Category Archives: Security

How is ACME different than XCEP/WSTEP anyway?

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If you read my blog there is a reasonable chance that you are familiar with RFC 8555, the standard for Automatic Certificate Management Environment (ACME). Even though ACME is a relatively young protocol it is already used by the majority of websites on the internet for certificate lifecycle management.

While I won’t go into a lot of detail for this post to make sense you have to understand a couple of things about the ACME protocol. 

The first is that it works on the concept of dynamic “account” registration. By that I mean requestors can in real-time, request that an “account” be created for them. This account is represented by a public key pair that the ACME service will use to persist meta-data about the requestor. The ACME service can deny this request for any reason it likes but commonly in Web PKI as long as the request is wellformed it is accepted.

The next thing you need to understand is that it has the concept of “challenges” that can be used to communicate conditions that must be met before a certificate is issued. For example, an ACME service may request that the account holder demonstrate that they are authorized to get a certificate for a given domain name by placing a specific value in DNS at a well-known location. Since only a DNS administrator could perform that action the ACME service can have confidence the requestor controls the name it has requested a certificate for.

And finally, there is nothing in the ACME protocol that limits its use to just web server certificates. It is a general framework that can be used to acquire and manage certificates of any type. For example, CISCO is using ACME in their WebEx offering to facilitate the acquisition of what are essentially email certificates via OIDC authentication as a way to authenticate chat members.

But there is another very popular protocol, a well set of protocols that fewer people know about, that is XCEP and WSTEP. These protocols are used by Windows machines to both determine what kind of certificates a machine or user should enroll for as well as enabling the enrollment for those certificates. 

Similar to ACME these protocols also support, although in a more ridged rigid way, the ability for the issuer to challenge the client for additional information necessary to get a certificate of a particular type. For example, you can configure a certificate type (known as a template) to require that the requestor provide a cryptographic attestation backed by a TPM to be used to prove the machine belongs to the organization operating the certificate authority.

There are differences though, the first of which is the concept of a template, this enables XCEP/WSTEP to have one URL endpoint issue many types of certificates which is very important within an enterprise which is where certificates are used for many different scenarios.

Another difference is that XCEP/WSTEP presume the authorization of the client happened out of the band before the client requested the certificate. The dynamic approach to challenges that was adopted by ACME allowed it to tackle this problem in-band or rely on the out-of-band authorization. It supports this out-of-band concept through the concept of External Account Binding which allows the requestor to use an API key gathered out of band to prove on account creation the account key is associated with some pre-enrolled user.

And finally, ACME has a clear model for extensibility built into it. What this means is that one can easily extend it with additional capabilities. The most fundamental part of this is the Directory resource which lists all of the APIs supported by this ACME instance. One could use this, for example, to add a “Templates” API that would allow an ACME client to request specific types of certificates from the ACME endpoint.

Similarly, the concept of the challenge allows the server to demand the client do any number of things before the certificate is to be issued so the idea of adding a TPM challenge, for example, is trivial within this framework.

In short, ACME, contrary to popular belief, is not a protocol for getting and managing website certificates it is a framework for getting and managing any certificate. More importantly, it is extensible in such a way that with just a few minor additions it would be a proper superset of all the capabilities within the Windows enrollment protocol suite.

Why is this important? That’s easy! When I talk to anyone who is using certificates at any reasonable scale their concerns almost instantly come to the complexity of managing the certificate lifecycle management of those certificates across the various products and services that use them.

When we look at this complexity most of it arises from the use of a mish-mash of solutions for lifecycle management that when viewed in isolation seemed sufficient but when looked at holistically were actually woefully insufficient. 

If as an industry we move these legacy systems to a single protocol so that certificates regardless of them being for public or private PKI or representing users, machines or workloads use one protocol we will have a reliable substrate that we can use to authenticate and authorize with agility.

The next decade of Public Key Infrastructure…

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Background

Before we talk about the future we need to make sure we have a decent understanding of the past. X.509 based Public Key Infrastructure originally was created in the late 80s with a focus on enterprise and government use cases.  These use cases were largely for private systems, it was not until a decade later this technology was applied to the internet at large.

Since the standards for enrollment and lifecycle management at the time were building blocks rather than solutions and were designed for government and enterprise use cases rather than the internet, the Web PKI, as it became known, relied largely on manual certificate lifecycle management and a mix of proprietary automation solutions.

While the use of PKI in the enterprise continued, primarily thanks to Microsoft AD/CS and its automatic certificate lifecycle management (I worked on this project), the Web PKI grew in a far more visible way. This was primarily a result of the fact that these certificates had to be acquired manually which led to the creation of an industry focused on sales and marketing of individual certificates.

The actors in this system had no incentive to push automation as it would accelerate the commoditization of their products. The reality was that these organizations had also lost much of their technical chops as they became sales and marketing organizations and could no longer deliver the technology needed to bring this automation anyways.

This changed in 2016 when the Internet Security Research Group, an organization I am involved in, launched Let’s Encrypt. This was an organization of technologists looking to accelerate the adoption of TLS on the web and as such started with a focus on automation as it was clear that without automation growth of HTTPS adoption would continue to be anemic. What many don’t know is in when Let’s Encrypt launched HTTPS adoption was at about 40% and year over year growth was hovering around 2-3%, about the rate of growth of the internet and — it was not accelerating. 

Beyond that TLS related outages were becoming more frequent in the press, even for large organizations. Post mortems would continuously identify the same root causes, a manual process did not get executed or was executed incorrectly.

The launch of Let’s Encrypt gave the Internet the first CA with a standards-based certificate enrollment protocol (ACME), this combined with the short-lived nature of the certificates they issued meant those that adopted it would have to use automation for their services to reliably offer TLS. This enabled products to make TLS work reliably and by default, a great example of this is the Caddy web server. This quickly took the TLS adoption rate to around 10% year over year and now we are hovering around 90%+ HTTPS on the internet.

While this was going on the concept of microservices merged with containers which led to container-orchestration, which later adopted the concept of mesh networking. This mesh networking was often based on mutual-TLS (mTLS). The most visible manifestation of that being SPIFFE, the solution used by Kubernetes.

At the same time, we saw networks becoming more composable, pushing authentication and authorization decisions out to the edge of the network. While this pattern has had several names over the years we now call it Zero Trust and a visible example of that today is Beyond Corp from Google. These solutions again are commonly implemented ontop of mutual TLS (mTLS).

We now also see the concept of Secure Access Service Edge (SASE) or Zero-Trust Edge gaining speed which extends this same pattern to lower-level network definition. Again commonly implemented ontop of mTLS.

The reality is that the Web PKI CAs were so focused on sales and marketing they missed almost all of these trends. You can see them now paying lip service to this by talking about DevOps in their sales and marketing but the reality is that the solutions they offer in this area are both too late and too little. This is why cloud technology providers like Hashicorp and cloud providers like Amazon and Google (I am involved in this also) had to step in and provide their offerings.

We now see that Web PKI CAs are starting to more seriously embrace automation for the public PKI use cases, for example, most of the major CAs now offer ACME support to some degree and generally have begun to more seriously invest in the certificate lifecycle management for other use cases.

That being said many of these CAs are making the same mistakes they have made in the past. Instead of working together and ensuring standards and software exist to make lifecycle management work seamlessly across vendors, most are investing in proprietary solutions that only solve portions of the problems at hand.

What’s next?

The usage of certificates and TLS has expanded massively in the last decade and there is no clear alternative to replace its use so I do not expect the adoption of TLS to wain anytime soon.

What I do think is going to happen is a unification of certificate lifecycle management for private PKI use cases and public PKI use cases. Mesh networking, Zero-Trust, and Zero-Trust edge is going to drive this unification.

This will manifest into the use of ACME for these private PKI use cases, in-fact this has already started, just take a look at Cert Manager and Small Step Certificates as small examples of this trend. 

This combined with the ease of deploying and managing private CAs via the new generation of Cloud CA offerings will result in more private PKIs being deployed and the availability problems from issues like certificate expiration and scalability will no longer be an issue.

We will also see extensions to the ACME protocol that make it easier to leverage existing trust relationships which will simplify the issuance process for private use cases as well as ways to leverage hardware-backed device identity and key protection to make the use of these certificate-based credentials even more secure.

As is always the case the unification of common protocols will enable interoperability across solutions, improve reliability and as a result accelerate the adoption of these patterns across many products and problems.

It will also mean that over time the legacy certificate enrollment protocols such as SCEP, WSTEP/XCEP, CMC, EST, and others will become less common.

Once this transition happens this will lead us to a world where we can apply policy based on subjects, resources, claims, and context across L3 to L7 which will transform the way we think about access control and security segmentation. It will give both more control and visibility into who has access to what.

What does this mean for the Web PKI?

First I should say that Web PKI is not going anywhere – with that said it is evolving.

Beyond the increase in automation and shorter certificate validities over the next decade we will see several changes, one of the more visible will be the move to using dedicated PKI hierarchies for different use cases. For example, we will ultimately see server authentication, client authentication, and document signing move to their own hierarchies. This move will better reflect the intent of the Web PKI and prevent these use cases from holding the Web PKI’s evolution back.

This change will also minimize the browser influence on those other scenarios. It will do this at the expense of greater ecosystem complexity around root distribution but the net positive will be felt regardless. I do think this shift will give the European CAs an advantage in that they can rely on the EUTL for distribution and many non-web user agents simply do not want to manage a root program of their own so the EUTL has the potential to be adopted more. I will add that is my hope these user agents instead adopt solution-specific root programs vs relying on a generic one not built for purpose.

The Web PKI CAs that have not re-built their engineering chops are going to fall further behind the innovation curve. Their shift from engineering companies to sales and marketing companies resulted in them missing the move to the cloud and those companies that are going through digital transformation via the adoption of SaaS, PaaS, and modern cloud infrastructures are unlikely to start that journey by engaging with a traditional Web PKI CA.

To address this reality the Web PKI CAs will need to re-invent themselves into product companies focusing on solving business problems rather than selling certificates that can be used to solve business problems. This will mean, for example, directly offering identity verification services (not selling certificates that contain assertions of identity), providing complete solutions for document signing rather than certificates one can use to sign a document or turnkey solutions for certificate and key lifecycle management for enterprise wireless and other related use cases.

This will all lead to workloads that were once on the Web PKI by happenstance being moved to dedicated workload/ecosystem-specific private PKIs. The upside of this is that the certificates used by these infrastructures will have the opportunity to aggressively profile X.509 vs being forced to carry the two decades of cruft surrounding it like they are today.

The Web PKI CAs will have an opportunity to outsource the root certificate and key management for these use cases and possibly subcontract out CA management for the issuing CAs but many of these “issuing CA” use cases are likely to go to the cloud providers since that is where the workloads will be anyway.

Due to the ongoing balkanization of the internet that is happening through increased regional regulation, we will see smaller CAs get acquired, mainly for their market presence to let the larger providers play more effectively in those markets.

At the same time, new PKI ecosystems like those used for STIR/SHAKEN and various PKIs to support IoT deployments will pop up and as the patterns used by them are found to be inexpensive, effective, and easily deployable they will become more common.

We will also see that the lifecycle management for both public and private PKI will unify ontop of the ACME enrollment protocol and that through that a new generation of device management platforms will be built around a certificate-based device identity anchored in keys bound to hardware where the corresponding certificates contain metadata about the device it is bound to.

This will lay the groundwork for improved network authentication within the enterprise using protocols like EAP-TTLS and EAP-TLS, enable Zero-Trust and Zero-Trust Edge deployments to be more easily deployed which will, in turn, blur the lines further between what is on-premise and what is in the cloud.

This normalization of the device identity concepts we use across solutions and the use of common protocols for credential lifecycle will result in better key hygiene for all use cases, and simplify deployment for those use cases.

Accountability and Transparency in Modern Systems

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Over the last several decades we have seen the rate of technological innovation greatly accelerate. A key enabler of that acceleration has been the move to cloud computing which has made it possible for hardware, software, and services to be shared. This significantly reduced both the capital and time necessary to adopt and operate the infrastructure and services built on these platforms.

This migration started by enabling existing software to run using dedicated computers and networks owned and operated by someone else. As these computers got faster and the tools to share the physical hardware and networks were built, the cost of technological innovation reduced significantly. This is what democratized modern startup entrepreneurship as it made it cost-effective for individuals and small businesses to gain access to the resources once only available to the largest companies.

This flipped technological innovation on its head. It used to be that government and big businesses were the exclusive sources of technological innovation because they were the ones who could afford to buy technology. The lowering of the cost of innovation is what gave us the consumer startups we have today. This drew the attention of large companies to this emerging market and led to the creation of the modern smartphone which was fundamental to creating the market opportunity we see in consumer startups. This was a scale opportunity that was fundamentally different than the prior government and enterprise models of innovation.

As enterprises saw the rate of innovation and agility this new model provided, it became clear that they too needed to embrace this model in their businesses. It is this reality that led to the creation of Salesforce, the first Software As a Service, and AWS, the first to market with a modern Cloud Service Provider. It was these offerings that gave us Software As a Service (SaaS), Platform As a Service (PaaS), and what we think of as modern cloud infrastructure.

At first, these enterprises only moved greenfield or very isolated projects to the cloud but as the benefits of the new model became irrefutable and the capabilities of these offerings were enriched in ways that were impractical to replicate in their environments, they started moving more business-critical offerings. We can see this trend continues today, a recent survey found that 55% of IT organizations are now looking at ways to reduce their on-premise spending. This will lead to many legacy systems being replaced with more modern, scalable, agile, and secure solutions.

That same survey found that digital transformation and security are the two biggest reasons for this shift. This is no surprise when we look at how capital efficient modern businesses are relative to those based on legacy IT and manual processes, or how vulnerable legacy IT systems are to modern attacks. 

This does beg the question, what is next?. I believe that two trends are emerging. The first being the democratization of compliance for modern systems and the second being the shift in expectations of what does it mean to be “secure”.

If we look at the first trend, the democratization of compliance, we see the internet becoming balkanized through regulation and governments seeking to get more control over what people do on the internet. Increased regulation makes it significantly harder for new entrants to compete, which in turn helps entrench the incumbents who can often eat the engineering and compliance costs associated with the regulations. When you think about this in the context of the global economy in which the internet exists, an economy made up of 195 independent sovereign countries, the compliance burden becomes untenable.

Modern Cloud Service Providers can make a significant dent in this by making it possible for those who build on them to meet many of these compliance obligations as a byproduct of adopting their platforms.

In the near term, this will likely be focused on the production of the artifacts and audit reports that are needed to meet an organization’s current compliance requirements but if we project out, it will surely evolve to include services for legal identity verification, content moderation, and other areas of regulatory oversight. A decade from now I believe we will see systems being built on these platforms in such a way that they will be continually compliant producing the artifacts necessary to pass audit as a natural byproduct of the way they work. 

This will in turn make it easier to demonstrate compliance and create new opportunities such as auditors continually monitoring an organization for its compliance with guidelines rather than just doing annual point-in-time assessments as is done today.

This has also led to companies like Coalition building offerings that let customers augment existing systems with the artifacts to demonstrate conformance with security best practices are being met so that insurance companies can offer more affordable risk-based insurance policies.

As we look at the second trend, the redefinition of what it means to be secure, we can see consumers becoming more aware of security risks and as a result, their expectations around the sovereignty of their data and the confidentiality of their information evolving. 

One response to this realization is the idea of decentralization. The thesis here is arguably is that there can be no sovereignty as long as there is centralization. In practice, most of these decentralized systems are in-fact quite centralized. While there are many examples of this, one of the more visible has been the DAO hard fork which was done to recover stolen funds or the simple fact that 65% of Bitcoin mining happens in China. Additionally, for the most part, the properties that enable sovereignty typically come from the use of verifiable data-structures and cryptography and not decentralization. That is not to say these systems do not have a place, I would argue that their success and durability so far at least suggests there is “a there, there” but I would also say that, at least currently, they do not yet live up to their full promise. 

Another response to this is the consumer adoption of End-To-End encryption in messaging applications (even iMessage is end-to-end encrypted!) and by extension to that problem the verifiability of the systems that implement these schemes. 

The best example here is probably Signal, they spent time designing security and privacy into their messaging protocol and implementing systems from the beginning, modeling its design on modern threats and decades of learning about what does, and does not work. This approach led to the protocol that they defined being adopted by many of their competitors, including WhatsApp, Facebook Messenger, Skype, and Google Allo.

Signal is also a great example of the verifiability property, in particular, the work they have done with Contact Discovery is exciting. What they have done with this feature is first to minimize what information they need to deliver the capability in the hope to limit future abuse. Secondly, they leveraged technologies like SGX, which is an example of a Confidential Compute, that enables them to demonstrate what they are doing with the information they do collect. This introduces transparency and accountability which both are important ingredients to earning trust.

The use of hardware security as a key component of the security boundary has already found its way from consumer phones, laptops, and tablets to the cloud. For example, Google Cloud‘s Shielded VMs and Azure Trusted Launch use hardware to provide verifiable integrity to VM instances to make it possible to detect VMs compromised by boot- or kernel-level malware or rootkits similar to how Apple does with the iPhone. We also now see AMD Sev and SGX seeing broader deployment in the larger Cloud Service Providers (I will be the first to admit these technologies have room to grow if they are to live up to their promises but they are promising none the less).

With this foundation, the industry is starting to look at how they can bring similar levels of transparency and accountability into applications and ecosystems too. One of the projects that have demonstrated that doing this can have a big impact is Certificate Transparency. As a result of the investments in deploying Certificate Transparency, the internet is now materially more secure than it was before and this is a direct result of introducing accountability into an opaque ecosystem based on blind trust.

Another example in this space is the Golang Checksum Database where verifiable data-structures like Merkle Trees are being used to introduce accountability into the software supply chain as a means to mitigate risks for those who rely on the Golang ecosystem. 

For many problems in the security space, you can solve from one of two philosophical bases. You can either create privileged systems only visible to a few that you hope aren’t corruptible or you can build democratizing transparency into the system as a check on corruption.

Dino A. Dai Zovi

While the earlier examples are using combinations of hardware, cryptography, and verifiable data-structures to deliver on these properties, other examples take a more humble approach. For example, Google Cloud’s Access Transparency uses privilege separation, audit logs, and workflows to provide the fundamental ability to track business justifications for access to systems and data. The existence of these systems is further validation that the trend of verifiability is emerging.

So what should you take away from this post? I suppose there are four key messages:

  1. The definition of security in modern Cloud services is continuing to be influenced by the consumer space which is leading to the concepts of verifiability, accountability, data sovereignty, and confidentiality becoming table stakes.
  2. Globalization and regulation are going to accelerate the adoption of these technologies and patterns as they will ultimately become necessary to meet regulatory expectations.
  3. Increasingly verifiable data structures, cryptography, and hardware security capabilities are being used to make all of this possible.
  4. These trends will lead to the democratization of compliance to the many regulatory schemes that exist in the world.

I believe when we look back, these trends will have significantly changed the way we build systems and a new generation of businesses will emerge enabling these shifts to take place.

Safes and Transparency

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Lately, I have been thinking about the history of defensive security technology. One of the purest examples here can be found in safes and vaults. The core purpose of a safe is obvious, to make it cost-prohibitive for an attacker to gain access to whatever is inside without being detected.

With that said, the topic is a lot more nuanced than it seems on the surface. If we look at a safe used by a typical community bank in the 1800s, one of the things you will notice is that they often have ornate decorations on their exteriors, beautifully designed locking mechanisms and their locking mechanisms are covered by specific patents. These traits were clearly designed to signal something to the visitors of the bank, namely that they use the latest technology to keep your valuables safe.

Beyond the messaging buried in the design, these safes were also designed to mitigate specific threats, for example, In the mid-1800s it was common for attackers to steal safes, use explosives to open them and to kidnap those that had access to the secrets necessary to open a safe, or those near and dear to them. 

In response to this reality, safe manufacturers started to use materials like manganese to manufacture safes, making the walls very thick and as a result very heavy (often 3 tons or more!), rounding corners, and using locking cylinder-shaped doors in combination to make theft or the use of explosives no longer interesting vectors for an attack.

These changes, combined with artful customizations also provided a way for banks to ensure that sophisticated thieves could not replace a safe in order to delay the detection time and have a safer getaway.

They also started incorporating time locks, to make it so if someone was kidnapped, they would still not be able to open the safe outside core business hours, essentially enabling the creation of a fully disclosed ledger of all goods stored in or withdrawn from the safe.

A famous example here is from 1876 in the robbery of the Great Northfield Minnesota Bank by Jesse James and the Cole Younger gang, it was foiled due to a safe with these design characteristics.

As I think about the parallels in modern technology, I can not help but to come back to a post I did this last year titled “An Evolution of Security Thinking’, in particular how we have gone from security as something you added after the fact to one where it is built into a system from the get-go. Moreover, it seems that these safes may also represent one fo the first examples of transparency being applied as a technique used to dissuade an attacker.

If a safe has no tumbler on the outside, what good would it do to kidnap the bank manager? As a result, the attacker is forced to attempt their theft during business hours when the bank was busy and they would have a larger chance of getting caught.

If it is obvious a safe has 12” thick walls and weighs in at over 3 tons, then stealing the safe at night, or using explosives to open the safe, given the skills and resources of the attacker, is no longer a viable path of compromise either. As a result, forcing the assailant to attack the bank during the day, when the vault may already be opened.

The safe manufactures, by making their designs, and mitigations clear, were attempting to dissuade attackers from even attempting their attack. This is not materially different from how today we are applying the concepts of cryptographic transparency as a tool to mitigate other attacks.

In short, transparent systems are essentially the antithesis of security by obscurity. While designing a system to be cryptographically verifiable does not necessarily require the contents of that system to be known, just as the safe design doesn’t require the contents of the safe itself to be known, the use of these patterns makes it possible to intelligently reason about the security and integrity of the system.

Just a thought…..

P.S. Thanks to Fotis Loukos and Yael Grauer for providing feedback on this post. 

Software Supply Chain Risk Mitigation

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Increasingly we are seeing attacks against what is now commonly referred to as the software supply chain.

One of the more notable examples in the last few months was from the Nodejs package management ecosystem [1]. In this case, an attacker convinced the owner of a popular but unmaintained Node package to transfer ownership to them. The attacker than crafted a version of the package that unsuccessfully attacked Copay, a bitcoin wallet platform.

This is just one example of this class of attack, insider attacks of the software supply chain are also becoming more prevalent. When looking at this risk it holistically it is also important to realize that as deployments move to the Cloud the lines between software and services also blur.

Though, not specifically an example of a Cloud deployment issue, in 2015 there was a public story of how some Facebooks employees have the ability to log into users accounts without the target user’s knowledge [2]. This insider risk variant of the supply chain exists in the Cloud in a number of different areas.

Probably the most notable being in the container images provided by their Cloud provider. It is conceivable that a Cloud provider could be compelled by government to build images that would attack a specific or set of customers as part of an investigation, or that an employee would do so under compulsion or in service of personal interests.

This is not a new risk, in fact, management of internal and external dependencies has always been core to building secure systems. What has changed is that in the rush to the Cloud and Open Source users have adopted the tools and resources these cloud providers have built to make this migration easier without fully understanding and managing this risk that they have assumed in doing so.

In response to this reality, Cloud providers are starting to provide tools to help mitigate this risk, some such examples include:

  • Providing audit records of employee access to customer data and services,
  • Building solutions to provide hardware-based trusted execution environments that provide some level of protection from cloud providers.
  • Offering hardware key management solutions provided by third-parties to protect sensitive key material,
  • Cryptographically signing the binaries and images that are published so that their distribution is controlled and tampering post-production can be detected.

Despite these advancements, there is still a long way to go to mitigate these risks in a holistic fashion.

One effort in this area I am actively involved in is in the adoption of the concept of Binary Transparency. This can be thought of as an evolution of legacy code signing models. In these solutions, a publisher places a cryptographic signature using a private key associated with a public certificate of some sort that is either directly trusted based on package origin and signature (such as with GPG signatures) or is authenticated based on the legal identity of the publisher of the package (as is the case with Authenticode).

These solutions, while valuable, help you authenticate a package but they do not provide you the tools to understand the history of that package. As a result, these publishers can produce packages either accidentally or on purpose that are malicious in nature that is signed with their “trusted keys” and it is not detectable until it is too late.

As an example of this risk, you only need to look at RealTek, over the years numerous times their code signing key has been compromised and used to produce malware, some of it targeted such as in the case of Stuxnet [3].

Binary Transparency addresses this risk in a few ways. At its core Binary Transparency can be thought of as an append-only ledger listing of all versions of a given binary, each of these versions having a pointer to a content addressable store where that binary is available.

This design enables the runtime that will execute the binary to do a few things that were not possible, It can, for example, ensure it is running the most recent version of a binary and to only run the binary when it, and some number of previous revisions are publicly discoverable. This also enables the relying parties of the published binaries and images to comp it can inspect all versions and potentially diff those versions to understand the differences.

When this technique is combined with the concept of reproducible builds, as is provided by Go [4] and a community of these append-only logs and auditors of those logs you can get strong assurances that:

  • You are running the same version as everyone else,
  • That the binary you are running is reproducible from the source you can review,
  • The binary are running has not neen modified since it was published,
  • That you, and others, will not run binaries or images that have not been made publicly available for inspection.

A system with these properties disincentivizes the attacker from executing these attacks as it significantly increases the probability of being caught and helps bound the impact of any compromise.

Importantly, by doing these things, it makes it possible to increase the trust in the Cloud offering because it minimizes the amount of trust the user must put into the Cloud provider to remain honest.

A recent project that implements these concepts is the Go Module Transparency project [5] [6].

Over time we will see these same techniques applied to other areas [7] [8] of the software supply chain, and with that trend, users of open source packages, automatic update systems, and the Cloud will be able to have increased peace of mind that their external dependencies are truly delivering on their promises.

  • [1] Node.js Event-Stream Hack Exposes Supply Chain Security Risks
  • [2] Facebook Engineers Can Access Your Account Without A Password
  • [3] STUXNET Malware Targets SCADA Systems
  • [4] REPRODUCING GO BINARIES BYTE-BY-BYTE
  • [5] Proposal: Secure the Public Go Module Ecosystem
  • [6] Transparent Logs for Skeptical Clients
  • [7] Firefox Security/Binary Transparency
  • [8] Contour: A Practical System for Binary Transparency

Secure, Privacy Preserving Key Discovery for End-To-End Encryption

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A lot of products today claim to offer End-To-End Encryption but not all of these products offer the same level of protection. Some of the differences between these solutions are rooted in the protocols and cryptography that they use, in some, it is in the way they are implemented and in others it is the way they handle the discovery of the cryptographic keys of the peers involved in the session.

The topic of key discovery itself is a complicated one, on its surface, for a messaging application all you need to do is go to a directory to request the public key pairs associated with the user or their devices you will communicate with. Where things get tricky is how, as a relying party, you can tell if the key discovery mechanism is lying to you or not.

This is important because if the key discovery server is lying to you it can facilitate an impersonation of that user, add a hidden third-party to the encrypted session without your knowledge, or potentially trigger a re-encryption to a device not under your control without your knowledge.

To understand the implications here you just need to look at iMessage. Although many do not know this iMessage is actually End-to-End Encrypted! Matthew Green has done several great write-ups on its protocol [1] [2] and how the lack of verifiability in the key discovery mechanism utilized weakens the overall solution.

The most used End-to-End Encrypted messaging application is probably Facebook’s What’s App. Several years ago a security researcher [3] reached out to The Guardian to discuss what they described as a “backdoor” in What’s App, this “backdoor” was related to how it handled key discovery in device recovery use cases.

As a product person, you often need to make trade-offs to achieve your goals and that was what happened in this case. This “backdoor” was a design decision that was made to ensure billions of users could get some of the End-to-End encryption protections without compromising usability.

A number of security researchers, including myself, spoke up [4] which resulted in the article being updated to correctly reflect this reality [5] flawed reporting about WhatsApp.

Later WhatsApp and how Key Discovery happens came up in the news again, this time in an article from Wired [6. Alex Stamos, the former Chief Security Officer of Facebook, responded to this article [7] affirming some of the article’s points and talking about how a conscious decision was made to enable the associated use case:

“Read the Wired article today about WhatsApp – scary headline! But there is no secret way into WhatsApp groups chats. The article makes a few key points.”

While is response may be true, it is nor verifiably true as it relies on the behavior of the client and not cryptographic verifiability.

This is where systems like CONiKS [8], Keybase [9] and Google’s Key Transparency [10] come into play.

These solutions aim to enable automated trust establishment with untrusted communication through the use of an auditable directory of all of its users’ keys both past and present.

The fact that these solutions provide the auditable history of keys means that both the relying party and subscriber involved in the communication can reliably be made aware of when new keys have been associated with a users account, and importantly what entity added the key to the account.

With this information, they applications the users are using can both prevent messagings (via policy) being sent or notify the user when keys have changed unexpectedly.

This allows messaging clients to verify the identity of users automatically and prevents malicious/compromised servers from hijacking secure communications without getting caught.

On the surface, this sounds much easier than it is to acomplish at least at scale. WhatsApp serves over a billion users, any solution needs to be able to deal with key updates and reads at rates necessary to support such a large user base.

It needs to do this without leaking metadata associated with who the users are communicating with.

And do this without significantly increasing the amount of data a user must download or the time it takes to change keys.

While these are all tractable problems, they are not problems that are solved today in this context.

For this reason, applications that implement End-To-End Encryption typically either provide a mechanism that users who care about these risks can use to out of band verify cryptographic keys in person [11] or simply implicitly trust the key discovery service as an honest actor.

At Google, I have the pleasure of working on Google’s answer to this problem [12]. It is our hope that when complete that applications that need to securely discover keys in a verifiable way can simply download our solution and focus on their application and not need to spend years of energy to solve this problem for their applications.

I firmly believe the best way to ensure the right thing happens is to make sure that the right way is the easy way and fundamentally that is the goal for the Google Key Transparency effort.

  • [1] Attack of the Week: Apple iMessage
  • [2] Let’s talk about iMessage (again)
  • [3] The Guardian is backtracking on a controversial story about WhatsApp
  • [4] Security researchers call for Guardian to retract false WhatsApp “backdoor” story
  • [5] Flawed reporting about WhatsApp
  • [7] Read the Wired article today about WhatsApp – scary headline!
  • [8] CONIKS Project
  • [9] OKCUPID’S FOUNDERS WANT TO BRING ENCRYPTED EMAIL TO THE MASSES
  • [10] Google’s Key Transparency project aims to ease a tough task in cryptography)
  • [11] Safety number updates

What is Fortify and how does it work?

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If you follow the W3C or web development, you probably know that the WebCrypto API was designed to provide fairly low-level cryptographic algorithms so that you could build web applications that interoperate with existing systems.

The idea being it was largely the cryptographic primitives that needed to be implemented natively and that the other layers of interoperability could be handled in pure Javascript when combined with good application security practices and new features like SRI.

While there are legitimate concerns over the use of cryptography in browser-based applications there are also legitimate uses. Afterall who doesn’t like to watch a film on Netflix now and again without having to run Flash?

For another example of an application that makes heavy use of WebCrypto take a look at 1Password which is one of the most popular password managers in use today. They use WebCrypto and the same origin security model of browsers to allow them to help manage their passwords locally and store the associated ciphertext on their servers.

The utility of WebCrypto does not end with applications though, many libraries, some by my company, Peculiar Ventures, leverage this raw cryptographic capability to make it easier for others to build applications that interoperate with their counterparts on other platforms. For example consider PKIjs,  XMLDSIG, XADESjs, 2key-ratchet and js-jose.

However powerful this new native cryptographic capability is, it intentionally left out providing access to local cryptographic certificates and key stores as well opted out of providing web applications access to smart cards and other security elements. I personally both agree with these decisions and understand why they were made but that is something for another post. With that said, that doesn’t mean those capabilities are not useful and that is where Fortify comes in.

So what is Fortify?

Fortify is a client application that you install that runs in the background as a tray application in Windows, OSX, and Linux that provides these missing capabilities to authorized applications.

It does this by binding to 127.0.0.1 and listening to a high-order well-known port for incoming requests. Browsers allow web applications to initiate sessions to this address, over that session a Fortify enabled application establishes a secure session and if approved by the user is allowed to access these missing capabilities.

How is this secure session established?

At the core of Fortify is a library called 2key-ratchet. This implements a `Double Ratchet` protocol similar to what is used by Signal. In this protocol each peer has an identity key pair, we use the public keys from each participant to compute a short numeric value since in the protocol the peers prove control of the respective private keys we know that once the keys are authenticated we are talking to the same “identity”.

Since 2key-ratchet uses WebCrypto we leverage the fact that keys generated in a web application are bound to the same origin, we also (when possible) utilize non-exportable keys to mitigate the risks of these approved keys from being stolen.

This gives us an origin bound identity for the web application that the Fortify client uses as the principal in an Access Control List. This means if you visit a new site (a new origin), even if operated by the same organization, you will need to approve their access to use Fortify.

For good measure (and browser compatibility) this exchange is also performed over a TLS session. At installation time a local CA is created, this CA is used to create an SSL certificate for 127.0.0.1. The private key of the CA is then deleted once the SSL certificate is created and the Root CA of the certificate chain is installed as a locally trusted CA. This prevents the CA from being abused to issue certificates for other origins.

What happens over this session?

The protocol used by Fortify use a /.wellknown/ (not yet registered) location for capability discovery. The core protocol itself is Protobuf based.

We call this protocol webcrypto-socket. You can think of the protocol as a Remote Procedure Call or (RPC) to the local cryptographic and certificate implementations in your operating system.

Architecturally what does the client look like?

The Fortify client is a Node.js application based on Electron and it accesses all cryptographic implementations via node-webcrypto-p11. This library was designed to provide a WebCrypto compatible API to Node.js applications but it also extends the WebCrypto API to provide basic access to certificate stores.

The Fortify client uses another Peculiar Ventures project called PVPKCS11 to access the OSX KeyStore, Mozilla NSS or Windows CryptoAPI via this PKCS#11 wrapper.

It also uses pcsclite to listen for a smart card or security token insertions and removals, when new insertions are detected it inspects the ATR of the card. If it is a known card the client attempts to load the PKCS#11 library associated with the card. If that succeeds events in the `webcrypto-socket` protocol are used to let the web application know about the availability of the new cryptographic and certificate provider.

Ironically, despite the complication of the PKCS#11 API, this approach enables the code to maintain a fairly easy to understand structure.

The application also includes a tray application that is used to help with debugging, access a test application and manage which domains can access the service.

So what can I do with it?

In the simplest case, you can think of Fortify as a replacement for the <keygen> tag.

Since the client SDK that implements the `webcrypto-socket` protocol is a superset of WebCrypto, with slight modifications, if you have an web application that uses WebCrypto you can also use locally enrolled certificates and/or smart cards.

Some of the scenarios we had in mind when building the Fortify client included:

— Enrolling for X.509 certificates over the web,

— Signing and encrypting/decrypting email or documents,

— Building certificate-based authentication schemes with a modern user experience.

Can I use this today?

Yes, it is feature complete and ready for you to take a look.

There are some examples on its usage here and you can find the documentation here.

It works on Windows 7+, OSX 10.12+, and Debian based Linux distributions, it also works on IE11, Edge, Safari, Chrome, and Firefox.

In general, you should consider this initial release of a Beta quality, for example I know we need to do additional testing with smart cards and make sure we have the metadata for each card so they work on each supported platform. Otherwise, we expect it to work largely as expected.

Is it Open Source?

Yes, all Peculiar Ventures related libraries to-date have been licensed as BSD or MIT and this is no different so you are free to do with them as you see fit.

What’s next?

Over the next year, we will gain enough confidence in the solution to declare it complete. We will also look at adding other useful like smart card password changes and unblocking at some point in the future.

Other than that, we are just looking for your feedback so we can refine the quality of the solution.

Thanks

I want to thank the members of the CASC for their support of this project and the many individuals from Twitter who provided feedback and testing.

What value can a third-party provide users when browsing the web?

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While at the CA/Browser Forum I was asked by a friend if we wanted to replace EV with a new class of certificate what would that certificate look like?

My response was that I would frame the question differently. The “real” question is what problems does a typical user have that a third-party with the strengths of a CA could help with?

With this in mind, you need to first understand who this stereotypical user is, a software engineer may have different needs than a grocery store clerk. They may also have common needs, you won’t know that until you do research.

The only way to do reliable research on this topic is to actually work with those users to understand what their needs are. While this is much harder than it sounds due to biases introduced in such processes a real needs analysis requires that you start here.

With that said, I suspect this exercise would show a broad swath of the target users is concerned with these questions:

  • Will I have a good experience working with the people behind the website?
  • Do the people behind this website have a good reputation?
  • Are the people behind this website experts in their craft?
  • How do I figure out how to reach a real human when and if I need to?

I would put those concerns into the context of the interaction they will have with the website (buying a product, downloading software, etc).

With that understanding I would then try to understand what the strengths of the CA are, having been a CA for a long time I would say:

CAs are good at verifying claims relating to the subject of a certificate.

I would then try to map the identified problems and strengths together to see what potential value the CA could provide that user.

Again the right thing to do is formally do those above explorations but for the purpose of this post I suspect these exercises would find that:

  • When a user visits a website they may struggle to find out how to contact the sales/support for that business,
  • When a user visits a site for the first time it may be hard for them to determine what the companies true line of business is,
  • After a user previously visited a website and completed a transaction with it they sometimes need to contact that business after the fact and could be assisted in finding the right contact information,
  • Before deciding to do a high-value transaction with a business, customers may want to find out the experience others have had with that business.

Now, just because a user may have these problems and a CA may be able to help solve them, it does not mean the SSL indicator is the right place to help answer these questions. It just means that there is a problem and skills intersection.

When, and how to solve this problem is another exercise altogether. Let’s explore EV for a second to give that some context.

Today if we assume the information in an EV certificate is correct (and not confusing see: this and this for context) we can say it provides the answer to “if I need to sue these people where do I tell my lawyer they are at?”.

The problem with that is that you may not have that information when you need it. I say this because you typically need to sue someone after you completed a transaction with them not before. After the fact, you have no assurance that this information in the certificate will be available at the site you did the transaction with.  The website may have gone away, they could have changed their certificate, or could some other change may have taken place that makes that information not readily available to you when you need it.

In any event, the point of this post is to say CAs should not be asking what they can put into certificates but what problems users have that CAs are well suited to solve. Unless they start there they will not be solving a real problem, they will just be bolting more things onto a certificate and asking why browsers and users don’t users see value in it.

Reality vs Fantasy – The DV vs EV argument

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This morning I woke up to a blog post from Melih, the founder of Comodo titled “Problem vs Solution Value mapping”.

This is a follow-up to an ongoing discussion Melih and I have been having about the value of EV, and positive trust indicators. On my blog, the conversation started July 2017 if you’re interested.

Melih’s focuses his most recent post on the assessment of “value”, correctly attempting to define it as the basis of the rest of the post. He chooses to define it as  “the direct result of a resolution to a problem.” I think it is this definition is the first part of his argument I have an issue with. Namely, The Oxford Dictionary defines “value” as “the regard that something is held to deserve; the importance, worth, or usefulness of something.”

When considering “value” with this definition, I believe an analysis of “value” would start by building a case on what is “deserved”. To do that, we have to also define a context in which that value is assessed. I think this is probably the hardest part, and probably where most of the disagreement on “value” of EV stems from.

If we say the context of this assessment is “the security and privacy guarantees that can be provided to the user by user agents to users” EV’s value is no better than that of DV. It is not a hard case to make either.

The security model of the browser is based on the concept of “origin” where that origin is essentially the “hostname” that the content was retrieved from. Any external website or resource embedded in the site (with rare exception) has the same permission as the original website as a result of this model. This is how web analytics work, advertising and many other products and services that make up the web.

Until user agents required all of these entities that make up a given site to use EV and to have the legal entity in all of the associated certificates match; EV is a false flag. It says “you are talking to this legal entity” when in-fact your talking to many legal entities and any one of them could equally harm you.

The reality is that if this change were to be made that you would almost never see EV badges though. This is because virtually every site is made up of content and services from across the web and this condition would almost never be met. This is why we do not see CAs making the argument that this rule should be enforced by UAs.

If we say the context of this assessment is “the average users practical ability to protect themselves from phishing” again EV does not fair well. There have been lots of user studies done on how users do not understand positive trust indicators, and in general, do even notice them in most cases.

Furthermore, even if we disregard these well-run studies (and the associated common sense) as Ian Carroll showed with his Stripe, Inc business in Kentucky the values displayed in these indicators can trivially be made, at a very low cost and with no traceability, be made to say whatever an attacker wants. This again frames EV as a false flag because it can so easily be used to lend credence to a phisher’s site by giving them the EV badge that says the same thing as their target site.

If this was not enough, again if we disregard these well-run studies and say that people need to take the responsibility for looking at the EV badge to get confidence they are dealing with a trustworthy entity we need to look no further than the work James Burton did when he got a certificate for his business “Identity Verified”.  In this case, if a user has been taught to look at the EV indicator for an abstract concept of “trustworthiness” we are back to the user being mislead.

All of this ignores another very real problem, that being most phishing sites are not bespoke sites, instead, they are sites that are hacked and re-purposed. A good example of this is this one from a few weeks ago. What we appear to have here is a company called Northern Computer Services, LLC hosting a website for a business with the domain name “stampsbyjudith.com” hosting a Bank of America phishing site.

Now EV proponents surely see this as an example of EV working but if you look at it critically you will see it is exactly the opposite. First, could a customer believe that this “Northern Computer Services” is somehow a service provider to Bank of America? It seems reasonable to assume that the average user does not know anything about the way Bank Of America operates its services. In-fact even if you do have some level of understanding it’s incredibly common for banks to use service providers for different capabilities, maybe this Northern Computer Services hosts the BoFa website or provide billpay or mortgage services. How is the average user to know?

But what about the URL? There is no plausible way Bank Of America is hosting their site on the domain stampsbyjudith.com! Your absolutely right! it’s a fair expectation of us that if a user happens to look at the address bar that they should be able to figure that out. This is of course something you get when you use DV though, no EV necessary. Then there is the issue that studies also show that users do not look at the address bar either.

This is why Microsoft has created SmartScreen and Google has created Safe Browsing. These solutions utilize the massive scale and technology depth of these organizations along with machine learning and other advanced techniques to find phishing sites. As a result when a user navigates to a site similar to this one they get a interstitial warning them about proceeding.

In summary, in this context, I would argue that as EV exists today it actually makes things harder on the user and easier on the attacker.

With that context in mind let’s explore each of the arguments that Melih makes.

Users want protection from Transit Providers. Sure they do but I would say the if a user framed the topic this way it would demonstrate the how little they actually understand of the problem in question. It is not just “transit providers” they need protection from, it is every entity other than those that are necessary to serve the application hosted at a domain.

Networking is so complex it is not possible to expect even some of the most technical users to understand all of the nuances involved here.

I would like to point out that Melih again attempts to redefine terms, this time in a disingenuous way. Specifically, in this part of his post suggest there is some common understanding that there is a difference between “encipherment” and “encryption”.

Let’s again take a look at what the Oxford Dictionary says:

Encryption – The process of converting information or data into a code, especially to prevent unauthorized access.

Encipherment – Convert (a message or piece of text) into a coded form.

As you can see, these words mean the same thing. The only difference being the example use case in one of the definitions. But maybe this inconsistency is use  is because the Oxford Dictionary does not address a cryptographers view on these words? Unfortunately, that is not the case either, if you were to look at books like Serious Cryptography, Cryptography and Network Security, or even the very dated Applied Cryptography you will find no usage of these terms in this way.

What Melih has suggested in the past, and continues to do so in this section is that somehow if you authenticate only the domain and use that authentication as the basis for the session protection that this is not “encryption”.

Going so far to suggest that it is only encryption if you authenticate the legal entity. This is frankly ludicrous and I can not even respond to this more than I just have here.

I can say, that redefining a term, especially in such a specious way devalues any other valid points he may have.

But what about the users! The users want to know who they are dealing with! I actually agree with this but I also think it is far more complicated than users actually understand. So much so I would argue it is not possible to do in most cases. As a father when I run into situations where my kids want things that are not possible I sometimes joke with them and say “Well I want a pony!”.

It feels to me this is probably a case where that response is appropriate. The reality is there is not a globally unique business name, this is also the case with logos. Probably the best mainstream examples of this are the fake Starbucks stores and the notorial “Apple Stores” of Asia.

Fake Apple Store Highlights Counterfeit China

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This is the nature of brand names, in-fact there is an entire discipline of law (Trademark Law) dedicated to this topic and multilateral international agreements on how such disputes are to be handled.

So in the context of the url, does EV as it stands today add or remove value? From my perspective, it seems to me at a minimum in this context it provides no value but I could also make a reasonable argument it makes things worse here as well due to the introduction of more surface area for confusion.

User’s want to know if its “safe” to interact with the website! Again I can agree with this, the problem is names do not harm — we even teach our kids rhymes to remind them of this fact:

Sticks and stones may break my bones, but names can never hurt me.

To keep users safe we have to look at far more than the name a website is hosted under; there are literally thousands of features that a solution intending to protect users safety need to consider and I would not be surprised to find out that the name is one of the least important.

This is, again, why we have solutions like SmartScreen and Safe Browsing these solutions are constantly watching feeds of data to determine if a website is safe or not. It is not possible to solve the “safety” problem in any meaningful way without similar techniques.

But user’s want to be able to trust the content they see! Again, I also think this is something that users want, I just don’t think they can have everything they want.

But before I talk about this I want to talk about how Melih is redefining a term again, he suggests that “trust” means “having the ability to validate VISA, Paypal logo etc”. The oxford dictionary defines trust as “Firm belief in the reliability, truth, or ability of someone or something.”

With that, I would think that it would be more correct to say that they want to believe what they see. This is of course a very natural thing, something scammers have taken advantage of since the dawn of time.

When considering this desire I think we have to ask ourselves what the best way we have to service the desire. We also have to acknowledge that malicious content is everywhere in the world (don’t forget our Fake Starbucks and Apple Stores from above) that the best we can do is provide a speedbump.

This is, again, why we have solutions like SmartScreen and Safe Browsing as they were designed, engineered and continually evolve to address these risks.

In closing, I believe EV as it stands today is a round peg in a square hole. This does not mean there is not value in knowing the legal identity of the organization who operates a website, it is also not because these third-parties can’t do more to help users manage the risks they are exposed to.

It is because EV is being sold as something it is not, a anti-phishing tool. Simply put it is not well suited to help with that problem and I would go so far that when we teach users to see it as such it even helps phishers.

Risk variance and managing risk

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One of my favorite security sayings is “My threat model is not your threat model”. We broadly accept there are different perspectives for every problem — the same is true with security.

Consider an Enterprises IT organization where you are chartered to support and secure a business. You need to meet this charter with a fairly fixed set of resources but the business requirements you must support are always changing. To deliver a reasonable level of service enterprises standardize on a core set of ways that certain issues (user and access management, compute, etc.) will be provided and force business units down the path of adopting them.  But that standardization often results in non-ideal user experiences, disjointed business workflows, slow innovation and importantly, in this case, it also commonly results in the either over or under mitigating security risks.

Startups, who are on the other end of the spectrum, are in a race to demonstrate market traction before their funding runs out. As a result, startups either virtually ignore security and privacy altogether or re-using a component they do not understand that is not well suited to the business problem they are solving or simply solves the wrong problems for their business risks.

Both enterprises and startups show the hard reality that we are often so close to our problems and set in our way of thinking we simply miss the big picture. This natural bias can hurt our businesses and in the context of security trade-offs, and result in incidents like the recent Equifax breach or the ever-growing list of Bitcoin exchange compromises.

The first step in preventing this “missizing” of risk is to make sure you understand what your risks actually are. The right way to do that is to think adversarially, taking a step outside of your business process or solution and thinking about the structure of the system your protecting and defining a threat model that captures those risks. This is not a one time exercise, it is something you need to constantly be re-visiting and getting new perspectives into.

Consider the typical Bitcoin exchange compromise, the exchanges usually start with a basic system limited to “online hot wallets” with weak architectural protections. They probably know better (for humanity’s sake I hope they do) but decided that the risk, in the beginning, is low enough because they have so little to lose that they go forward. Later they find success and are focused on other parts of their business and never get back to fixing that early trade-off.

As an aside, this bitcoin example showcases lots of problems, the largest being the asymmetric risk distribution. Specifically, the risk here is that of the depositor but the decision to take the risk is made by the exchange. I digress but this class of problem is a real problem in most startups and is the impact of which is multiplied 1000x in Bitcoin startups.

In any event, we can see how these sorts of things happen in hindsight so how can we limit how often these issues happen in the first place? As a technologist it hurts me to say this, the answer is process.

The good news is that process does not need to be heavy-weight. You need to make sure you approach the problem systematically and regularly, for example:

  • Instead of a threat model, you can do a simple threat tree,
  • You can use your bug tracking system to track the security issues you have found,
    • You can make sure those bugs capture the security decisions you have made,
    • The consequences of the identified risks for the actors in the system are captured,
    • What mitigations you have put in place for those issues along with how effective you think they will be are captured,
  • And importantly have a plan for how you will respond when things go wrong because they will regardless of how well you plan and invest in making the right security decisions.

You can then make sure you are reviewing these and acting accordingly on a regular schedule. This will ensure your organization at least has an inventory of issues that can last the individuals on a team and will make sure there is a point of conscious risk acceptance that the organization has taken.

This does not replace a full-on security program but it can at least make sure you are looking at the problem in the context of your business, your users and not just assuming every system has the same security needs.

On a related note for you startups, especially those who are operating in murky waters regarding regulation. The current regulations belong in your threat tree so you can make sure you understand them and begin to understand how they might apply to you even if you have to squint a bit to do it.