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Economics and Software Bills of Materials (SBOM)

In an article for The Hill, Shannon Lantzy and Kelly Rozumalski have discussed how Software Bill Of Materials (SBOMs) are good for business as well as security. SBOMs more forcefully emerged on the American policy space after the Biden Whitehouse promulgated an Executive Order on cybersecurity on May 12, 2021. The Order included a requirement that developers and private companies providing services to the United States government be required to produce Software Bill of Materials (SBOM).1 SBOMs are meant to help incident responders to cybersecurity events assess what APIs, libraries, or other digital elements might be vulnerable to an identified operation, and also help government procurement agencies better ensure the digital assets in a product or service meet a specified security standard.

Specifically, Lantzy and Rozumalsko write:

Product offerings that are already secure-by-design will be able to command a premium price because consumers will be able to compare SBOMs.

Products with inherently less patchable components will also benefit. A universal SBOM mandate will make it easy to spot vulnerabilities, creating market risk for lagging products; firms will be forced to reengineer the products before getting hacked. While this seems like a new cost to the laggards, it’s really just a transfer of future risk to a current cost of reengineering. The key to a universal mandate is that all laggards will incur this cost at roughly the same time, thereby not losing a competitive edge.

The promise of increased security and reduced risk will not be realized by SBOM mandates alone. Tooling and putting this mandate in practice will be required to realize the full power of the SBOM.

The idea of internalizing security costs to developers, and potentially increasing the cost of goods, has been something that has been discussed publicly and with Western governments for at least two decades or more. We’ve seen the overall risk profiles presented to organizations continue to increase year over year as a result of companies racing to market with little regard for security, which was a business development strategy that made sense when they experienced few economic liabilities for selling products with severe cybersecurity limitations or vulnerabilities. In theory, enabling comparison shopping vis-a-vis SBOMs will disincentivize companies from selling low-grade equipment and services if they want to get into high-profit enterprise or high-reliability government contracts, with the effect being that security improvements will also trickle down to the products purchased by consumers as well (‘trickle down cybersecurity’).

While I think that SBOMs are definitely a part of developing cybersecurity resilience it remains to be seen just how much consumers will pay for ‘more secure’ products given that, first, they are economically incentivized to pay the lowest possible amounts for goods and services and, second, they are unlikely to know for certain what is a good or bad security practice. Advocates of SBOMs often refer to them as akin to nutrition labels but we know that at most about a third of consumers read those labels (and those who read them often experience societal pressures to regulate caloric intake and thus read the labels) and, also, that the labels are often inaccurate.

It will be very interesting to see whether enterprise and consumers alike will be able or willing to pay higher up-front costs, to say nothing of being able to actually trust what is on the SBOM labels. Will companies that adopt SBOM products suffer a lower rate of cybersecurity incidents, or ones that are of reduced seriousness, or be able to respond more quickly when a cybersecurity incident has been realized? We’re going to actually be able to test the promises of SBOMs, soon, and it’s going to be fascinating to see things play out.


  1. I have a published a summary and brief analysis of this Executive Order elsewhere in case you want to read it. ↩︎
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Operation Fox Hunt

(Photo by Erik Mclean on Pexels.com)

ProPublica’s Sebastian Rotella and Kirsten Berg have an outstanding piece on the Chinese government’s efforts to compel individuals to return to China to face often trumped up charges. Efforts include secretly sending Chinese officials into the United States to surveil, harass, intimidate, and stalk residents of the United States, and also imprisoning or otherwise threatening residents’ family member who have remained in China.

Many of the details in the article are the result of court records, interviews, and assessments of Chinese media. It remains to be seen whether Chinese agents’ abilities to conduct ‘fox hunts’ will be impeded now that the US government is more aware of these operations. Given the attention and suspicion now cast towards citizens of China, however, there is also a risk that FBI agents may become overzealous in their investigations to the detriment of law-abiding Chinese-Americans or visitors from China.

In an ideal world there would be equivalent analyses or publications on the extent to which these operations are also undertaken in Canada. To date, however, there is no equivalent to ProPublica’s piece in the Canadian media landscape and given the Canadian media’s contraction we can’t realistically expect anything, anytime soon. However, even a short piece which assessed whether individuals from China who’ve run operations in the United States, and who are now barred from entering the US or would face charges upon crossing the US border, are similarly barred or under an extradition order in Canada would be a positive addition to what we know of how the Canadian government is responding to these kinds of Chinese operations.

Aside

2021.7.26

I’ve created a series of recipes for my Fuji X100F and it’s been immensely satisfying to capture images and they look exactly the way I want, with no editing required aside from minor crops. Definitely check out Fuji X Weekly if you want to get started yourself!

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Alarmist Takes On Chinese Influence Operations Must Be Set Aside

Lotus Ruan and Gabrielle Lim have a terrific piece in Just Security ‌which strongly makes the case that, “fears of Chinese disinformation are often exaggerated by overblown assessments of the effects of China’s propaganda campaigns and casually drawn attributions.”

The two make clear that there are serious issues with how some Western policy analysts and politicians are suggesting that their governments respond to foreign influence operations that are associated with Chinese public and private parties. To begin, the very efficacy of influence operations remains mired in questions. While this is an area that is seeing more research of late, academics and policy analysts alike cannot assert with significant accuracy whether foreign influence operations have any real impact on domestic opinions or feelings. This should call for conservatism in the policies which are advanced but, instead, we often see calls for Western nations to adopt the internet ‘sovereignty’ positions championed by Russia and China themselves. These analysts and politicians are, in other words, asserting that they only way to be safe from China (and Russia) is to adopt those countries’ own policies.

Even were such (bad) policies adopted, it’s unclear that they would resolve the worst challenges facing countries such as the United States today. Anti-vaxxers, pro-coup supporters, and Big Lie advocates have all been affected by domestic influence operations that were (and are) championed by legitimately elected politicians, celebrities, and major media personalities. Building a sovereign internet ecosystem will do nothing to protect from the threats that are inside the continental United States and which are clearly having a deleterious effect on American society.

What I think I most appreciated in the piece by Ruan and Lim is that they frankly and directly called out many of the so-called solutions to disinformation and influence operations as racist. As just one example, there are those who call for ‘clean’ technologies that juxtapose Western against non-Western technologies. These kinds of arguments often directly perpetuate racist policies; they will not only do nothing to mitigate the spread of misinformation but will simultaneously cast suspicion and violence towards non-Caucasian members of society. Such proposals must be resisted and the authors are to be congratulated for directly and forcefully calling out the policies for what they are instead of carefully critiquing the proposals without actually calling them as racist as they are.

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Standards as the Contemporary Highway System

Jonathan Zittrain, in remarks prepared a few weeks ago, framed Internet protocol standards in a novel way. Specifically, he stated:

Second, it’s entirely fitting for a government to actively subsidize public goods like a common defense, a highway system, and, throughout the Internet’s evolution, the public interest development of standards and protocols to interlink otherwise-disparate systems. These subsidies for the development of Internet protocols, often expressed as grants to individual networking researchers at universities by such organizations as the National Science Foundation, were absolutely instrumental in the coalescence of Internet standards and the leasing of wholesale commercial networks on which to test them. (They also inspired some legislators to advertise their own foresight in having facilitated such strategic funding.) Alongside other basic science research support, this was perhaps some of the best bang for the buck that the American taxpayer has received in the history of the country. Government support in the tens of millions over a course of decades resulted in a flourishing of a networked economy measured in trillions.

Zittrain’s framing of this issue builds on some writing I’ve published around standards. In the executive summary of a report I wrote a few months ago, I stated that,

… the Government of Canada could more prominently engage with standards bodies to, at least in part, guarantee that such standards have security principles baked in and enabled by default; such efforts could include allocating tax relief to corporations, as well as funding to non-governmental organizations or charities, so that Canadians and Canadian interests are more deeply embedded in standards development processes.

To date I haven’t heard of this position being adopted by the Government of Canada, or even debated in public. However, framing this as a new kind of roadway could be the kind of rhetorical framing that would help it gain traction.

Repurposing Apple Time Capsule as a Network Drive

(Photo by MockupEditor.com on Pexels.com)

For the past several years I’ve happily used an Apple Time Capsule as my router and one of many backup drives, but it’s been getting a big long in the tooth as the number of items on my network has grown. I recently upgraded to a new router but wanted to continue using my Time Capsule, and it’s very large drive, for LAN backups.

A post in Apple’s discussion forums helpfully kicked off how to reset the wireless settings for the Time Capsule and prepare it to just live on the network as a drive. After following those instructions, all I needed to do was:

  1. Open Time Machine Preferences on my device;
  2. Select ‘Add or Remove Backup Disk…’;
  3. Select the freshly networked disk;
  4. Choose to use the pre-existing backup image, and input the encryption password for the backup.

Voila! And now my disk–with all its data–is available on the network and capable of continuing my Time Machine backups!

The Kaseya Ransomware Attack Is a Really Big Deal

Screen Shot 2021-07-19 at 2.26.52 PM
(Managed Service Provider image by the Canadian Centre for Cybersecurity)

Matt Tait, as normal, has good insights into just why the Kaseya ransomware attack1 was such a big deal:

In short, software supply chain security breaches don’t look like other categories of breaches. A lot of this comes down to the central conundrum of system security: it’s not possible to defend the edges of a system without centralization so that we can pool defensive resources. But this same centralization concentrates offensive action against a few single points of failure that, if breached, cause all of the edges to fall at once. And the more edges that central failure point controls, the more likely the collateral real-world consequences of any breach, but especially a ransomware breach will be catastrophic, and cause overwhelm the defensive cybersecurity industry’s ability to respond.

Managed Service Providers (MSPs) are becoming increasingly common targets. It’s worth noting that the Canadian Centre for Cybersecurity‘s National Cyber Threat Assessment 2020 listed ransomware as well as the exploitation of MSPs as two of the seven key threats to Canadian financial and economic health. The Centre went so far as to state that it expected,

… that over the next two years ransomware campaigns will very likely increasingly target MSPs for the purpose of targeting their clients as a means of scaling targeted ransomware campaigns.

Sadly, if not surprisingly, this assessment has been entirely correct. It remains to be seen what impact the 2020 threats assessment has, or will have, on Canadian organizations and their security postures. Based on conversations I’ve had over the past few months the results are not inspiring and the threat assessment has generally been less effective than hoped in driving change in Canada.

As discussed by Steven Bellovin, part of the broader challenge for the security community in preparing for MSP operations has been that defenders are routinely behind the times; operators modify what and who their campaigns will target and defenders are forced to scramble to catch up. He specifically, and depressingly, recognizes that, “…when it comes to target selection, the attackers have outmaneuvered defenders for almost 30 years.”

These failures are that much more noteworthy given that the United States has trumpeted for years that the NSA will ‘defend forward‘ to identify and hunt threats, and respond to them before they reach ‘American cybershores’.2 The seemingly now routine targeting of both system update mechanisms as well as vendors which provide security or operational controls for wide swathes of organizations demonstrates that things are going to get a lot worse before they’re likely to improve.

A course correction could follow from Western nations developing effective and meaningful cyber-deterrence processes that encourage nations such as Russia, China, Iran, and North Korea to punish computer operators who are behind some of the worst kinds of operations that have emerged in public view. However, this would in part require the American government (and its allies) to actually figure out how they can deter adversaries. It’s been 12 years or so, and counting, and it’s not apparent that any American administration has figured out how to implement a deterrence regime that exceeds issuing toothless threats. The same goes for most of their allies.

Absent an actual deterrence response, such as one which takes action in sovereign states that host malicious operators, Western nations have slowly joined together to issue group attributions of foreign operations. They’ve also come together to recognize certain classes of cyber operations as particularly problematic, including ransomware. Must nations build this shared capacity, first, before they can actually undertake deterrence activities? Should that be the case then it would strongly underscore the need to develop shared norms in advance of sovereign states exercising their latent capacities in cyber and other domains and lend credence to the importance of the Tallinn manual process . If, however, this capacity is built and nothing is still undertaken to deter, then what will the capacity actually be worth? While this is a fascinating scholarly exercise–it’s basically an opportunity to test competing scholarly hypotheses–it’s one that has significant real-world consequences and the danger is that once we recognize which hypothesis is correct, years of time and effort could have been wasted for little apparent gain.

What’s worse is that this even is a scholarly exercise. Given that more than a decade has passed, and that ‘cyber’ is not truly new anymore, why must hypotheses be spun instead of states having developed sufficient capacity to deter? Where are Western states’ muscles after so much time working this problem?


  1. As a point of order, when is an act of ransomware an attack versus an operation? ↩︎
  2. I just made that one up. No, I’m not proud of it. ↩︎

Vaccination, Discrimination, and Canadian Civil Liberties

Photo by Karolina Grabowska on Pexels.com

Civil liberties debates about whether individuals should have to get vaccinated against Covid-19 are on the rise. Civil liberties groups broadly worry that individuals will suffer intrusions into their privacy, or that rights of association or other rights will be unduly abridged, as businesses and employers require individuals to demonstrate proof of vaccination.

As discussed in a recent article published by the CBC, some individuals are specifically unable to, or concerned about, receiving Covid-19 vaccines on the basis that, “they’re taking immunosuppressant drugs, for example, while others have legitimate concerns about the safety and efficacy of the COVID-19 vaccines or justifiable fears borne from previous negative interactions with the health-care system.” The same expert, Arthur Schafer of the Centre for Professional and Applied Ethics at the University of Manitoba, said, “[w]e should try to accommodate people who have objections, conscientious or scientific or even religious, where we can do so without compromising public safety and without incurring a disproportionate cost to society.”

Other experts, such as Ann Cavoukian, worry that being compelled to disclose vaccination status could jeopardize individuals’ medical information should it be shared with parties who are not equipped to protect it, or who may combine it with other information to discriminate against individuals. For the Canadian Civil Liberties Association, they have taken the stance that individuals should have the freedom to choose to be vaccinated or not, that no compulsions should be applied to encourage vaccination (e.g., requiring vaccination to attend events), and broadly that, “COVID is just another risk now that we have to incorporate into our daily lives.”

In situations where individuals are unable to be vaccinated, either due to potential allergic responses or lack of availability of vaccine (e.g., those under the age of 12), then it is imperative to ensure that individuals do not face discrimination. In these situations, those affected cannot receive a vaccine and it is important to not create castes of the vaccinated and unable-to-be-vaccinated. For individuals who are hesitant due to historical negative experiences with vaccination efforts, or medical experimentation, some accommodations may also be required.

However, in the cases where vaccines are available and there are opportunities to receive said vaccine, then not getting vaccinated does constitute a choice. As it stands, today, in many Canadian schools children are required to received a set of vaccinations in order to attend school and if their parents refuse, then the children are required to use alternate educational systems (e.g., home schooling). When parents make a specific choice they are compelled to deal with the consequences of said decision. (Of course, there is not a vaccine for individuals under 12 years of age at the moment and so we shouldn’t be barring unvaccinated children from schools, but adopting such a requirement in the future might align with how schools regularly require proof of vaccination status to attend public schools.)

The ability to attend a concert, as an example, can and should be predicated on vaccination status where vaccination is an option for attendees. Similarly, if an individual refuses to be vaccinated their decision may have consequences in cases where they are required to be in-person in their workplace. There may be good reasons for why some workers decline to be vaccinated, such as a lack of paid days off and fear that losing a few days of work due to vaccination symptoms may prevent them from paying the rent or getting food; in such cases, accommodations to enable them to get vaccinated are needed. However, once such accommodations are made decisions to continue to not get vaccinated may have consequences.

In assessing whether policies are discriminatory individuals’ liberties as well as those of the broader population must be taken into account, with deliberate efforts made to ensure that group rights do not trample on the rights of minority or disenfranchised members of society. Accommodations must be made so that everyone can get vaccinated; rules cannot be established that apply equally but affect members of society in discriminatory ways. But, at the same time, the protection of rights is conditional and mitigating the spread of a particularly virulent disease that has serious health and economic effects is arguably one of those cases where protecting the community (and, by extension, those individuals who are unable to receive a vaccine for medical reasons) is of heightened importance.

Is this to say that there are no civil liberties concerns that might arise when vaccinating a population? No, obviously not.

In situations where individuals are unhoused or otherwise challenged in keeping or retaining a certification that they have been vaccinated, then it is important to build policies that do not discriminate against these classes of individuals. Similarly, if there is a concern that vaccination passes might present novel security risks that have correlate rights concerns (e.g., a digital system that links presentations of a vaccination credential with locational information) then it is important to carefully assess, critique, and re-develop systems so that they provide the minimum data required to reduce the risk of Covid-19’s spread. Also, as the population of vaccinated persons reaches certain percentages there may simply be less of a need to assess or check that someone is vaccinated. While this means that some ‘free riders’ will succeed, insofar as they will decline to be vaccinated and not suffer any direct consequences, the goal is not to punish people who refuse vaccination and instead to very strongly encourage enough people to get vaccinated so that the population as a whole is well-protected.

However, taking a position that Covid-19 is part of society and that society just has to get used to people refusing to be vaccinated while participating in ‘regular’ social life, and that this is just a cost of enjoying civil liberties, seems like a bad argument and a poor framing of the issue. Making this kind of broader argument risks pushing the majority of Canadians towards discounting all reasons that individuals may present to justify or explain not getting vaccinated, with the effect of inhibiting civil society from getting the public on board to protect the rights of those who would be harmfully affected by mandatory vaccination policies or demands that individuals always carry vaccine passport documents.

Those who have made a choice to opt-out of vaccination may experience resulting social costs, but those who cannot opt to get a vaccine in the first place or who have proven good reasons for avoiding vaccination shouldn’t be unduly disadvantaged. That’s the line in the sand to hold and defend, not that protecting civil liberties means that there should be no cost for voluntarily opting out of life saving vaccination programs.

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Does Canada, Really, Need A Foreign Intelligence Service?

A group of former senior Canadian government officials who have been heavily involved in the intelligence community recently penned an op-ed that raised the question of “does Canada need a foreign intelligence service?” It’s a curious piece, insofar as it argues that Canada does need such a service while simultaneously discounting some of the past debates about whether this kind of a service should be established, as well as giving short shrift to Canada’s existing collection capacities that are little spoken about. They also fundamentally fail to take up what is probably the most serious issue currently plaguing Canada’s intelligence community, which is the inability to identify, hire, and retain qualified staff in existing agencies that have intelligence collection and analysis responsibilities.

The Argument

The authors’ argument proceeds in a few pieces. First, it argues that Canadian decision makers don’t really possess an intelligence mindset insofar as they’re not primed to want or feel the need to use foreign intelligence collected from human sources. Second, they argue that the Canadian Security Intelligence Service (CSIS) really does already possess a limited foreign intelligence mandate (and, thus, that the Government of Canada would only be enhancing pre-existing powers instead of create new powers from nothing). Third, and the meat of the article, they suggest that Canada probably does want an agency that collects foreign intelligence using human sources to support other members of the intelligence community (e.g., the Communications Security Establishment) and likely that such powers could just be injected into CSIS itself. The article concludes with the position that Canada’s allies “have quietly grumbled from time to time that Canada is not pulling its weight” and that we can’t prioritize our own collection needs when we’re being given intelligence from our close allies per agreements we’ve established with them. This last part of the argument has a nationalistic bent to it: implicitly they’re asking whether we can really trust even our allies and closest friends? Don’t we need to create a capacity and determine where such an agency and its tasking should focus on, perhaps starting small but with the intent of it getting larger?

Past Debates and Existing Authorities

The argument as positioned fails to clearly make the case for why these expanded authorities are required and simultaneously does not account for the existing powers associated with the CSE, the Canadian military, and Global Affairs Canada.

With regards to the former, the authors state, “the arguments for and against the establishment of a new agency have never really been examined; they have only been cursorily debated from time to time within the government by different agencies, usually arguing on the basis of their own interests.” In making this argument they depend on people not remembering their history. The creation of CSIS saw a significant debate about whether to include foreign human intelligence elements and the decision by Parliamentarians–not just the executive–was to not include these elements. The question of whether to enable CSIS or another agency to collect foreign human intelligence cropped up, again, in the late 1990s and early 2000, and again around 2006-2008 or so when the Harper government proposed setting up this kind of an agency and then declined to do so. To some extent, the authors’ op-ed is keeping with the tradition of this question arising every decade or so before being quietly set to the side.

In terms of agencies’ existing authorities and capacities, the CSE is responsible for conducting signals intelligence for the Canadian government and is tasked to focus on particular kinds of information per priorities that are established by the government. Per its authorizing legislation, the CSE can also undertake certain kinds of covert operations, the details of which have been kept firmly under wraps. The Canadian military has been aggressively building up its intelligence capacities with few details leaking out, and its ability to undertake foreign intelligence using human sources as unclear as the breadth of its mandate more generally.1 Finally, GAC has long collected information abroad. While their activities are divergent from the CIA or MI6–officials at GAC aren’t planning assassinations, as an example–they do collect foreign intelligence and share it back with the rest of the Government of Canada. Further, in their increasingly distant past they stepped in for the CIA in environments the Agency was prevented from operating within, such as in Cuba.

All of this is to say that Canada periodically goes through these debates of whether it should stand up a foreign intelligence service akin to the CIA or MI6. But the benefits of such a service are often unclear, the costs prohibitive, and the actual debates about what Canada already does left by the wayside. Before anyone seriously thinks about establishing a new service, they’d be well advised to read through Carvin’s, Juneau’s, and Forcese’s book Top Secret Canada. After doing so, readers will appreciate that staffing is already a core problem facing the Canadian intelligence community and recognize that creating yet another agency will only worsen this problem. Indeed, before focusing on creating new agencies the authors of the Globe and Mail op-ed might turn their minds to how to overcome the existing staffing problems. Solving that problem might enable agencies to best use their existing authorizing legislation and mandates to get much of the human foreign intelligence that the authors are so concerned about collecting. Maybe that op-ed could be titled, “Does Canada’s Intelligence Community Really Have a Staffing Problem?”


  1. As an example of the questionable breadth of the Canadian military’s intelligence function, when the military was tasked with assisting long-term care home during the height of the Covid-19 pandemic in Canada, they undertook surveillance of domestic activism organizations for unclear reasons and subsequently shared the end-products with the Ontario government. ↩︎