help everybody do everything because we can’t.

But it gives us a chance to focus on what the problem is. What’s the risk that we’re facing? How can we reduce that risk? And can we actually pull this off with the resources that we have? So yeah, I get it. Not everybody wants to sit in these chairs. I’ve met so many folks throughout my career that they keep looking at me going, Jesus, Tim, why would you ever want to be in that space?

Why would you ever accept the fact that you’re, that they’re trying to hold you accountable for breaches or or for events or incidents? And I challenge back with it from it, for me, it’s that opportunity to speak at a business language, to get the folks at the business level, to appreciate what we bring to the table, whether it’s in OT security, IT t or cyber, it physical or cyber, it’s,

It’s a chance for all of us to be represented at that table, at that level, but at a business focus. So for me, that’s why I kept looking for these opportunities is can I continue to move the message forward that we’re here to help, but let’s make sure we do it the right way.

Andrew Ginter
So, fascinating principles. Can you give me some examples? I mean, TaleCraft is about telling stories. Can you tell me a story? How did this work? How did it come about? What kind of stories are you telling here?

Tim McCreight
So there’s there’s a lot that i’ve I’ve presented over the years, but a really good one is I was working with Bell Canada many years ago. We had accepted the, we were awarded the communication contract and some of the advertising media supporting contracts for the Olympics for 2010 for Vancouver.

And I was working with an amazing team at Bell Canada. Doug Leese was on the team as well, reporting into the structure. So it was very cool to work with Doug on some of these projects. We decided that the team that was putting in place the communication structure decided they want to use the first instance of voice over IP, commercial voice over IP. It was called hosted IP telephony.

And it was from Nortel. If folks still remember Nortel, it was from Nortel Networks. We looked at the approach that they were taking, how we were going to be applying the the technology to the Olympic Village, et cetera.

Doug and the team, they did this amazing work when the risk assessment came across, but they were able to intercept a conversation decrypt the conversation and play it back as an MP4, like an MP3 file.

You could actually hear them talking. And it was at the time it was the CEO calling his executive assistant order lunch. And we had that recorded. You could actually hear it. It was just as if it was, they were speaking to you.

So that’s a problem when you’re trying to keep secure communications between endpoints in a communication path. We wrote up the risk assessment. We presented it to the executives. We we presented the report up to my chain and it was simple.

Here’s the risk. Here’s the mitigation strategy. We need a business decision for the path that we wanted to take. And that generated quite the stir. My boss got back to me and said, well, we have to change the report. No, I said, no, we don’t. We don’t change this shit. We just, you you move it forward.

We’ve objectively uncovered the risk. The team did a fantastic job. But here’s an attached recording. If you want to hear it, but let’s keep moving forward. So it went up to the next level of management and same thing. Would you alter report? No, no I would not.

Move on, move on. Finally got to the chief security officer. And I remember getting the phone call. It’s like, well, Tim, this is, this is going to cause concerns. No, it’s a business decision. It isn’t about concerns. This is a business decision. And what risk is the business willing to accept?

So he submitted the report forward. Next thing I’m getting a call from, an executive office assistant telling me that my flight is going to be made for the next day. I’ll be, I’ll be flying to present the report. Like, Jesus Christ. So, all right, I got on a plane headed out east.

Waited forever to talk to the CEO at the time. And all they asked all they asked was, it is this real? are you is Would you change this? I said, no, the risk is legitimate.

And here’s the resolution. Here’s the mitigation path. Here’s the strategy. So they asked how much we needed, what we needed for time. it was about six months worth of work with the folks at Nortel to fix the problem. And all of that to state that had we done this old school many years ago, we would have just accepted the risk and move forward with it.

That wasn’t our role. That’s not our job, right? In that whole path, that whole risk assessment needed to presented to the point where executives understood what could potentially happen. We already proved that it could, but they needed to understand here’s the mitigation strategy. We found a way to resolve it.

We need this additional funding time resources to fix the problem. So that That stuck with me. That was like almost 20 years, like that was over 20 years ago. And that stuck with me because had I, altered my report, had I taken away the risk, had he accepted it on behalf of the security team, we don’t know what could have happened to the transmissions back and forth at the Olympics.

But I do know that in following that process, you never read about anyone’s conversations being intercepted at the 2010 Olympics, did you? It works. The process works, but what it takes is an understanding that from a risk perspective, this is the path that we have to take.

It’s not ours to accept. You have to make sure you get that to the executives and let them make that decision. Those are the stories that we need folks to hear now, as we move into this next phase of developing the profession of security.

Andrew Ginter
So Nate, you might ask, the CEO had a conversation, intercepted ordering lunch. Is this worth, the the big deal that it turned into? And I discussed this offline with with Tim and what he came back with is was, Andrew, think about it. Imagine that you’re nine days into the 10-day Summer Olympics or two week, whatever it is.

And someone, pick someone, let’s say the Chinese intelligence is found to have been intercepting and listening in on all of the conversations between the various nations, teams, coaches in the various sports and their colleagues back in their home countries.

They’ve been listening in on them for the the whole Olympics. What would that do to the reputation of the Olympics? What would that do to the reputation of Bell Canada? This is a huge issue. It was a material cost to fix. It took six months and he didn’t say how many people and how much technology.

But this is not something that the security team could say, “Okay, we don’t have any budget to fix this, therefore we have to accept the risk.” That’s the wrong business decision.

When he escalated this, it went all the way up to the CEO who said, yeah, this needs to be fixed. Take the budget, fix it. We cannot accept this risk as a business. That’s ah a business decision the CEO could make. It’s not a business decision he could make with the budget authority that he had four levels down in the organization.

Andrew Ginter
So fascinating stuff. Again, I look forward to stories in in the book. But you mentioned stories at the very beginning when you introduced TaleCraft. Can you tell me more about TaleCraft? How does this this idea of storytelling dovetail with with the work you’re doing right now?

Tim McCreight
When I was first designing this idea of what TaleCraft could be, we reached out to a good friend of ours here in Calgary, Mike Daigle. He does some amazing work. He spent some time just dissecting what I’ve done in my career and what I’ve accomplished. More importantly, some of the things that he wanted to focus on from company perspective.

And one of the the parts he brought up, and this is how TaleCraft was created, the word tail was I i spend a significant amount of my time now telling stories and it’s to help educate and to inform and stories to influence and and to provide meaning and value to executives.

But the common theme for all of this has been this concept of telling a story. One of the things I found throughout my career is as security professionals move through the ranks, as they begin, junior levels, moving into their first role as management and moving into director positions and eventually chief positions, the principles and the concepts of being able to tell a story or to communicate effectively with executives,

I found that some of my peers weren’t doing a great job or they were, I don’t know about you, Andrew, but if you sit in a ah presentation that someone’s giving and if all you’re reading is the slide deck, Jesus, you could just send that to me. I got this. I don’t need to spend time watching you stagger through a slide deck or the slides that have a couple of thousand words on them that you’re expecting us to read from 40 feet away.

It doesn’t happen. So what really bothered me is that we started losing this skillset of being able to tell a story. And to effectively use the principles of storytelling to provide input to executives, to make decisions for things like budget or resourcing or allocating, staff resources, et cetera.

So that’s one of the things that we do at TaleCraft is we teach security professionals and others, the principle and the concept of storytelling and how the story arc, those three parts to a story arc that we learned as kids, the beginning of the story, the middle where the conflict occurs, the resolution, and finally the end of the story, when, when you’re closing off and heading back to the village, after you slayed the dragon, those three things that we have, we learned as kids, they still apply as an adult because we learn as human beings through stories. We have for hundreds of years, thousands of years, used oral history as a way to present a story from one generation to the next.

We can use the same skill sets when we’re talking to our executives, when we’re explaining a new technique to our team, or when we’re giving an update in the middle of an incident and how you’re going to react to the next problem and how you’re going to solve it.

Those principles exist. It’s reminding people of what the structure is, teaching people how to follow the story arc when they’re presenting their material, taking away the noise, the distractions and everything else that gets in the way when listening to a story, but focus on the human.

And that’s one of the things that we’re doing here Telegraph is we’re teaching people to be more human in their approach and the techniques work. I just, My wife is up in Edmonton doing a conference right now for the CIO c Conference for Canada.

And she actually asked me to, this is a first folks, for all those of you who are married, what what kind of a progress I’ve made. My wife actually asked if I could dissect her presentation and help her with it. I thought that was pretty amazing. We restructured it so that she was able to use props.

She brought in a medical smock and and a stethoscope to talk about one of the clients that she worked with. And it sounds like it worked because she got some referrals for folks in the audience and she’s spending time right now talking to more clients up in Edmonton. So yeah, I crossed my fingers I was going to get through that one and it seemed to have worked. But these principles of telling a story, if you have a chance to understand how a story works and you’re able to replicate that in a security environment, all of a sudden now you’re speaking from a human to a human.

You’re not bringing in technology. You’re not talking about controls. You’re not spewing off all of these different firewall rules that we have to go through. Nobody cares about that stuff. What they want to hear is what’s the story and can I link the story to risk?

And at the top end of that arc, can I provide you an opportunity to reduce the risk and then finish the story by asking for help? If we can do that, those types of presentations throughout my career, that’s when I’ve been the most successful is when I can focus on the story I need to tell, get the executives as part of it and focus on the human reaction to the problem that we have.

That’s one of the things that we’re teaching at TaleCraft.

Andrew Ginter
So that makes sense in principle. Let me let me ask you. I mean, I do a lot of presentations. I had an opportunity to present on a sort of an abstract topic at S4, which is the currently the world’s biggest OT security-focused conference. And, if you’re curious, it was the title was “Credibility Versus Likelihood.” So, again, a very sort of abstract, risky, risk-type topic.

And the the the advice I got from Dale Peterson, the organizer, was, “Andrew, I see your slides. You can’t just read the slides. You’ve got to come to this presentation armed with examples for every slide, for every second slide.”

Tim McCreight
Yep.

Andrew Ginter
“Get up there and tell stories.” so I would give examples. Sometimes they would be attack scenarios. is that is that the same kind of thing here?

Tim McCreight
It is, I think. you And congratulations for for being asked to present at that conference. That’s amazing. So so kudos to you. That’s that’s awesome, Andrew. That’s great to hear. But you’re right. You touched on one of the things that a lot of presentations lack is the credibility or how I view the person providing the presentation. Do they have the authority? Do I look at them as someone who’s experienced and understands it?

And you do that by telling the story and providing an example for, let’s say, an attack scenario where you saw how it unfolded, how you’re able to detect it, how are you able to contain it, eradicate it, recover back. Those are the stories that people want to hear because it makes it real for people. Providing nothing but a technical description of an attack or bringing out, us as an example, a CVE and breaking it down by different sections on a slide. Oh my God, I would probably poke my eye out with a fork.

But if you walk me through how you identified it, The work that you guys did to identify, to detect it, to contain it, to eradicate it, and then recover. it If you can walk me through those steps from a personal example that you’ve had, that to me is the story.

And that’s the part that gets compelling is now you’ve got someone who’s got real world experience, expertise in this particular problem. They were able to solve it and they provide to me in a story. So now I can pick up those parts. I’m going to remember that part of the presentation because you gave me a great example, which is really, you gave me a great story. Does that make sense?

Andrew Ginter
It does to a degree. Let me Let me distract you for a moment here. I’m not sure this is I’m not sure this is the same the same topic, but I’ve, again, i’ve I’ve written a bit on risk.

Tim McCreight
Okay.

Andrew Ginter
You know I’ve tried to teach people a bit about what what is risk, how do you manage risk in in especially critical infrastructure settings. And I find that a lot of risk assessment reports are, it seems to me not very useful. They’re not useful as tools to make business decisions.

You get a long list of, you still have 8,000 unpatched vulnerabilities in your your your OT environment. Any questions? To me what business decision makers understand more than a list of 8,000 vulnerabilities is attack scenarios.

And so what I’ve argued is that every risk assessment should finish or lead, if you wish, with a in In physical security, you’re you’re probably more familiar this than I am, the the concept of design basis threat, a description of the capable attack you must defeat. You’re designed to defeat with a high degree of confidence.

And you look at your existing security posture and decide this class of attack we defeat with a high degree of confidence. These attacks up here, we don’t have that high degree of confidence.

And and what I’ve argued you should tell the story. Go through one or two of these attack scenarios and say, here is an attack that we would not defeat with a high degree of confidence. Is it acceptable that this attack potential is out there? Is that an acceptable risk?

Is that Is that the kind of storytelling we’re talking about here, or have I drifted off into some other space?

Tim McCreight
No, I think you’ve actually applied the principles of telling a story to something as complex as identifying your particular response or your organization’s response to ah either an attack a attack scenario or a more sophisticated attack scenario. So no, I think you’ve you’ve nailed it.

What it does though, in the approach that you just talked about, It gives a few things to the business audience. One, you have a greater understanding of the assets that are in place and how they apply to the business environment, right? Whether it’s in a physical plant structure for OT or whether it’s a pipeline, et cetera.

If you understand the environment that is being targeted, understand the assets that are in place and the controls that you have there in place, that gives you greater a greater understanding and foundations for what is the potential risk.

By telling the story then of what a particular attack scenario looks like, And if you have a level of confidence that you’d be able to protect against it, you’d be able to walk through the different parts of the story arc.

This is the context of the attack. This is what the attack could look like. Here’s how we would try to resolve it if we can. And then here’s the closing actions that we would be focused on if the attack was either successful or unsuccessful.

So all of those things, I think, apply to the principles of telling a story. What you’ve given is a great example of how to take something that’s very technical or, the the typical risk assessment I’ve seen in my career where, that Andrew here, here’s your 200 page report, the last 10, last hundred pages are all the CVEs we found.

And let us know if you need any help. Well, that doesn’t help me. But if you walk me through a particular example where here is in this one set of infrastructure, we’re liable or we’re open to this type of attack.

I think that’s amazing because it gives the executives the story they need. You understand the assets. Here’s the risk. Here’s the potential impact. Here’s what we can and cannot do to defeat or defend against this.

And then we need your help if this is a risk that you can’t accept. So no, I think you’ve covered all parts of what would be an appropriate story arc for using that type of approach. And honest to God, if you could get more folks to include that in reports, I would love to see that because I’m like you, I i have read too many reports that don’t offer value.

But the description you just provided and the way we break it down, that offers huge value to executives moving forward.

Nathaniel Nelson
Tim’s spending a lot of time emphasizing the importance of storytelling in conveying security concepts to the people who make decisions. Andrew, in your experience, is this sort of thing something you think about a lot? Do frame your your information in the same ways that he’s talking about, or do you have a different sort of approach?

Andrew Ginter
This makes sense to me. it’s sort of a step beyond what I usually do. So I’m i’m very much thinking about what he’s done and and how to use it going forward. But just to give you an example, close to a decade ago, I came out with a report, the “Top 20 Cyber Attacks on Industrial Control Systems.”

And it wasn’t so much a report looking backwards saying what has happened. It’s a report looking at what’s possible, what kind of capabilities are out there. And I tried to put together a spectrum of attack scenarios with a spectrum of consequences. Some of the attacks were very simple to carry out and had almost no consequence.

Some of them were really difficult to carry out and would take you down hard and cost an organization billions of dollars or dozens of lives. And everything in between.

And I did that because, in my experience, business decision makers understand attack scenarios, better than they understand abstract numeric risk metrics or lists of vulnerabilities.

But I described it as attack scenarios. In hindsight, I think really… what I was doing there was telling some stories and, I need to update that report.

I’m going to do it by updating it to read in more of a storytelling style so that, people can hear stories about attacks that they do defeat reliably and why, and attacks that they probably will not defeat with a high degree of confidence and what will be the consequences so that they can make these business decisions.

Nathaniel Nelson
Yeah, and that sounds nice in theory, but then I’m imagining, you tell your nice story to someone in the position to make a decision with money and they come back to you and say, well, Andrew, your story is very nice, but why can’t we defeat all of these attack scenarios with the amount of money we’re giving you?

Nathaniel Nelson
What do you tell them at that point?

Andrew Ginter
That is a very common reaction, saying, “You’ve asked us where to draw the line. We draw the line above the most sophisticated attack, fix them all.” And then I explain what that’s going to cost.

They haven’t even really paid attention to the attack scenarios. They haven’t even asked me about the attack scenarios. I’ve just explained the concept of a spectrum. They said, yeah, put it on the very put the line on the top, fix them all. And then you have to explain the cost.

And they go, “Whoa. Okay, so what are these?” And they ask in more detail and you give them the simplest attack, the simplest story that you do not defeat with a high degree of confidence.

And you ask them, is that something we need to fix? And they say, “Yeah, that’s nasty. I could see that happening, fix that. What else do you got?” And you work up the chain and eventually you reach an attack scenario or two where they look at it and say, “That’s just weird.”

I mean, let me give you an extreme example. Imagine that a foreign power has either bribed or blackmailed every employee in a large company. What security program, what policy can this the the CEO put in place that will defend the organization? Well, there isn’t one. Your entire organization is working against you. Is that a credible threat? The business is probably going to say, no, this is why we have background checks.

A conspiracy that large, the government is going to, be you going to come in and, and and and arrest everyone. That’s not a credible threat. And so, the initial reaction might be, yeah, fix it all. Draw the line across the very top of the spectrum.

And when that becomes clear that you can’t do that, this is where you dig into the stories and they have to understand the the individual scenarios. And they will eventually draw the line and say, “These three here that you told me about, fix them.” The rest of them just don’t seem credible.

That’s the decision process that you need to to to go through. And you need to describe the attacks. And I think the right way to describe the attacks is is with storytelling.

Andrew Ginter
So, I mean, this all makes great sense to me. I mean, this is why I asked you to be a guest on the podcast. But let me ask you, a sort of the next level of detail at TaleCraft. If, I don’t know, a big business, a CISO, says, TaleCraft makes sense to me and they bring you in, what do you actually do? Do you do you run seminars? Do you review reports and give advice? what What does TaleCraft actually do if we if somebody engages with you?

Tim McCreight
So there are a couple of things that we can offer to organizations that bring us in that from a TaleCraft perspective. First, what we offer, let me talk about storytelling first. What we offer from the storytelling approach is we will go to the client site.

We will run workshops, anywhere from four-hour workshop to a two-day workshop. We will bring team members from the security group, as well as others that the security team interacts with. We’ll go over the principles of storytelling and the concepts of storytelling, how to be more mindful in your public speaking and in your preparation.

And we’ll spend the first day going through the theory and the concepts of telling a story and becoming a better public speaker. Then on the second day of the workshop, we we then ask all participants to stand up for up to 10 minutes and provide their stories.

At the end of each one of the sessions, we provide positive feedback and provide them opportunities to grow and experience more more storytelling opportunities. And then we close out the workshop We provide reports back to each of the individuals on how we observed them absorbing all of the content from day one, and then offer opportunities for individual mentoring and coaching along the way.

So that’s one of the first services we offer. The second, as we come into organizations, if a CISO or CSO contacts us and asks us for assistance, we can do everything from helping them redesign their security program using the principles of enterprise security risk management, review the current program that they have today, assess the maturity of the controls that they have in place, identify risks that are facing the organization at a strategic level. And then we can come in and help them map out and design path to greater maturity by assessing the culture of security across the organization as well, where we go out and interview stakeholders from across the organization, from different departments, different divisions, and different levels of employees in the organization and identify their perception of security, the value that security brings to the organization, and how the security team can become greater partners and trusted advisors to the company. That’s part of the work that we do at Telegram Security.

Andrew Ginter
I understand as well that you’re working with professional associations or or something. I mean, I know that in in Canada, there’s the Canadian Information Processing Society. It’s not security focused. Security is an aspect of information processing in in the IT space.

In Alberta, there’s APEGA, the Association for Professional Engineers, Geologists, Geophysicists. I would dearly love to see these professions embrace cybersecurity and establish professional standards for practitioners for what is considered acceptable practice so that there is sort of a minimum bar.

So tell me, you’re you’re working with these folks. what What is it that you’re doing? How’s that going?

Tim McCreight
Yeah, so this happened, I’ve been thinking about this for probably the last 20 some years, and it always bothered me that the security director, the CISO, et cetera, in an organization, if they did get a chance to come to a board meeting or to be invited to talk to executives, you got a 45 minute time slot. Most times it was less. You had a chance to drink the really good coffee, and then you were asked to leave the room, and that was your time.

Where your peers who were running other departments across the organization in legal, finance, HR, etc. They stayed the entire weekend to help map out the strategy for an organization. Yet we weren’t invited to that party.

And that kind of annoyed me for the last some years. So I took it upon myself to begin a journey and I brought some folks along with me. There’s about 15 of us now that are working on the concept of designing and developing the profession of security, focusing on Canada first, and then working through the Commonwealth model to all those countries that follow the Commonwealth parliamentary system.

And it it made sense to me. I couldn’t do much work when I was the president of ASIS 2023. I didn’t want to have any perceived conflict of interest or anything that I was doing. But what we looked at from this concept of designing the profession of security It’s an opportunity for thus those who call this our profession and want to be recognized as such to borrow some of the great work that KIPPS has done and that APEGA has done here in Alberta, KIPPS across the country, to recognize the path that they took, how they were recognized and established, how they developed their charters, et cetera.

So we’ve had an opportunity to chat with some folks from KIPPS, but also to look at the work that they’ve done. And I’ve had a chance to review APEGA and it made sense to me. So now, Spin forward to 2025. We have a group of individuals who are focused on designing and developing what we consider to be a model that will provide a professional designation for security professionals in Canada.

It’s an opportunity to demonstrate your expertise and your body of knowledge. It’s an opportunity to take all of the the designations that you’ve received from groups like ISC squared, ISACA, ASIS, et cetera, use them as stepping stones to the next level where you’re accepted as a professional designation so that a security designation, whatever we can land on for the post nominals would be recognized the same as an engineer or as a doctor or as potentially a lawyer.

It gives us the validation of our work that we do. It gives us the recognition of the value that security brings to an organization. And it ties together OT, IT, t cyber, physical, all of the different parts of makeup security. And it’s a chance for us to come under one umbrella. So the way I describe it is that, I’ve, For years, I said, I ran a department. It just happens to be security. Now we can say I’m a security professional and my expertise is in OT security or in forensics or in investigations or in a crime prevention through environmental design.

It gives us an umbrella designation for security and a chance to specialize. So a good friend of mine is a surgeon. He started off as a doctor and now he’s a thoracic surgeon. So whenever he recognizes himself is that, he’s a, he’s a doctor, my specialty is c thoracic surgery, and now he’s chief of thoracic surgery at Vancouver General Hospital. Super great guy, but the path he took was become a doctor, demonstrate your expertise, spend more time to create your specialty, focus on that, be recognized for that. And now that’s his designation.

I want to do the same here in Canada for security. The reason why is, look, you and I both know this, Andrew, and we’ve we’ve seen this. If I go do a risk assessment for a client or internally, and if I do a bad job, I just go to the next client.

But if we have a doctor or a lawyer who mishandles a file or mishandles an operation or is liable for their actions, they’re held accountable to it. We are not. What I want to be able to do is put in the standards that demonstrate the level of our expertise, that we’re held accountable for our actions, that we maintain our credentials throughout our career, that we’re able to give back to the profession of security, and that if something does happen, we’re actually accountable for the work that we do.

And think that’s important, right? like here in our new house, an engineer stamped our plans. He’s accountable for the work he did. Why can’t we have the same for security? I think we need to, because then that provides executives a greater understanding of how important the work that we do every day to secure your organization so that you can achieve your goals and objectives.

That that’s what I’ve been doing on the side of my desk for the past 20 years. I finally got some breathing room to do it now with a TaleCraft giving me the space to do it. So I’m, I’m looking forward to trying to roll this thing out between now and the end of the year, at least the structure of it, and then we engage more people to get their comments and their perceptions so that we’re trying to reflect and represent as many folks as we can across the security profession.

Andrew Ginter
Well, Tim, this has been tremendous. Again, I look forward to to your book. Hopefully you find some time to work on it. Before we let you go, can I ask you to sum up for us? What are the what what should we take away from from the discussion we’ve had in the in the episode here and and use it going forward?

Tim McCreight
Thank you for that. I appreciate it. And yeah, fingers crossed, I can get working on the book over the summertime. That’s my goal. But for this particular episode, I think a couple of things. One, as security professionals, it’s not our job to accept the risk. It’s our job to identify it, provide a mitigation strategy, and present it back to executives. So that’s that’s one of the things that I want to keep stressing for everybody. Our role is to be an advisor to the organization.

It’s not to accept the risk on behalf of the organization. Second is, We all have a story to tell. We all understand the value and the power of a story. We all see how important it is when we tell a story to our executives, to our leaders, to our teams, and to others.

You need to focus on those skill sets of how to tell a story, particularly in the role of security, because not everyone understands the value that we bring. and the second annual and then And the last point for me is that You need to continue to look for mentors, for instructors, for trainers who can offer you these skill sets and you can provide this type of training for you so that you can continue to build your career.

We can’t do this alone. but You need to make sure that you have an opportunity to reach out to folks that can help you, whether it’s looking at your security program and trying to build it on a risk-based approach or teaching people the value of telling a story and then applying those skills the next presentation you give to executives. If folks remember those things, that’d be terrific.

So for those folks listening to the podcast today, if those points resonate with you, and if you’re looking for opportunities to learn more about telling a story or how to be effective doing that, how to look at your program from a risk-based approach and how to find mentors that can help you in your career path, reach out to TaleCraft Security.

This is what we do. It’s our opportunity to give back to the profession of security, to help organizations build their security programs, and to grow the skill sets of people who want to learn more about telling a story, becoming a better security leader, or understanding the concepts of a risk-based approach to security.

That’s what we’re here at TaleCraft for us, to help, to give back, and to grow.

Nathaniel Nelson
Andrew, that seems to have done it with your interview with Tim. Do you have any final word you would like to say gazelle today?

Andrew Ginter
Yeah, I mean, I think this is a really important topic. I see way too many security teams saying, this is my budget. This is all I have budget to I do not have budget to solve that problem. Therefore, I will accept the risk of that problem. And, especially for new projects, for risks that that we’ve never considered before, you That is often the wrong decision.

When we have new kinds of decisions to make, we need to escalate those decisions to the people who assign budget. We need to tell those people stories so they understand the risk. We have to get the right information, the right stories to the right people so they can make the right decisions. Saying, I have no budget, therefore I’m going to accept the risk many times is the wrong decision for the business. And we cannot afford to be making those wrong decisions time and again.

As the threat environment becomes more dangerous, as consequences of of industrial cyber attacks increase, we need to be making the right decisions. And this seems an essential component of of making the right decisions.

Nathaniel Nelson
Well, thanks to Tim McCreight for that. And Andrew, as always, thank you for speaking with me.

Andrew Ginter
It’s always a pleasure. Thank you, Nate.

Nathaniel Nelson
This has been the Industrial Security Podcast from Waterfall. Thanks to every everyone out there listening.

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NIS2 and the Cyber Resilience Act (CRA) – Episode 142 https://waterfall-security.com/ot-insights-center/ot-cybersecurity-insights-center/nis2-and-the-cyber-resilience-act-cra-episode-142/ Mon, 18 Aug 2025 08:29:50 +0000 https://waterfall-security.com/?p=35094 NIS2 legislation is late in many EU countries, and the new CRA applies to most suppliers of industrial / OT computerized and software products to the EU. Christina Kieffer, attorney at reuschlaw, walks us through what's new and what it means for vendors, as well as for owner / operators.

The post NIS2 and the Cyber Resilience Act (CRA) – Episode 142 appeared first on Waterfall Security Solutions.

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NIS2 and the Cyber Resilience Act (CRA) – Episode 142

NIS2 legislation is late in many EU countries, and the new CRA applies to most suppliers of industrial / OT computerized and software products to the EU. Christina Kiefer, attorney at reuschlaw, walks us through what's new and what it means for vendors, as well as for owner / operators.

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“So NIS2 is focusing on cybersecurity of entities, and the CRA is focusing on cybersecurity for products with digital elements.” – Christina Kiefer

Transcript of NIS2 and the Cyber Resilience Act (CRA)  | Episode 142

Please note: This transcript was auto-generated and then edited by a person. In the case of any inconsistencies, please refer to the recording as the source.

Nathaniel Nelson
Welcome everyone to the Industrial Security Podcast. My name is Nate Nelson. I’m here with Andrew Ginter, the Vice President of Industrial Security at Waterfall Security Solutions, who’s going to introduce the subject and guest of our show today. Andrew, how’s going?

Andrew Ginter
I’m very well, thank you, Nate. Our guest today is Christina Kiefer. She is an Attorney at Law and a Senior Associate in the Digital Business Department of reuschlaw. And she’s going to be talking to us about cybersecurity regulation in the European Union. As we all know, NIST 2 is coming and there’s other stuff coming too.

Nathaniel Nelson
Then without further ado, here’s your conversation with Christina.

Andrew Ginter
Hello, Christina, and welcome to the podcast. ah Before we get started, can i ask you to say a few words, introduce yourself and your background, and tell us a bit about the good work that you’re doing at Reuschlaw.

Christina Kiefer
Yes, of course. So first of all, thank you very much for the invitation. I’m very happy to be in your podcast today. So, yeah, to me, my name is Christina Kiefer. I’m an attorney at law working as a senior associate at our digital business unit in the law firm reuschlaw.

Christina Kiefer
We are based in Germany and reuschlaw is one of Europe’s leading commercial law firms specialized in product law. And for more than 20 years, our team of approximately 30 experts has been advising companies in dynamic industries, both nationally but also internationally.

Christina Kiefer
And for me myself, in my daily work, I advise companies and also public institutions on yeah complex issues in the areas of data protection, cybersecurity, but also IT and contract law.

And one focus of my work is on supporting clients in introduction of digital products in the EU market. And also looking at the field of cybersecurity and IT law. Since my studies, I have already focused on IT law and cybersecurity. And yes, I have been involved in the legal development since since then in this area.

Andrew Ginter
Thank you for that. And our topic is, you know, the law in Europe for cybersecurity, its regulation. The big news in Europe is, of course, NIS2. And it’s not a law, it’s a directive to the the nation states to produce laws, to produce regulations. So every country is going to have its own laws. Can I ask you for an update? How’s that going? who’s Who’s got the law? I thought there was a deadline. do the do the Do the nations of Europe have this covered or or is it still coming?

Christina Kiefer
Yes, so it’s the last point, so it’s still coming. Some countries have already transposed NS2 Directive into national law, but also a lot of countries are still in the developing and the transposition yeah period.

And that that’s why we are yeah confusing because NIS2 Directive it’s already or has already been enforced since January 2023. and and also the deadline for the EU member states to impose the NIS2 directive international law was October 2024.

So because of that, because of a lot of member states haven’t transposed the NIS2 directive international law, the EU Commission has launched an infringement proceeding against 23 member states last fall in 2024. And this has led to some movements in some EU member states. So as of now, 10 countries have fully transposed this to international law.

So for example, Belgium, Finland, Greece or Italy. And then another 14 countries have published at least some draft legislation so far. And there you can call ah Bulgaria, Denmark and also Germany. And then there are also two countries, it’s Sweden and Austria, and those two EU member states, they have not published neither a draft or also a final national law. So there we have no public information available on their implementation status yet.

Andrew Ginter
And, you know, someone watching this from the outside with, you know, a command of English and of very limited command of German, is there sort of a standard place that a person like me looking at this from the outside could go to find all this stuff? Or is it on every country’s national website in a different language in a different location? Is is there any central repository of these rules?

Christina Kiefer
No, not yet at least. Maybe there will be some private websites where you can find all the different implementation information. But until until now, when you are a company, either you within the EU or also the EU, when you are providing your services into the EU market, you have to fulfill with the NIS2 directive. And this means you have to fulfill with the national laws in each EU member states.

And this is yeah a big challenge for all international companies because they have to check each national law of each EU member states and they have to check if they fall under the scope of application. And what is also very important that the different national laws have different obligations. So the NIS2 directive has a minimum standard which all national legislators have to fulfill But on top of this, some EU member states have imposed more obligations or ah portal for registration or new reporting obligations.

So you have to check for each EU member state. But here we can also help because we see in our daily work that this is a very, very hard yeah challenge for companies to check all the laws and also understand all the national laws. We offer a NIS2 implementation guide where you can get regularly updates on and an overview of how the different EU member states have transposed NIS2.

And yes, in addition to this, we also have a NIS2 reporting and obligation guide, especially looking at the reporting and registration obligations to see where you have to register in each EU member state, but guide So you can book our full guide, but we also post yeah some overviews on LinkedIn and our newsletter.

Andrew Ginter
So thanks for that. You touched on the yeah the the goal of NIS2 was to increase consistency among the nation states of Europe in terms of their cyber regulations, and in my understanding, to increase the strength of those regulations across the board. How’s that coming? Are the regulations that are coming out stronger than we saw with NIS2? And are they consistent?

Christina Kiefer
Well, it’s… correct that the idea behind NIS2 or the NIS2 directive was to create ah stronger and also more consistent cybersecurity framework across the whole EU and the EU market. And also the NIS2 directive should also cover a broad set of sectors for regulated companies. So there should be some consistency within the EU. but it’s an EU directive and not an EU regulation. So this means the NIS2 directive sets only a minimum standard to all EU member states that they can then transpose into national law. And that’s why EU member states are allowed also to go beyond if they want to. And some of the EU member states have already done this. this So what we’re seeing right now, looking at the national laws which have already been enacted and also looking at the draft of some national laws, we see quite a mixed picture. So we don’t see a whole consistency what a lot of companies were hoping for. We see more like a mixed picture with some countries like Belgium again, for example.

They have pretty much stuck to the core of the directive and haven’t added much on top. So there you are also for you as a company, you can ensure when you’re looking at this two directive or when you have already looked at this two directive, you can be yeah positive that you also fulfill the requirements of the law of Belgium. But on the other hand, looking for example, on Italy, they have expanded the the scope of application. So Italy has, for example, included a cultural sector as an additional regulated area. So the sector of culture hasn’t been mentioned in NIS2 directive at all. But Italy ah had the idea, well, we can regulate also the cultural sector. So that’s why they have also sort in yeah included it into their national law.

And also in France, you can see that they have imposed more obligations and also have broadened the scope of application of their national law. because here they have also widened up the regulated sectors and here they have added educational institutions, for example. We have a minimum set of standards set out in the NIS2 directive, but across the EU, looking at the national laws, we have a lot of national differences. And that’s why it’s very hard for companies to comply with the NIS2 directive or with the national laws within the EU market.

Nathaniel Nelson
One of the more interesting things that Christina mentioned there, Andrew, was Italy treating its cultural sector as like critical infrastructure, which sounds a little bit, it sounds very Italian, frankly.

Andrew Ginter
Well, I don’t know. It’s not just the Italians. The original, you know, this was back in the, I don’t know, the the late noughts. One of the original directives that came out of the American administration was… a list of critical infrastructures. And at the time it included something like national monuments as a critical infrastructure sector. And the justification was, you know, any monument or, you know, cultural institution that was that was seen as essential to national identity, national cohesions,

And then it disappeared in the 2013 update of what were ah critical national infrastructure. So it’s no longer on CISA’s list of critical infrastructures, but it used to be. And, you know, in terms of Italy, oh I don’t, you know, I don’t have a lot of information about Italy, but again, you might imagine that national monuments and certain cultural institutions are vital to sort of national identity. Think the Roman Colosseum. Should that be regarded as critical infrastructure? It’s certainly critical to tourism, that’s for sure. So that’s that’s what little I know about it.

Andrew Ginter
And in my recollection of NIS2, one of the changes was increased incident disclosure rules. Now, i’ve I’ve argued or I’ve speculated. we We did a threat report at Waterfall. We actually saw numbers sort of plateau in terms of incidents. I wonder, I speculate whether increased incident disclosure rules are in fact reducing disclosures because lawyers see that disclosing too much information can result in lawsuits. For instance, SolarWinds was sued for incorrect disclosures. And so they they i’m I’m guessing that that they… they yeah conclude that minimum disclosure is least risk. And if they get partway into an incident and say, this is not material, we don’t need to disclose it we’re not going to disclose it, we actually see fewer disclosures.

Can you talk about what’s happening with the the disclosure rules? are they How consistent are they? Multinational businesses, how many different ways do they have to file? And are we seeing greater disclosure or in your estimation, fewer disclosures because of these rules?

Christina Kiefer
Yeah, that’s a really good question and honestly it’s something we get also asked all the time right now because once we hear again all over if we operate in several and several EU countries do I need to report a security incident in one you member states or via one portal and then I’m fine or do I really have to report a security incident to each EU member states which is kind of affected with the with regard to the security incident.

And yeah, unfortunately, the answer right now is yes, you have to report your security incident to each EU member state or to each national authority of the EU member state, which you fall under the scope of the national law. Because the NIS2 directive does not really require one portal or one obligation registration and also a reporting portal for all EU member states. So it’s up to the national authorities and also up to the EU member states to regulate this field law. And you can see that many national authorities have already recognized this issue and they are also looking at ways to simplify the process of registration but also of reporting security incidents and there you can see some member states try to yeah at least include or to to set up a portal a national-wide portal where you can yeah report your security incident.

Some other national authorities go even further. They say they implement a yeah scheme or structure where you only have to report to them and then they will yeah transfer the report to the other relevant EU authorities. But again, this is each and in e in each EU member state national law, so then you also have to check again all the other national laws within the EU. Yes, but also the authorities of the EU member states have already, well, at least indicated that they are talking to each other. So maybe in the future we will get one portal to report everything. But as I said before, it’s not regulated in the NIS2 directive and is also not foreseen for now.

Yes, and to the other part of your question. You could think that when you’re obliged to report everything and each security incident that the reporting would decrease But you also have to look at a yeah at the at the risk of non-compliance and the risks are very high because the NIS2 directive is imposing high sanctions and also a lot of yeah authority measures, authority market measures. And that’s why in the daily consulting work, it’s better to say, please report an incident because also the national authorities communicate this to the companies. They say, please report something because then we can work together. So the focus of the national authorities, at least in Germany, we see right now is they want to cooperate together.

They want to ensure a cyber secure en environment and a cyber secure market. So the focus is to report something that they can yeah work on together and that’s why it would be better to report and I would say maybe we get also an increase of reporting.

Andrew Ginter
So I’m a little confused by your answer. the The rules that I’m a little bit familiar with are the American ah Securities and Exchange Commission rules. And those rules mandate that any material incident must be reported to the public, any incident that might cause a reasonable investor to either buy or sell or assign a value to shares in in a company.

Which means non-material incidents can be kept quiet. And the SEC disclosures are public. Everyone can see them because reasonable people need information to buy and sell shares. The NIS2 system, is it requiring all incidents to be reported? And are those reports public?

Christina Kiefer
That’s a good point. To your first part of your question, the NIS2 directive and also the reporting obligation is kind of the same as the regulation you mentioned before, because you have to report only severe security incidents. As a regulated company, you are obliged to check if there is a security incident in the first step and then the second step you have to check if there a severe security incident.

And only this security incident you are obliged to report to the national authorities. So that’s kind of the same structure or mechanism. And to the second part of your question, the report will not be published for everyone. So first of all, if you report it to national authorities, only the national authorities have the information. It can happen because we have in some Member States some laws where yeah people from the public can access or can get access to information, to public information. It can happen that some information will be publicly available. But the the first step is that you will only report it to the national authority and that the report will not be available for the public as such.

But next to the reporting obligation to the national authorities, you also have information obligations in the NIS2 directive. So it can happen that you are also obliged to inform the consumers of your services.

Andrew Ginter
So thanks for that. The other big news that I’m aware of in Europe is the CRA, which confuses me because I thought NIS2 was the big deal, yet there’s this other thing that sort of came at me out of the blue a year ago, and I’m going, what’s what’s going on? Can you introduce for us what is the CRA, and how’s it different from NIS2?

21:30.66
Christina Kiefer
Yeah, sure. So, as you mentioned before, the CRA is like the sister or brother and the second major piece. of the new European cybersecurity framework alongside the NIS2 Directive.

Christina Kiefer
It’s the Cyber Resilience Act, or for short CRA. And while the NIS2 Directive focuses on the cybersecurity requirements for businesses or entities in critical sectors, the CRA takes a different angle and the CRA introduces EU-wide cybersecurity rules for products.

So NIS2 is focusing on cybersecurity of entities and the CRA is focusing on cybersecurity for products with digital elements. And also the other difference is also that NIS2 directive, we have an EU directive, so it needs to be transposed into national law by each EU member state and the Cyber Resilience Act is an EU regulation So when the Resilience Act comes into force, it will apply directly in each EU member state.

Andrew Ginter
Okay, so that’s how the CRA fits into NIS2. What is the CRA? What are what are these rules? is it Can you give us a high-level summary?

Christina Kiefer
Yeah, sure. So the CRA is the EU-wide first horizontal regulation, which imposes cybersecurity rules for products with digital elements. So regulated are products with digital elements and this definition is very broad. It covers software and also hardware and also software and hardware components if they are yeah brought to the EU market separately. And products with digital elements are kind of like connected devices and as I said, software and hardware that can potentially pose a security risk. Also, what is very important, the CRA imposes obligations not only to manufacturers, but also to importers, distributors, and also to those companies which are not resident in the EU, because the main point for the geographical scope of application is that you place a product in the EU market, whether you are placed in the EU or not.

Christina Kiefer
So this means also that the Cyber Resilience Act, such as data and such as the General Data Protection Regulation, has a global impact impact for anyone selling tech products in Europe.

Andrew Ginter
So let me jump in real quick here, and Nate. What Christina‘s described here, oh you the CRA, the scope applies to all digital products sold in Europe. To me, this the CRA is, in my estimation, and she’s going to explain more in ah in a few minutes, it’s probably the strictest cybersecurity regulation for products generally in the whole world. it It sounds to me like this might become just like GDPR. This was ah a European regulation that came through a few years ago. It had to do with marketing and the use of private information, in particular my email and sending it. Basically, so it was like an anti-spam act. It’s the strictest in the world. And everybody who has any kind of worldwide customer base, which is almost everybody in the digital world that that’s sending out marketing emails, is now following the GDPR pretty much worldwide because it’s just too hard to apply one law in one country and one law in the other. So what you do is you pick the strictest that you have to comply with worldwide, which is the gp GDPR, and you do that. worldwide instead of trying to figure out what’s what. It sounds to me like the CRA could very well turn into that kind of thing. It might be the thing that all manufacturers that embed a CPU in their product have to follow worldwide because it’s just too hard to to change what they do in one country versus another.

Andrew Ginter
Okay, so can you dig a little deeper? I mean, an automobile, you buy a a ah new automobile from the from the dealership. My understanding is that it has 250, 300, maybe 325 CPUs in it, all of them running software. It would seem to me that ah a new automobile is covered by the CRA. what What are the obligations of the manufacturer? What should customers like me expect in automobiles that that might be different because of the CRA?

Christina Kiefer
Thank you. First of all, looking at your example, automobiles are not covered by the CRA, because the CRA some exemptions. And the CRA says, we are not regulating digital products with the digital elements, which are already regular regulated by specific product safety laws. And here, looking at the automotive sector, we have for sure in the EU very strong and very specialized regulation for product safety of cars and so on. So just for your example, but looking at other products with the chill elements, for example, wearables or headphones, smartphones, for example, you can say that there are kind of five core obligations for manufacturers in the CRA. So the first obligation is compliance with Annex 1, which means you have to fulfill a list of cybersecurity requirements. And you don’t only have to fulfill those cybersecurity requirements, but you also have declare and show compliance with Annex 1 of the CRA. So it’s a conformity assessment you have to undergo.

Christina Kiefer
The other application, number two, is cyber risk assessment. If you are a manufacturer of a product with digital digital elements, you are obliged to assess cyber risks and not only during the development and the construction of your product and also not only during the placing of your product to the EU market, but throughout the whole product life circle. So if you have a product and you have it already placed on the market, you are obliged to undergo cyber risk assessments. Then looking at the third obligation, it’s free security updates.

Christina Kiefer
So manufacturers have to provide free security updates throughout the expected product life cycle. We have also mandatory incident reporting. So we have here also reporting and registration obligations, such as we already talked about looking at the NISS2 directive. And also like in each product safety law in the EU, we also have the obligation for technical documentation. So this is of those are the five core obligations, compliance, cyber risk assessment, free security update, reporting and documentation.

Andrew Ginter
And you mentioned distributors. What are distributors and importers obliged to do?

Christina Kiefer
yeah there We have some graduated obligations. So they they are not such strict obligations such for manufacturers, but importers and distributors are obliged to assess if the product, what they are importing and distributing to the EU market are compliant with the whole set of cybersecurity requirements of the CRA. So they have to check if the manufacturer and the product is compliant and if not, They have to inform and yeah cooperate with the manufacturer to ensure cybersecurity compliance. But also importers are also obliged to yeah impose their own measures to to fu fulfill with the CRA.

Andrew Ginter
Okay, and you said there were five obligations. You spun through them quickly. Some of them make sense on their own. Do a risk assessment, do it from time to time, see if the risks have changed. That kind of makes sense. The first one, though, comply with Annex 1. That’s like an appendix to the CRA. What’s in there? what What are the obligations?

Christina Kiefer
Yes, sure. Annex 1 is, yeah the you can also say, Appendix 1 to the CRA. and And there are you can see there is a list of certain cybersecurity requirements which manufacturers have to fulfill. And the list is divided into two different main areas. And one area is cybersecurity requirements. So it focuses on no known vulnerabilit vulnerabilities at the time of the market placement, secure default configurations, protection against unauthorized access, ensuring confidentiality, integrity and availability, and also secure deletion and export of user data. So kind of all of cyber security requirements such as them which I have mentioned. And the other area is vulnerability management. So manufacturers have to ensure that they have a structured vulnerability management process and they have to yeah install a software bill of materials.

They have to provide free security updates. They have to undergo cybersecurity testing and assessments. there needs to be a process to publish information on resolved vulnerabilities. And again, here we also need a clear reporting channel for known vulnerabilities.

Andrew Ginter
So it sounds like you said that a manufacturer is not allowed to ship a product with known vulnerabilities. Practically speaking, how does that work? I mean, a lot of manufacturers in the industrial space use Linux under the hood. Linux is a million lines of code of kernel. And, you know, the, these devices don’t necessarily do a full desktop style Linux, but they still have a lot of code that they’re pulling from an open source distribution. And in these millions of lines of code, From time to time, people discover vulnerabilities and they get announced. And so it’s it’s almost a random process. Do I have to suspend shipments the day that a vulnerability a Linux vulnerability comes to light until I can get the thing patched and then three days later ah start shipments again? Practically speaking, how does this zero known vulnerabilities requirement work?

Christina Kiefer
Basically, it is like, as you said, because the Cyber Resilience Act focuses on known ah no known vulnerabilities not only in your product but also in the whole supply chain. So the Cyber Resilience Act focuses not only on products with digital elements but also focusing on the cybersecurity of the whole supply chain. So this means looking at Annex 1 and the cybersecurity requirements Products with digital elements may only be placed on the EU market if they don’t contain any known exploitable vulnerabilities. So it’s not any vulnerability, but it’s any known exploitable vulnerability. That is a clear requirement under Annex 1. And also when you’re looking at making a product available on a market, that doesn’t just mean selling it.

Christina Kiefer
It includes any kind of commercial activity. And also what is also a very good question also in our daily work, looking at making a product available on the market. A lot of companies say, well, I have a ah batch of products. So, and if I have placed this batch of products on the EU market, I have already placed product on the market. So I can also place the other products of this batch also in the future. But it is not correct, because looking at EU product safety law, the regulation is focusing on each product. So looking at these requirements, you can say, first of all you really have to check your own product, your own components, but also the products and the components you are using from the supply chain. And you have to check if there are any known exp exploitable vulnerabilities. So you have to yeah impose a process to check the known vulnerabilities and also to ah impose mechanisms to fix those vulnerabilities.

Christina Kiefer
And if you have products already on the market, you don’t have to recall them because first of all, it’s okay if you have a vulnerability management which is working and where you can fix those vulnerabilities. And when you have products already in the shipment process, there it’s up to each company to assess if they have to yeah recall products in the and the shipment process or if they say, okay, we leave it in the shipment process because we know we can fix the vulnerability within two or three days. So in the end, it’s kind of a risk-based approach and each company has to assess what measurements are yeah applicable and also necessary.

Andrew Ginter
So that that makes a little more sense. I mean, the Linux kernel and sort of core functions in my, but I don’t have the numbers, but I’m guessing that you’re going to see a vulnerability every week or two in that large set of software. And if that’s part of a router that you’re shipping or part of a firewall that you’re shipping or part of any kind of product that you’re shipping, Does it make sense that, you know, you discover the exploitable vulnerability on Thursday and you have to suspend shipment until, ah you know, three weeks out when you have incorporated the vulnerability in your build and you’ve repeated all of your product testing, which can be extensive.

Andrew Ginter
And by the time you’re ready to ship that fix, two other problems have been developed and now you have to, you can’t ship until, you know, it, It sounds like it’s not quite that strict. it’s not that That scenario sounds like nonsense to me. It just it would never work. You’re saying that there is some flexibility to do reasonable things to keep bringing product to market as long as you’re managing the vulnerabilities over time. Is is that fair?

Christina Kiefer
Yes, yes, that’s right. Because in the CRA we have a risk-based approach and also you have to… No, the basis for each measure you have to to impose under the CRA is your cyber risk assessment. So you have to check what kind of product am I using or am i manufacturing? Which kind of product am I right now placing on the EU market? What are the cybersecurity risks right now? And also what what are the specific cybersecurity risks of this known vulnerability?

Christina Kiefer
And then you have to check, have i do I have a process? Do I have a process imposing appropriate measures to to fix those vulnerabilities? And if I have appropriate measures, to fix the vulnerabilities in a timely manner, then it’s not the know you are not obliged to recall the product itself. But at the end, looking at a risk-based approach, it’s up to the decision of each company.

Andrew Ginter
So this is a lot of a lot of change in in for a lot of product vendors. Can I ask you, how’s it going? Is it working? Are are the vendors confused? can you Do you have any sort of insight in into how it’s going?

Christina Kiefer
Yeah, sure. So what we’re seeing right now, a lot of companies, both manufacturers, but also suppliers, are getting ahead of the curve when it comes to the Cyber Resilience Act, because they see that there is a change and there there will be new strict obligations, not only on manufacturers, but also in the whole supply chain. So suppliers, distributors, importers are also coming to us and asking if they are under the scope of the CRA. So this is the first point. If you’re a distributor or an importer, you already have to check if you and your company itself falls under the scope of the CIA. And if it is like this, then you are already obliged to ensure all the obligations of the CRA. But it can also happen that suppliers are under the scope of the CRA in an indirect manner.

Because ensuring all those new cybersecurity requirements from a manufacturer point of view, you have to ensure it within the whole supply chain. And the main instrument to ensure this was already in a future in a and the past and will also be in the future is contract management. So you have to impose or transpose all those new obligations to the suppliers via contract management. And there we see different reactions, but there’s definitely a growing awareness that cybersecurity needs to be addressed contractually, especially in relation to the CRA obligations. And yeah looking at contract negotiations, of course, we have some negotiations with the suppliers And one of the main points which is negotiated is the regulation of enforcement.

Christina Kiefer
Because when you have contractual management looking at cybersecurity requirements, you can not only yeah transpose those obligations to the suppliers, but you also have rules on enforcing those new contractual obligations. For example, contractual penalties. And there we see that contractual penalties often sparks some debate during negotiations. But to sum up, in practice, we’ve always been able to find a balanced solution that works for all parties involved.

Nathaniel Nelson
I suppose I could think about any number of potentially trivial electronics products, Andrew, but let’s say that I or my neighbor has ah a smart fridge, a fridge with a computer it. We generally assume that those devices don’t even really have security in mind at all. And a security update is like so far from the universe of how anyone would interact. with such a device and now we’re saying that that kind of thing is going to be regulated in these ways.

Andrew Ginter
I think the short answer is yes. You might ask, what good does this regulation do for a fridge? And, you know, I think about this sometimes. I think the answer is it depends. If, you know, a lot of the larger home appliances nowadays have touchscreens. There’s a CPU inside. There’s software inside. These are cyber devices. You might ask, well, when was the last time I updated the firmware in my fridge? How many times am I going to update the firmware in my fridge? Those are good questions. Most people never think about something like that. But the law might… you know, very reasonably apply to the fridge if the fridge is connected to the Internet so that I can see, for example, how much power my fridge is using on my cell phone app.

Isn’t that clever? But now I’ve connected the fridge to the Internet. We all know what what happened to, what was it, the Mirai botnet took over hundreds of thousands of Internet of Things devices and and used them as attack tools for denial of service attacks. If you’ve got an internet connected fridge, you risk that if you haven’t updated the software. Worse, if someone gets into your fridge, takes over the CPU, you could change the set point on the temperature and cause all your food to spoil. This is a safety risk.

Andrew Ginter
Again, how many consumers are going to update the software in their fridge? Realistically, I don’t think… You the majority of consumers will, even if there is a safety threat. To me, you know, the risk, this this is part of the risk assessment. If there’s a safety threat because of these vulnerabilities, you might well need to… I don’t know, auto-update the firmware. That might be part of your risk assessment so that the consumer doesn’t have to do it. Or better yet, design the fridge so that safety threats because of a compromised CPU are impossible, physically impossible. Make the the temperature setting manual or something. But this is this is a bigger problem than I think one regulation, the the the question of safety critical devices connected to the cloud.

Nathaniel Nelson
Yeah, admittedly, the the notion of a smart refrigerator safety threat isn’t totally resonating with me. And then we haven’t even discussed the matter of like, OK, let’s say that my refrigerator gets automatic updates or I just have to click a button in an app when it notifies me to do so to update my firmware. At some point, you know, fridges sit in houses for long periods of time. I can’t recall the last time that my fridge has been replaced. In that time, any manufacturer could go out of business. And then how do you get those updates, right?

Andrew Ginter
Exactly. So, you know, to me, but this is outside the scope of the CRA, but, you know, to answer your question, to me, the solution you know, two or threefold, we we need to design safety-critical consumer appliances in such a way that the unsafe conditions cannot be brought about by a cyber attack. I mean, we talk about, you know, fixing known vulnerabilities. That’s only one kind of vulnerability. What about zero days? There is, there’s there’s logically no way that someone can, you solve all zero days. It it It’s a nonsensical proposition. So there’s always going to be zero days. What if one is exploited and, you know, a million fridges set to a ah set point that that’s unsafe?

Andrew Ginter
To me, we’ve got to design the fridges differently, but that’s that’s sort of a different conversation. In fact, that’s the topic of my next book, but which is why I care so much about it. but but it’s These are important questions, and I think the CRA is a ah step in the direction of answering them, but I don’t know that it has all the answers.

Andrew Ginter
So work with me. you know, what, what you described there makes sense for, you know, manufacturers like, uh, IBM who can, you know, produce high volumes of, or, you know, Sony or the, the big fish. But, you know, if I’m a small manufacturer, I produce a thousand devices a year. I buy components for these devices. I buy software for these devices from big names like Sony and Microsoft and Oracle. And, you know, I go to Oracle and say, you must meet my contract requirements or I won’t buy my thousand products from you at a cost of $89 a product. Oracle is going to say, take a flying leap. We’re not signing your contract. Is this realistic?

Christina Kiefer
Yes, and we see this also in practice because we are not only consulting the big manufacturers but are also the smaller companies in the supply chain. And there you can have different approaches because when you are buying products from the big companies, First of all, you have to know that they are or they might be obliged also under the CRA. So they are fulfilling all those new cybersecurity requirements. And you also have to take it though there you also have to check their contracts because there you can see already they have a lot of new regulations looking at cybersecurity, either if it’s implemented into the the general contractual documents or implemented into one cybersecurity appendix.

So you see all the companies are looking at the Cyber Resilience Act and then they are taking measures and also looking at their contract management. So if you are lucky enough, you can see, okay, they have a contract which is already regulating all the obligations under the CIA. And then if it’s not like this, We take the approach that we establish a cybersecurity appendix. So when you’re already a contractual relationship with the big players, you don’t have to negotiate the whole contract from the beginning. You can only show them your appendix and then on on basis of this appendix, you can discuss the cybersecurity requirements. So this is kind of a approach which has helped also smaller companies in the market.

Andrew Ginter
So you gave the example of of headphones and smartphones. For the record, does this apply to industrial products as well? I mean, our our listeners care about programmable logic controllers and steam turbines that have embedded computer components, or is it strictly a ah consumer goods rule? Now, and this is a very important point to highlight, the Cyber Resilience Act explicitly applies not only to consumer products but also to products in the B2B sector. so this means that all software and all hardware products along with any related remote data processing solutions fall under the scope of the CRA, either in B2C or also in B2B relationships.

Andrew Ginter
Well, Christina, thank you so much for joining us. Before we let you go, can I ask you, can you sum up for our listeners? What are the the key messages to take away to understand about what’s happening with cyber regulations, both NISU and CRA in Europe, and and what we should be doing about them as both consumers and manufacturers?

Christina Kiefer
Yeah, sure, of course. So let me give you a quick recap. So first of all, you see the EU legislature is tightening the cybersecurity requirements significantly with both the NIS2 directive and also the Cyber Resilience Act. And the new requirements affect any company that offers products or services to the EU market, no matter where they are based. So it is it has a very broad scope of application. Looking at the NIS2 directive, it’s very important to know that the NIS2 directive is already enforced, but it has to be transposed into national law, which has not been fulfilled by all EU member states, and that the national implementation across the EU is still quite varied.

Looking at the Cyber Resilience Act, the CRA brings new security obligations to products with digital elements, so for all software, for all hardware products. And it also is focusing not only on cybersecurity on products, but also in the whole supply chain. So both frameworks require companies to take proactive steps right now, looking at risk assessment, risk management, reporting, and also contract management, particularly when it comes to managing their supply chain. So looking at the short implementation deadlines ahead, both from the NIS2 Directive and also the CIA, it’s very important for companies to act now. And the first step we consult to do is to identify the relevant laws, because we have a lot of new regulations looking at digital products and digital services. So, yeah first of all, check the relevant laws and the relevant obligations which are applicable to your business.

And here we offer a free NIS2 quick check and also a free CRA quick check where you can just click through the different questions to see if you are under the scope of NIS2 and CRA. And then after all, when you clarified that you are affected on the one or both of the new regulations, the company needs to review and adopt their cybersecurity processes, both technically and also organizationally. So it’s very crucial to continuously monitor and ensure compliance with the ongoing legal requirements, especially also looking at contract management and focusing on the supply chain. And yeah, there we can help national but also international companies with kind of a 360 degree approach to cybersecurity compliance because we enter ensure solutions with the range from product development and marketing to reporting and market measures. So, yeah, we we give companies ah practical and also actionable guidance in ah in an every step way.

So looking at the first step to to act and yeah to identify the relevant laws and obligations to your business, companies can yeah visit our free NIS2 QuickCheck and our free CRA QuickCheck, which is available under nist2-check.com and also And yeah, if you have any further question, you are free and invited to write to me via email via LinkedIn. Yeah, I’m happy to connect. And thank you very much for the invitation.

Nathaniel Nelson
Andrew, that just about concludes your interview with Christina Kiefer. And maybe for a last word today, we could just talk about what all of these rules mean practically for businesses out there because, you know, it’s one thing to mention this rule and that rule in a podcast, but sounds like kind of stuff we’re talking about here is going to mean a lot of work for a lot of people in the future.

Andrew Ginter
I agree completely. It sounds like a lot of new work and a lot of new risk, both for the critical infrastructure entities that are covered by NIST or by the local laws, especially for for businesses, the larger businesses that are active in multiple jurisdictions, and certainly for any manufacturer who wants to sell anything remotely CPU-like into the the the European market. It sounds like a lot of work, but I have some hope that it’s also, because it’s such a lot of work, it’s also a business opportunity. And we’re going to see entrepreneurs and service providers and even technology providers out there providing services and tools that will automate more and more of this stuff so that not every manufacturer and every critical infrastructure provider can. in the European Union or in the world selling to the European Union. Not every one of them has to invent all of this the the answers to these these new rules by themselves.

Nathaniel Nelson
Well, thank you to Christina for elucidating all of this for us. And Andrew, as always, thank you for speaking with me.

Andrew Ginter
It’s always a pleasure. Thank you, Nate.

Nathaniel Nelson
This has been the Industrial Security Podcast from Waterfall. Thanks to everyone out there listening.

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The post NIS2 and the Cyber Resilience Act (CRA) – Episode 142 appeared first on Waterfall Security Solutions.

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