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This is the AmpicCyber Critical Assets Podcast. Each episode we cover important OT and ICS

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security topics with an eye towards standards and regulation to keep you ahead of your adversaries

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and your auditors.

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Hey everyone, welcome back to the Critical Assets Podcast. I am Patrick Miller and with

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me today I have Leslie Carhartt, also known as Hacks for Pancakes and I am just thrilled

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to have you on. I've got so many questions, I'm so interested in what you're doing. And

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let's just start by telling us a little bit about yourself for the audience that doesn't

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already know who you are.

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Hi everybody, my name is Leslie Carhartt and thank you for having me, Patrick. It's nice

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to be here. I am an OT cybersecurity professional. I've been doing that for quite a long time.

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Specifically, I work for a company called Dragos and at Dragos we specialize in industrial

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and critical infrastructure cybersecurity and I work specifically there in incident response

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and digital forensics for systems like power plants and mines and transportation that have

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been compromised by various types of adversary groups.

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Awesome. So keeping the people safe from the big machines.

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I'm certainly trying to do that. That's important to me.

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Fantastic. Well, on that same thread, these systems are definitely different than IT,

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right? They're very different. What are some of the unique challenges for incident response

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and forensics in OT generally? Like, can you do the same things that you would do in IT

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in the OT world and if not, why?

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Incident response is stunningly different in OT. Yes, we use some of the same forensic

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tools to do investigations of malware and compromises and computers and things like

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that, but there's some things that just make it a completely different way of life. The

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first one, of course, is process consequences. Everything. When you're talking about physical

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kinetic systems like industrial control systems, you're talking about things that can kill

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people. They can cause critical services to fail if they aren't there, like water, power,

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things like that. They can also harm operators. They can cause environmental damage, facility

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damage. They do physical stuff in the real world.

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So everything that we do in cybersecurity in OT, we have to do with these process consequences

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in mind. And so when you're talking about a system that's been compromised, there's

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a whole bunch of extra considerations that go into the response and recovery efforts

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like how long can the system be down without people dying? How long can we operate on manual

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operations without any of the computers before things start failing? And then there's a side

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of the investigation too. What tools can I safely run in these computers that aren't

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going to cause a worse consequence? You're not going to find EDR or XDR on a bunch of

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industrial hosts. You just can't do that on a lot of vendor and older hosts. Even on newer

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hosts, they have to operate in a very structured, vendor approved way to operate safely. So

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limited security tooling and oftentimes very old systems with very, very legacy security

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tooling and the forensics tools we have to use in those hosts are very old as well. If

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we're talking about Windows XP or older Windows 95, I see on a routine basis, Windows NT.

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So old school forensics, sometimes very manual forensics, and then very judicious risk decisions

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about what we can and can't do and how much time we actually have to do those forensics

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efforts.

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What do you mean by time? So talk to me about that.

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Sure. So everything in a process, when you're talking about business continuity and process

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operations, everything comes down to time. Time of how fast the process functions, how

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many widgets you produce, how much power you put out per minute, per hour, per day, et

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cetera. And that ties into your bottom line of whether you can stay in business or not.

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And then time in terms of how long you can safely run without your computers. The computers

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that I'm talking about, the industrial control digital systems I'm talking about are things

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that provide telemetry. So making sure systems are operating safely and effectively and efficiently.

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They provide process efficiency. And a lot of human beings have been removed from the

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mix and a lot of process environments and their roles of keeping things running smoothly

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have been replaced by computers. So switching back to manual operations is a big deal. And

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then even more beyond that, some things like modern micro grids and smart grids are so

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complicated and mathematically complex that they have to be run long-term by computers.

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So there's the timeframe there of how long can we have these systems down, pulling images

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from them, investigating who's compromised them, figuring out what they did, how long

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before we just have to start swapping things out with an adversary still in the system

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to keep people alive. Everything comes down to these time and risk decisions in our investigations.

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Okay. And in some cases, I assume there are even situations where you just can't take

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them down, right? You're going to have to do this in a live operating environment.

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Yeah. I mean, there's a lot of it depends in what I tell customers when they call me

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in on what's usually their worst day ever. And that comes down to what do you need? Do

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you need to be up and running in two hours or somebody dies or you go out of business?

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Can we spend 24 hours doing an investigation? Things like that. Those are tough conversations.

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And in talking about these immature environments where there's less logging and very old systems

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that have less forensic detail, all those things play into how much I can actually say

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about what the adversary did. Oftentimes these incidents and these more legacy and less defended

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environments are detected very, very late. I'm talking about months or years after the

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initial intrusion. So I do my best. I have to use a lot of manual, very advanced old

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school forensics to pull things out of the ether to try to tell people what the root

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cause was in the initial point of intrusion. And sometimes I can't. Sometimes it was too

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long ago. Sometimes we just have to get things up and running. And I collect the forensic

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evidence I can to do a very manual investigation on after the system's been restored. And

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that's a very hard decision to make because you start restoring things on a system that

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say a state adversary or criminal adversary group is still in. They're going to respond

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to that. They see restoring the systems. If they still have access when the internet connectivity

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is restored, they're just going to destroy things again. So very complicated decisions

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to make with the leadership in those organizations, with the safety personnel, with the external

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experts on that industrial system, and with my colleagues and peers in forensics and intelligence.

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Okay. This sounds incredibly challenging. So these organizations, I know that they vary

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in terms of maturity and skill sets and technologies, but generally speaking, if you had to pick

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like, you know, top three, top five, what are the things that you think they could do

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better to enable you to do your job easier? Like when you walk in, what are the things

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you wish or you hope they have ready for you or the capabilities that they have for you

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to use to actually make your life easier to help them?

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Start with the basics. There's a white paper out through SANS called the five critical

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controls for industrial cybersecurity. And they name things like basic architectural

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controls, vulnerability management, remote access control, having some fundamental incident

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response plan and some fundamental security monitoring and logging. And those are things

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that you build onto over time. You start with the very basic elements of those five capacities

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and start with something. Give me something to work with. Give me anything. Give me some

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logging. Give me some architectural diagram, some asset inventory, some idea of how your

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environment is connected to remote access. Anything helps. If I don't have those foundational

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details at the beginning of one of these very critical response efforts, I have to go find

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that stuff. And that's time in these. I was talking about how important time is when you're

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talking about restoring a perhaps crippled industrial environment. Time is crucial and

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you don't want me at incident response rates having to build you a network map. And so

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think about those very foundational things like understanding your environment, building

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some segmentation in it, doing some logging, some monitoring, having some plan of what

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you'll do if you do see something nefarious. Anything is better than nothing there.

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Excellent. Okay. That's fantastic advice. Totally agree. Well, in general, I mean, the

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critical infrastructure organizations, OT organizations, and I'm going to generalize

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this just globally because I know I both work on a global scale. Which sectors do you think

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are leading or lagging in general? Kind of curious to get your take.

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Yeah. So it usually has to directly equate to the funding of the organizations. So it's

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not necessarily related to the size of the organizations either. It's how much money

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they spend on IT and cybersecurity. So the ones that have the most money for cybersecurity,

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the best resources are usually like the large oil and gas firms and some of the very large

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electric utilities. There's some legislative pressure there to do cybersecurity and they

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also have money and they're willing to invest that money, that margin on cybersecurity,

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on preventative controls. So they generally in the range of things are doing better. And

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then you have like municipal utilities that are also doing very important things like

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making sure we have safe drinking water and our toilets flush and garbage goes away and

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transportation works, our traffic lights work. And a lot of those are very underfunded organizations

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in general. They're small municipal organizations. They maybe have one or two IT people and things

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are much, much more challenging there. Things are prioritized in terms of keeping the water

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running instead of spending money on margins of things for cybersecurity. So that's one

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of the scariest spaces for people who are professionally in this field. If you're talking

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about like manufacturing, even like big manufacturing firms oftentimes have big problems with industrial

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cybersecurity because of the low margins, even though they can make a lot of profit

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and be very large companies, they don't tend to invest as much in IT because that's not

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green dollars coming in. That's an expense. That's a cost center. So we see problems there

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as well. This is generalization. So I mean, we see variation in organization size and

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global locations in those various industries. And the thing I do want to express is that

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spending a bunch of money and having a bunch of people in your cybersecurity program is

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good, but it's not necessarily a complete defense against intrusions. I respond to incidents

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in those organizations too. They have their own challenges. But in general, the industries

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that concern most of us, and I don't know if you agree with this, municipal utilities,

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things like water, sewage, any power that's handled by a small co-op, things like that.

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Those are scary spaces that do really important stuff and don't have many resources for cybersecurity.

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Yeah, I would generally agree. And I would also say the same where I've seen very large

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organizations that have spent lots of money on a wide range of tools and they've got even

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multiple divisions within a security department. And they still suffer from, in some cases,

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fundamental issues where I've seen some smaller organizations, even in some of these co-ops,

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for example, that they've got just a superstar one or two people that can do an amazing job

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with limited tool sets. So people that are there and the investment from senior leadership

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in how much they care about cybersecurity and stand behind those people. And in general,

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sometimes you can be more agile as a small organization. So don't feel defeated if you

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are that small organization. You have potential to do really interesting things too.

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Yeah, absolutely. Now in these sectors, like I agree, I've seen a lot in the electric sector,

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oil and gas space as well. They do have generally deeper pockets. I would see them definitely

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leading, especially in front of local water utilities, even in some cases like rail and

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manufacturing and shipping, mining. Yeah. Now, just globally, I wanted to bring a little

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bit of a global aspect. Which areas do you see are more advanced or further along, shall

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I say? I hate using the word mature or advanced, but I guess further along on their security

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journey than other areas.

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Well, I mentioned like oil and gas tends to be very, very well-resourced. They have a

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lot to protect and they've invested a lot in their IT programs and in their cybersecurity

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programs and they're willing to have larger margins in these things that aren't direct

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income. So yeah, so that's usually one where cybersecurity is quite strong. Again, there's

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still problems there when you have that large of an organization and oil and gas tends to

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be very distributed operations with a lot of different facilities, remote facilities

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that make cybersecurity very challenging. When you're talking about like platforms out

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in the ocean, that's a tough one. That's a really hard thing to secure, but they tend

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to do quite a bit better. When we're talking about like electric utilities, that depends

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on how they're regulated and organized in different parts of the world, whether they're

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centralized, whether they're a bunch of different companies, whether they're small co-ops, if

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there's a lot of like independent generations, smart grids, et cetera, that changes things.

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But in general, beyond those verticals, it tends to be the organizations that have good

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management buy-in and a willingness to have that cost center of cybersecurity that put

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organizations ahead of other organizations. Okay. Yeah. And I'm even thinking in terms

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of a global perspective, like in some cases it's been regulatory driven and in other places

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it's been market driven. So I've seen situations where, oh, let's say higher threat locations

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obviously go for a higher security profile, right? And then there's other areas where

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just the regulation in that region or that country have caused the whatever sector to

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do more. In the U.S. of course we have NERC SIP for the electric sector. We have the TSA

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pipeline security directives for our gas space. There's been talk about the water sector.

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In Europe they have more of a general approach overall with the NIS2. And then of course

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each individual member state has their own quasi, that's a quasi that I almost direct

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in some cases specific to state things like German DSI or UK has a framework like the

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CAF, Australia has their own CSF. Any of those that you see are really kind of, I guess becoming

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more of the standard to which others should look to, I guess is the best way to ask the

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question. I think that there's a lot of good things coming out of Europe and the U.S. and

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Australia. I'm always a very cautious person on critical infrastructure cybersecurity regulation.

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And I'll tell you why. It's because oftentimes I see two problems. The first one is that

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it's very strategic and it doesn't actually provide tactical details. So strategic in

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terms of who owns what, who's in charge of what and very, very high level directives

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that can be interpreted in a lot of different ways. And I understand why they do that because

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there's so much variety and variation and debate about how to do a lot of these things.

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But I do wonder about the efficacy in some of those cases where it's just very, very

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high level and strategic. But the bigger concern to me is when things are regulated without

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providing resources to do them. Again, thinking back to like the small municipal utilities,

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those water utilities, they got one IT person, maybe half an IT person, maybe they're an

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operator the other half of their time. And you're going to tell them to do a bunch of

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installing EDR patching or installing elaborate network controls. That's going to take away

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from something else. Have you thought about what that's going to take away from? Is that

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going to stop them from doing monitoring? Is it going to stop them from responding to

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trouble tickets from the operators who see stuff happening? What is that going to take

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away from if you don't give them tools and actual functional resources to do that cybersecurity?

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So anytime I see regulation like that come into play, I also want to see at least good

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educational resources being provided to those utilities. More preferential would be giving

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them monetary resources, incident response resources, tooling, licenses for tooling to

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do things that you're legislating. This stuff is expensive. It's hard to do. OT cybersecurity

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is hard and it costs money. And again, if you're regulating stuff, that money and those

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people are coming from somewhere. So be very cautious about that. But in general, I mean,

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to answer your question, there's a lot of good ideas in that legislation. They are reaching

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out to industry. They're reaching out to specialists in the field in most of those countries. And

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they're thinking about, again, those kinds of critical control things like, gosh, we

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really need to control remote access. We really need to make sure that we understand vulnerabilities

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in these environments. We really need to segment. Yeah, that's all really important stuff. But

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again, doing that is not easy. You think it's hard in enterprise. It's really hard in a

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legacy industrial environment that you can't shut down. So a lot of considerations to go

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into that. And I wish there was a little bit more tactical recommendations and resources

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coming out from those countries too. Yeah. I have the joy of having written regulation

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and then they forced it. So I've seen what it looks like on the other side too. It's

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really difficult to write regulation in a tactical way because technology moves so fast

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and threat actors change their tactics so quickly. So you're basically forced to write

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it strategically. It's a difficult balance. But one thing I am seeing on a regular basis,

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I would say commonly through much of the regulation that leans into the critical infrastructure

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spaces in an OT and our world is definitely a push for good incident response. One of

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the things I've debated with Danielle Czaponski on a previous podcast was if you had to write

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one regulation, if you just had the capability to write one, what would it be? And we both

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kind of circled around the concepts of just incident response or just threat hunting.

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I see how they kind of go both hand in hand, but I have seen this as such a common thread

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through a lot of these different regulations across multiple countries and regions. And

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when I ask those that are writing it or influencing it, it seems to come down to the fact that

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there, of course, many companies will not report an incident on the street, right? To

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any federal agency or to the news or to anywhere, basically other than even to their shareholders

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in some cases. It just, if it only goes up and out to the places, it absolutely must.

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So given that we've got a really bad and patchwork and misleading set of actuarial data. So we

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know that if Leslie eats bacon cheeseburgers every day and never exercises, watches TV

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and is extremely sedentary, there's a chance that you're going to die by 40. But we know

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this because of the actuarial data we have on humans and healthcare for like, you know,

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arguably a thousand years or more. We have, you know, in some cases, not only, you know,

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none, but misleading data in this space. And this is what they're trying to do is what's

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working and what's not. What's actually being effective and what isn't. So these regulations,

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when I ask about them, this is what they're trying to get to is how do we get this information?

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So barring, you know, asking and getting inconsistent, well, as a euphemism, inconsistent answers,

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regulation and forcing it out of them is pretty much the only way. So that's where we're seeing

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a lot of this incident response regulation or standardization in some cases around it.

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So do you think this is even a good idea given what you do? This is your world and you do

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this every day. So is this something they can do? Is this a good idea? Is this useful

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for the regulatory bodies?

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I'll start with for the audience. I do this every day. I am an incident responder for

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industrial systems. I am busy enough and I have been for the last seven years at Dragos

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that this is what I do every day. There is a lot more going on in the industrial incident

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space than people see on the news. And all the things that you described are true. Nobody

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wants to have a big eye incident. They don't want to report it to their board. They don't

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want to have to report it to regulators. They don't want to get dinged for whatever they

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think they were responsible for in the intrusion, even if they weren't. And so that really is

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a thing. There is a resistance to reporting incidents when there's no regulatory requirement.

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We do track those incidents. We have our own numbers, not with customers named, obviously,

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but just general to what types of incidents are happening and how many per year. And yeah,

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I mean, that's important information. That's important information to track adversary activity,

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to understand what threat groups are doing, what criminal groups are doing, and how people

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are adapting their techniques to attack, especially lower level industrial systems, which is happening

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too. Now, the other side of that, though, is a lot of stuff is not being detected in

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time. And there's a few different reasons for that in industrial environments. First

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of all, the security maturity is so low. There is a lack of detection tooling. There is a

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lack of host tools, network tools, antivirus, EDR, smart firewalls, things that we are very

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dependent on in our security operations centers are only trained on these days don't exist

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in a lot of levels of the industrial environments. So picking up things is hard. Oftentimes it

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takes somebody at a system seeing something weird happening or something actually breaking

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or something visible, like a ransomware pop-up, something like that, to detect things. And

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that can happen quite late. And there's a built-in temptation because of the poor relationship

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oftentimes between cybersecurity and these OT environments that do their own thing for

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a multitude of reasons to just swap out boxes when something weird happens, troubleshoot

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it like it's a equipment failure and not a cybersecurity issue. So we don't know how

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many things are just being swept under the rug because systems aren't monitored or when

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they have problems when they're infected past the point of no return or an adversary destroys

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them. They just get swapped out by the vendor or the people on site because that's what

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they do. And you can talk about incident reporting, but if nobody ever detects anything, things

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aren't going to get reported anyway. And if they are massively de-incentivized to detect

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anything, they aren't going to ever detect anything because they're not going to install

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any more detection controls. So you mentioned having a debate previously about detection

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versus having incident response as the primary capability. And they're both important. They

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go hand in hand. I don't have a horse in that race. You have to have something to do if

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you detect something. It can be very minimal. And to be able to do something, do incident

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response and report anything, you have to have some kind of detection. They're both

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essential. They're both critical controls in the five critical controls for industrial

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cybersecurity. You have to start a little bit on both of those and slowly build both

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of them up over time. But yeah, if you just build an incident response plan, there's a

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lot of organizations out there with some kind of OT incident response plan. Maybe it's never

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been tested that have zero detection and they're never going to detect anything because when

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somebody perhaps gets horribly injured in a critical incident that was perhaps caused

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by somebody tampering with their environment, they're just going to treat it as an equipment

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failure. The vendor is going to swap out all the equipment and nobody's ever going to know

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that it was a cyber attack. So culture is really important there. Building a strong,

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healthy culture between OT operators, vendors, OEMs and cybersecurity firms, agencies, et

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cetera, is really important. And then making sure as we're building that legislation, we're

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putting a focus on both of those things, both having some capability to actually do investigations,

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make cybersecurity part of root cause analysis, do detection in those environments, even in

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a very rudimentary way, and have some plan to do incident response so you know there's

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an incident going on and you can report it. All that stuff, it's cyclical, it's dependent

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on one another. You can't pull one of those elements out, unfortunately, but the trick

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is just starting with the very basics in each of those things.

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Excellent. Yep, you summed it up right there. That was fantastic. So if they're going to

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mandate incident response reporting, and this in some cases, even when I talk to the regulators

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who are writing this stuff, they assume that there is the capability for detection. They

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assume that there is the capability for all the things that feed into the incident response

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capacity because you can't respond effectively if you don't have this other information.

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So they try to, I would say, imply that you need these other capacities in order to do

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incident response. So they do this in a lot of ways by saying you must have these minimum

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components that you report, and that kind of passively or indirectly says that you must

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have the capability to detect these things in order to provide this information in your

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incident response report. So they kind of get to it through that roundabout waivers

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as directly mandating that you have detection capabilities, for example. If they were going

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to do that, what do you think would be the most useful minimum set of things that they

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need to know?

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You have to understand your environment, which is more challenging than people expect. I

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know that, again, these cybersecurity people coming from the enterprise side of things

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are like, yeah, sure, I just go into my asset inventory software and it tells me based on

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agents what computers I have. It's really easy. That's not the case in OT. Like, what

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computers do you have? What do they do? Who owns them? Where do their logs go? A lot of

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that stuff has to be figured out on paper in OT environments, and it's really, really

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tough. So I highly recommend starting there, having a foundational knowledge of your environment,

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your logging, remote access. That's another really tough one. How are things connected?

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Those are all tough things to understand. And then what things mean in your OT environment.

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That's the hardest bit. A lot of organizations get to the point of actually being able to

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do security monitoring and they have some knowledge of the environment. They stick their

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sock on it. They get their security personnel to start looking at logs from that environment,

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and they have no idea what anything means. Because they don't have a good relationship,

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again, with the OT personnel, and they don't have anybody to ask, and weird stuff comes

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out of those devices. It's a totally different set of protocols, and the domain is different.

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The devices are different. There's older systems, and you don't know what any of it means. You

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can establish something of baseline, but something's change doesn't tell you a lot. So I recommend

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job shadowing programs. I think that's a really, really important thing. If you're going to

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build a healthy cybersecurity program for OT, I highly recommend that you implement

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some kind of job shadowing for your cybersecurity personnel to spend time in the OT environment,

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and how people work there, and how the system works, and just build a good relationship

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to ask those types of questions. What does this mean? What's going on here? Is this bad?

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That kind of stuff is going to help you a lot at those beginning stages.

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Okay. That's super useful. Yeah. When I look at, for example, NERC-ZIP or Circea, and even

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the NIST 2, it doesn't have a lot of specifics that you have to report. But I look at what

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they're asking for, and I'm just wondering, is that enough for them to really... It sounds

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like they're just really grasping... Oh, like incident details? Like what happened

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in the case? Yeah. Yeah. I mean, anything is helpful there. It depends on the level

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of investigation. Yeah. What vertical was it? How many systems... I mean, how many systems

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is going to depend a lot on how flat your network is in a lot of cases?

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And how much you know about how many of them were actually hit?

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And what security controls you have in place? Whether you have some security controls that

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prevented lateral movement. But more relevantly, there is fundamental threat intelligence data

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there. Do you know which adversary group it was potentially by any name, by any organization's

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identifier? What were their tactics across MITRE ATT&CK? That's useful. What parts of

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the kill chain did you forensically analyze and identify? So we can track that in somebody

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else's environment. IOCs are important. All of that information can be useful to peers

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and to tracking these adversary groups at a national level. If you're talking about regulation,

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you're talking about what's useful for intelligence agencies to understand what other countries

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are doing to our critical infrastructure or to other friendly nations' critical infrastructure.

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So all of that tactical detail is useful. But I wouldn't make all of it obligatory because

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people don't always have the maturity to get all that information. You might see one little

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piece of MITRE ATT&CK. You might see one little piece of the cyber kill chain. You might just

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know that a system was tampered with and have no other details. And that's still important

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to know.

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Yeah, I've been advising that less is more. Just notification of incident in some cases

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would even be enough that they're having a problem. Because while I would love to have

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that rich data set you just described, some of them I've never even heard of the MITRE

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ATT&CK.

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Yeah, you can't really legislate that. You can't require it. They don't have the capability

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to provide it. You could provide suggestions. Again, when I'm talking about more tactical

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details in some of this documentation, I'm talking about cross-references to supplemental

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documentation, not necessarily obligating people to do it as part of the regulation.

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But again, those resources, the supplemental resources to help people do stuff, when things

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are very high level and vague, they can feel very overwhelming for a less mature organization.

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So if you're going to say you have to have an incident response plan, then gosh darn

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it, maybe we should start having government sanction templates out there for various types

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of playbooks and incident response plans in OT. Because the enterprise ones don't work.

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So yeah.

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That would be tremendously useful. Maybe one of our agencies like CISN or even MITRE can

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produce something like that for us.

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Maybe.

364
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Yeah. We can certainly ask. We know some people. Okay. And then the next piece on these is

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not just what is reported, but the timeframe. So what, I mean, you've done so many of these.

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What do you think is realistic for any, again, generally speaking, and I know I understand

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it widely varies, but generally speaking, is 72 hours enough time? I mean, because NERC

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sets as an hour after you notice an impact to your operation.

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After you notice some things going on.

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Yeah.

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The sad reality is, okay, so let's say an adversary uses a system as a testbed. Maybe

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they pick a little co-op and they want to test one of their future attacks against a

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big city. So they pick somewhere they think is less defended and this happens, this is

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the real thing. And they test their attack on them. So there is a impact. It's successful.

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It does something bad. It has a process impact. What are the things that happen early on in

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the first day of that? Well, first of all, the operator and the engineers try to figure

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out, troubleshoot what's going on. They try to fix it themselves. And then when they can't

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do that, they call in their OEM. And maybe then the vendor has to get called in by the

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OEM because the OEM can't figure out what's going on. And then we've got the iffy situation

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where maybe they just swap out the box because they can't figure out what's going on, or

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maybe they call their cybersecurity team because they think it's so weird and they want them

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to be part of root cause analysis. So how long has that taken? I mean, that could have

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taken days of troubleshooting, of getting the vendor to go out to the site. They have

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to get it, dispatch somebody, they have to get in their car. Then they decide that it's,

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you know, first they called out an engineer and the engineer couldn't fix it and then

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they called out the OEM. The OEM couldn't fix it. Then they called out the vendor. So

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I mean, I don't want to let people take more time than is necessary, but understand that

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there is time involved in troubleshooting OT stuff. Now if it's ransomware, if it's

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like, you know, you see some mouse moving on the screen, that's quite visible, although

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there is going to be troubleshooting involved in that too. Somebody's going to, an engineer

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is going to have to call somebody and they're going to have to call somebody, but it's not

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going to happen fast. I'm getting called in six months after incidents. I'm getting called

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in six years after incidents. Like it's a slow process right now because of that lack

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of detection and incident response maturity I talked about. It's a really slow process

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for people to figure out it's a cyber thing and get somebody involved who knows what to

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do with that. So I don't have an answer to the question. Like, you know, 72 hours, if

397
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it's ransomware, yeah. If it's something that's visibly cyber, yeah, but don't expect that's

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going to happen when it's actually the big bad doing something to a process. It's not

399
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going to happen that fast. I've often said the more advanced the adversary, the longer

400
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it's going to take for them to notice it's an actual incident. So those are the ones

401
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you're actually trying to solve. Yeah. Yeah. And that's the really scary stuff because

402
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they're making the same thing happen as a dangerously failed piece of equipment. So

403
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it's going to look like a dangerously failed piece of equipment. Yeah. Well, it's good

404
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to know that even someone who does this every day doesn't have a good answer. Maybe an actuary

405
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does or something. Maybe looking at the incident metrics, you could come up with a number,

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but it takes a long time and that's a big problem that we have to solve first. It's

407
00:35:01,080 --> 00:35:06,160
super challenging. No, I couldn't agree more, but that's, I didn't expect anything. Definitely

408
00:35:06,160 --> 00:35:13,680
be honest. Now the last one I wanted to argue about, argue about, discuss is the definition

409
00:35:13,680 --> 00:35:21,680
of incident because rarely is this well defined. Do you have something you use or is this just

410
00:35:21,680 --> 00:35:26,840
as squishy for you as it is everybody else? So definition of how you, how you qualify

411
00:35:26,840 --> 00:35:33,560
one, what an incident means? Yeah. Yeah. So, um, yeah, I mean, I would still use the standard

412
00:35:33,560 --> 00:35:38,920
cybersecurity definition of incident. You know, it's, it's a major event, but what,

413
00:35:38,920 --> 00:35:43,560
how you quantify a major of event, a cyber event in your environment is going to depend

414
00:35:43,560 --> 00:35:47,320
on what matters to you in your industrial environment. And this is something that everybody

415
00:35:47,320 --> 00:35:52,480
misses in OT as well. Um, they usually copy their severity matrix over from enterprise

416
00:35:52,480 --> 00:35:58,160
and it's absolutely goofy and ineffective for OT. Um, your severity matrix in OT, what

417
00:35:58,160 --> 00:36:05,000
you quantify as a high, medium, low severity audit level incident or event in OT is going

418
00:36:05,000 --> 00:36:11,400
to depend on what makes people get hurt. That's, that's the worst day ever is how I usually

419
00:36:11,400 --> 00:36:14,880
explain this to people is what you really need to do is you need to sit down with your

420
00:36:14,880 --> 00:36:18,920
leadership and say, what is our worst day ever? What is our worst case scenario as a

421
00:36:18,920 --> 00:36:23,440
industrial business or an organization that relies on industrial systems? Is it somebody

422
00:36:23,440 --> 00:36:29,600
dying? Is our process failing for 24 hours? A worst case scenario is our, our really expensive

423
00:36:29,600 --> 00:36:34,000
equipment being utterly destroyed, a worst case scenario. And then you work from down

424
00:36:34,000 --> 00:36:38,400
from there and figure out, well, what could practically cause that and what mitigations

425
00:36:38,400 --> 00:36:42,400
for those hazards are in place because you don't want that to happen because an operator

426
00:36:42,400 --> 00:36:46,440
screws up. So there's safety controls in place. They're not all digital safety controls.

427
00:36:46,440 --> 00:36:50,480
Some of them are physical, some of them are human. So you have to do that kind of risk

428
00:36:50,480 --> 00:36:55,700
mapping down from actual consequences you actually care about what would really cause

429
00:36:55,700 --> 00:37:00,640
the worst case scenarios. And those are your high and critical level incidents. And that's

430
00:37:00,640 --> 00:37:05,080
going to vary depending on your industrial environment, your process, your vertical,

431
00:37:05,080 --> 00:37:10,280
your location, et cetera, your redundancy, all of those things are going to play into

432
00:37:10,280 --> 00:37:13,560
that calculation. So you've got to do that for your industrial environment. And that's

433
00:37:13,560 --> 00:37:20,640
how you name what an incident is, what a high severity incident is versus a audit level

434
00:37:20,640 --> 00:37:25,960
event that isn't actually considered an incident to a moderate severity incident, incident,

435
00:37:25,960 --> 00:37:30,440
et cetera. You can't just say, oh, a web server compromise. That can't be in your severity

436
00:37:30,440 --> 00:37:37,480
matrix for OT. It can't be, oh, there's 40 computers infected. Does that actually matter?

437
00:37:37,480 --> 00:37:42,040
If they're infected with Conficker or Sality? No. Shutting down the process to reimagine

438
00:37:42,040 --> 00:37:46,200
those computers is going to have a much worse impact from a consequence perspective. If

439
00:37:46,200 --> 00:37:51,240
it's ransomware and there's a loss of control, that's a very, very different situation. And

440
00:37:51,240 --> 00:37:56,920
you should be calling out a loss of control, loss of visibility situation, not, oh my God,

441
00:37:56,920 --> 00:38:01,360
you've got 40 computers infected with malware. I've been called into environments that have

442
00:38:01,360 --> 00:38:05,160
been infected for 10 years and they finally have a big enough maintenance outage and upgrade

443
00:38:05,160 --> 00:38:09,880
period to get rid of it. So they're calling me in 10 years later. Like consequences are

444
00:38:09,880 --> 00:38:14,640
king there. Yeah. I would say it's, I've been to generation plants and they're just rife

445
00:38:14,640 --> 00:38:17,800
with Conficker and no one cares. It's just not impacting anything.

446
00:38:17,800 --> 00:38:21,440
But they're all infected. Yeah. You can't think about things like that.

447
00:38:21,440 --> 00:38:26,640
Yeah. There are some that argue that it doesn't qualify as an incident unless there is malicious

448
00:38:26,640 --> 00:38:31,200
intent. What are your thoughts on this? Oh my God. I don't care. I don't care.

449
00:38:31,200 --> 00:38:36,880
Design incidents however the hell you want. Like, you know, I see them defined differently

450
00:38:36,880 --> 00:38:42,120
in every industrial org because they define words differently between IT and OT. Sometimes

451
00:38:42,120 --> 00:38:48,280
OT defines incident as, you know, something independent of malicious activity. Yes. I

452
00:38:48,280 --> 00:38:53,200
understand in enterprise environments, we usually clearly define cybersecurity incidents

453
00:38:53,200 --> 00:38:58,720
as things that have malicious intent involved. But in OT, sometimes you've already defined

454
00:38:58,720 --> 00:39:05,840
the big eye incident as anything that impacts the process. So I don't care. I'm sorry. That's

455
00:39:05,840 --> 00:39:11,000
my answer. My old curmudgeonly answer to that is figure out your definition, share it with

456
00:39:11,000 --> 00:39:15,280
OT, make sure you're on the same page with definitions and make sure you've quantified

457
00:39:15,280 --> 00:39:19,840
how you're going to define those incidents at different severities very, very clearly

458
00:39:19,840 --> 00:39:23,560
in a way that actually makes industrial and process and safety sense.

459
00:39:23,560 --> 00:39:28,960
Yeah. No, and I totally agree. I understand. The reason I was asking was it matters when

460
00:39:28,960 --> 00:39:33,320
you're trying to report both upstream within the organization for incident management metrics

461
00:39:33,320 --> 00:39:38,920
or KPIs in addition to outwardly to insurance firms or whether you're going through M&A

462
00:39:38,920 --> 00:39:43,580
or regulatory agency, for example. So yeah. Figure it the hell out. Decide whether that's

463
00:39:43,580 --> 00:39:48,200
going to be a differentiator for that and how that figures into your regulation. That's

464
00:39:48,200 --> 00:39:53,240
the only answer I'll give there is make sure you have a clear, common, shared definition

465
00:39:53,240 --> 00:39:57,360
that everybody knows and make sense for making people stay alive.

466
00:39:57,360 --> 00:40:02,560
Yeah. I'm just still waiting to see what that clear definition is for any of them.

467
00:40:02,560 --> 00:40:09,080
Yeah. I don't think that they're going to include malicious intent in regulation for

468
00:40:09,080 --> 00:40:14,320
incidents. I haven't seen it in a lot of places globally for that type of legislation and

469
00:40:14,320 --> 00:40:20,160
regulation for reporting. I haven't seen that requirement for it to be purposefully malicious

470
00:40:20,160 --> 00:40:24,480
activity. Yeah. It's not in like NIST 2, for example,

471
00:40:24,480 --> 00:40:28,480
but if you get to the NERC SIP standards, they actually have a clause in there that

472
00:40:28,480 --> 00:40:34,400
says attempt to compromise. And that one seems to lean into the malicious intent space a

473
00:40:34,400 --> 00:40:38,780
little bit. To compromise. Is the worm that's just headless

474
00:40:38,780 --> 00:40:43,780
and spreading in your environment and doing bad stuff unintentionally, is it attempting

475
00:40:43,780 --> 00:40:51,560
to compromise systems? Gosh. That's like, is sality getting on something today? Attempting

476
00:40:51,560 --> 00:40:56,240
to compromise. I don't know. I don't know. It's ambiguity again.

477
00:40:56,240 --> 00:41:00,400
Yep. That seems to be the crux of the argument when you have those situations that really

478
00:41:00,400 --> 00:41:06,240
do, they look like they would qualify as an event or a cyber security incident, but you

479
00:41:06,240 --> 00:41:11,520
don't have that malicious intent or that attempt to compromise. So it's one of those things

480
00:41:11,520 --> 00:41:15,840
I just thought it would be interesting to ask. It's an interesting thing to think about.

481
00:41:15,840 --> 00:41:21,600
Again, make sure that you have a common standard definition. And if you are a regulator, make

482
00:41:21,600 --> 00:41:29,560
sure that your definition for other people who need to report to you is clearly defined.

483
00:41:29,560 --> 00:41:32,960
And based on what you want to know about, if you're the regulator, do you want to know

484
00:41:32,960 --> 00:41:37,800
every time somebody deals with Conficker? Do you want to know about that? Is that useful

485
00:41:37,800 --> 00:41:43,720
to you? It has real impacts and environments. It can eat up low resource machines and cause

486
00:41:43,720 --> 00:41:49,600
really weird, bad things to happen in industrial environments. But like we discussed earlier,

487
00:41:49,600 --> 00:41:54,080
pretty much everybody has old headless worms in their critical infrastructure environment.

488
00:41:54,080 --> 00:41:57,600
So do you want to know about everyone? Then you're going to need to define that. You're

489
00:41:57,600 --> 00:42:00,960
going to need to say that in your regulation. Yeah. And then you're going to have to house

490
00:42:00,960 --> 00:42:03,560
all that data and then see if this is trying to make things worse.

491
00:42:03,560 --> 00:42:10,040
That's a them problem. That's definitely a them problem there. Figure that out. Define

492
00:42:10,040 --> 00:42:15,680
it clearly. Don't make these ambiguous definitions. You have to make things clear for people.

493
00:42:15,680 --> 00:42:18,560
Yeah. Do the hard work to actually get it defined right.

494
00:42:18,560 --> 00:42:24,920
Yep. Awesome. Okay. Well, I'm going to wrap up with asking you what is next for pancakes?

495
00:42:24,920 --> 00:42:31,200
What's going on? No. I mean, I guess personally, I am currently

496
00:42:31,200 --> 00:42:37,960
me and making an endeavor to move to Australia with Drago and start working on a new frontier

497
00:42:37,960 --> 00:42:44,600
of industrial operations and incident response there in that region of the world. So there's

498
00:42:44,600 --> 00:42:48,300
a lot of development and growth and incident response there. And I hope that that works

499
00:42:48,300 --> 00:42:54,020
out. I'm very excited to start working in Australia and the nearby nations in defending

500
00:42:54,020 --> 00:42:58,840
their critical infrastructure as well. So that's what's next for me, hopefully.

501
00:42:58,840 --> 00:43:02,600
Okay. Fantastic. I really hope that works out because I know it would be a valuable

502
00:43:02,600 --> 00:43:04,600
resource anywhere you go. So I certainly hope that happens.

503
00:43:04,600 --> 00:43:06,960
Thank you. You're so kind. This was so fun.

504
00:43:06,960 --> 00:43:12,040
Yeah. Now, are you going to any of the conferences that we usually see you at coming up? So in

505
00:43:12,040 --> 00:43:13,920
case anybody's listening, they can catch you.

506
00:43:13,920 --> 00:43:22,560
I will be at Shmoocon. I'll be at ChiBurcon in Chicago. I will be speaking in Canada a

507
00:43:22,560 --> 00:43:28,920
little bit later in the winter time. And I don't know beyond that. Right now, my plans

508
00:43:28,920 --> 00:43:33,560
are a little bit up in the air based on when I'm going to move. But I'm always trying to

509
00:43:33,560 --> 00:43:38,560
find opportunities to speak and participate in conferences. So I'm sure I will, whatever

510
00:43:38,560 --> 00:43:41,120
continent I'm on that month.

511
00:43:41,120 --> 00:43:46,880
Fantastic. Okay. And I will put all of your contact info in the show notes so that people

512
00:43:46,880 --> 00:43:51,320
can find you and contact with you and get much, much more of your valuable information.

513
00:43:51,320 --> 00:43:52,600
Oh, you're so kind.

514
00:43:52,600 --> 00:43:55,720
Alyssa, I really appreciate your time. Thank you so much.

515
00:43:55,720 --> 00:44:05,400
It was such a pleasure. Thank you for the really thought provoking questions.

516
00:44:05,400 --> 00:44:09,880
Thanks for listening to the Ampex Cyber Critical Assets podcast. You can find us on all your

517
00:44:09,880 --> 00:44:14,840
favorite podcast sources. So please like, subscribe and share with your colleagues.

518
00:44:14,840 --> 00:44:24,240
Check out our other content such as blogs, news and more at AmpexCyber.com. It's A-M-P-Y-X-C-Y-B-E-R.com.

519
00:44:24,240 --> 00:44:45,120
Ampex Cyber, securing your world.

