The Scale of Consequence: Storm-0558 vs DigiNotar

When we look at the Storm-0558 and DigiNotar incidents side by side, we find striking similarities in their repercussions and severity. Both cases involve significant breaches orchestrated by nation-states – China and Iran respectively, targeting critical digital infrastructure and security protocols that are designed to safeguard user data and communications.

In the case of Storm-0558, the skilled dismantling of Microsoft’s authentication infrastructure not only compromised the integrity of exchange inboxes but potentially rendered confidential information accessible to unauthorized entities.

Similarly, the DigiNotar breach constituted a severe undermining of internet security, as the attackers were able to issue trusted certificates that facilitated man-in-the-middle attacks. This compromised user interactions with sensitive services, including email communications.

Given their similar impact on user privacy and internet security, it begs the question are we treating both incidents with equal gravitas and severity?

If not we must ask the question as to why and what are the consequences of that reality?

To answer these questions it might be useful to think about a different kind of breach of trust that happened in the late 2010s where a fake vaccination campaign was used as a cover to collect DNA samples in the hunt for Osama bin Laden. That move ended up causing a lot of people in the area to give a side-eye to vaccination drives, fearing there’s more than meets the eye.

It almost feels like sometimes, big tech in the US gets to bend the rules a little, while smaller players or those from other parts of the world have to toe the line. It’s this uneven ground that can breed mistrust and skepticism, making folks doubt the systems meant to protect them.

In short, these decisions to compromise core infrastructure and come with long-term consequences that are surely not being fully considered.

The Evolution and Limitations of Hardware Security Modules


Hardware Security Modules (HSMs) have not substantially evolved in the last two decades. The advent of enclave technology, such as Intel SGX, TDX and AMD SEV, despite their weaknesses [1,2,3,4,5,6,7,8,9], has enabled some to build mildly re-envisioned versions of these devices [10]. However, the solutions currently available on the market today are far from meeting the needs of the market. In this paper, we will explore what some of the shortcomings of these devices look like and discuss how the market for them has evolved.

A Brief History of HSMs

The first Hardware Security Module was introduced in the late 1970s by IBM. It was designed to be attached to a specific host with the goal of never exposing the PINs to the host. By the early 90s, there were a handful of more capable solutions in this market, they were primarily sold to governments, often for military use cases where the cost of key compromise warranted the increased operational burden and associated costs of this particular approach.

In the late 90s, we started to see practical innovation in this space. For example, the existing HSMs moved into hosts that enabled them to be accessed over the network. We also began to recognize the need to use code containing business logic that gated the use of specific keys. nCipher was one of the first to market with a generic offering in this space which was ahead of its time.

During this time period, the US government had established itself in the area of security and cryptographic standards. It was in this decade that we saw the concept of “Military Grade” security being extensively used in marketing. At this time, the idea of a commercial security industry was in its nascent stage, and the traction that was achieved was usually with government agencies and those who provided services to governments.

As these companies expanded their sales to the rest of corporate America, they mostly pushed for adopting the same patterns that had been found to be successful in the government. In the context of key management, these physical HSMs were considered the gold standard. As cryptography was seldom used in commercial software in any extensive way, the adoption of these devices was usually limited to very high-security systems that were often largely offline and had low-volume usage, at least by today’s standards.

During the 2000s, enterprise software began to move to third-party data centers and later to the cloud. This trend continued into the 2010s and gave us SEV/SXG-based appliances offering HSM-like capabilities, as well as the first HSMs designed for some level of multi-tenancy. However, from a product standpoint, these devices were designed much like their predecessors, so they inherited many of their shortcomings while also introducing their own issues along the way.

Evolution of Development in the Era of HSMs

In the 1970s, security was not really considered a profession but rather an academic exercise at best. In the following decades, software and hardware were shipped with huge leaps of assumption, such as assuming that anything on the network that can talk to me is trusted because we share the physical network. Networks were largely closed and not interconnected at the time. It was not until the 1980s that TCP/IP was standardized, and the interconnected ecosystem of networks and devices we all know today became a reality.

During the period of technological evolution, software was often written in Assembler and C. In the late 1990s and 2000s, the concept of memory-safe languages became increasingly important. Originally, these languages required large tradeoffs in performance, but as they evolved and Moore’s Law caught up, those tradeoffs became inconsequential for most applications.

It was during this same period that security, as a whole, was evolving into both a profession and an academic specialty. One of the largest milestones in this transition was the Microsoft Trustworthy Security Memo [11], which stressed that security had to become core to the way Microsoft built software. It took the next two decades, but the industry evolved quickly at this point, and the approaches to produce secure-by-default software, as well as the technology that made it easier to create secure-by-default software, became more common.

During this time the US Government stopped being seen as a leader in security, and its role in developing cryptographic standards began to wain due to several suspected examples of the government pushing insecurities and viabilities into both standards and commercial systems.

As a result, we saw a Cambrian explosion of new cryptographic approaches and algorithms coming out of academia. The government’s role in standardizing cryptography was still strong, and the commercial and regulatory power of the government meant that products using cryptography were effectively limited to using only the algorithms approved by the government.

Around the same time, Bitcoin, cryptocurrencies, and blockchain gained momentum. As they had no interest in governments, this created a once-in-a-lifetime opportunity for the world to explore new design patterns and approaches to solving problems related to cryptography and lit a fire under researchers to further long-standing ideas like Homomorphic Encryption (HE), Multi-Party Computation (MPC), Threshold Signatures, new ECC algorithms and more.

At the same time, we saw quantum computers become far more real, which introduced the question of how the cryptography we rely on will need to change to survive this impending change. Despite the reputational damage experienced by the US government due to its shepherding of cryptographic standards in preceding years, it still had a role to play in establishing what cryptographic algorithms it will rely upon in this post-quantum world. In 2016, the government started a standardization process for the selection of post-quantum cryptographic algorithms. In 2022, they announced the first four approved PQ algorithms based on that process [12].

During this same time, we have seen a substantial increase in security in the applications and operating systems we use, as a result of improvements in the processes and techniques used to build software. Despite this, there is still a long way to go. In particular, although this is changing, a lot of development happens in non-memory safe languages, and legacy applications still see broad deployment, which makes broad assumptions on the software and operating system dependencies they rely on.

Cloud adoption has played a significant role in driving this change, with as much as half of all enterprise computing now happening on cloud service providers. With the move to cloud, the physical computing environment is no longer the primary risk when it comes to protecting keys. The focus has shifted to online access, and as recent cryptocurrency compromises have shown, it is key management, not physical key protection, that is the weak link in modern cryptographic systems.

One notable exception here is Signal. It has been designed to minimize assumptions on underlying dependencies and is seen as the most secure option for messaging. So much so that most large technology companies have adopted their design, and the IETF has standardized its own derivatives of their protocols. This, combined with the earlier trend, signals how we are not only changing the processes, languages, and tooling we use to build everyday software but also the actual designs in order to mitigate the most common vulnerabilities.

This journey is not done, the Whitehouse has recently signaled [13,14,15] it will be using its regulatory power to accelerate the move to more secure services and will be looking to “rebalance the responsibility to defend cyberspace” by shifting liability for incidents to vendors who fail to meet basic security best practices.

What does this mean for HSMs?

The evolving landscape of cybersecurity and key management has significant implications for Hardware Security Modules (HSMs). With businesses moving their computing to cloud service providers, protecting keys has shifted from a physical computing environment to online access, making key management the weak link in modern cryptographic systems.

To stay relevant and effective, HSMs need to adapt and innovate. They will become computing platforms for smart contract-like controls that gate access to keys rather than cryptographic implementations that protect from physical key isolation.

This means that the developer experience for these devices must evolve to match customers’ needs for development, deployment, and operations, including languages, toolchains, management tools, and consideration of the entire lifecycle of services that manage sensitive key material.

Additionally, the HSM industry must address the issue of true multi-tenancy, securing keys for multiple users while maintaining strong isolation and protection against potential breaches.

Moreover, the HSM industry must address the growing demand for quantum-safe cryptography as current cryptographic algorithms may become obsolete with the development of quantum computers. HSMs must support new algorithms and provide a smooth transition to the post-quantum world.

In conclusion, the HSM industry needs to continue evolving to meet the changing needs of the cybersecurity landscape. Failure to do so may lead to new entrants into the market that can better provide solutions that meet the needs of today’s complex computing environments.

What are the opportunities for HSMs?

The changing landscape of cybersecurity and key management presents both challenges and opportunities for Hardware Security Modules (HSMs). One opportunity is the increasing need for secure key management as more and more businesses move their computing to cloud service providers. This presents an opportunity for HSMs to provide secure, cloud-based key management solutions that are adaptable to the evolving needs of modern cryptography.

Furthermore, the shift towards smart contract-like controls gating access to keys presents an opportunity for HSMs to become computing platforms that can be customized to meet specific business needs. This could lead to the development of new HSM-based services and applications that can provide added value to customers.

Another opportunity for HSMs is the growing demand for quantum-safe cryptography. With the development of quantum computers, the cryptographic algorithms used today may become obsolete, requiring the adoption of new quantum-safe cryptographic algorithms. HSMs can play a critical role in providing the necessary support for these new algorithms and ensuring a smooth transition to the post-quantum world.

In addition, the increasing adoption of blockchain and cryptocurrencies presents a significant opportunity for HSMs. These technologies rely heavily on cryptographic keys for security, and HSMs can provide a secure and scalable key management solution for these applications.

Overall, the changing landscape of cybersecurity and key management presents several great opportunities for HSMs to provide innovative solutions that can meet the evolving needs of businesses and the broader cryptographic community.

Towards Greater Accountability: A Proposal for CA Issuance Decision Logs

It took us a long time, but objectively, Certificate Transparency is a success. We had to make numerous technology tradeoffs to make it something that the CAs would adopt, some of which introduced problems that took even longer to tackle. However, we managed to create an ecosystem that makes the issuance practices of the web transparent and verifiable.

We need to go further, though. One of the next bits of transparency I would like to see is CAs producing logs of what went into their issuance decisions and making this information public. This would be useful in several scenarios. For example, imagine a domain owner who discovers a certificate was issued for their domain that they didn’t directly request. They could look at this log and see an audit history of all the inputs that went into the decision to issue, such as:

  • When was the request for the certificate received?
  • What is the hash of the associated ACME key that made the request?
  • When CAA was checked, what did it say? Was it checked via multiple perspectives? Did all perspectives agree with the contents?
  • When Domain Control was checked, did it pass? Which methods were used? Was multiple perspectives used? Did all perspectives agree with the contents?
  • What time was the pre-certificate published? What CT logs was it published to?
  • What time was the certificate issued?
  • What time was the certificate picked up?

This is just an example list, but hopefully, it is enough to give the idea enough shape for the purpose of this post. The idea here is that the CA could publish this information into cheap block storage files, possibly. I imagine a directory structure something like: ” /<CA CERTHASH>/<SUBJECT CERTHASH>/log”

The log itself could be a merkle tree of these values, and at the root of the directory structure, there could be a merkle tree of all the associated logs. Though the verifiability would not necessarily be relied upon initially, doing the logging in this fashion would make it possible for these logs to be tamper-evident over time with the addition of monitors.

The idea is that these logs could be issued asynchronously, signed with software-backed keys, and produced in batches, which would make them very inexpensive to produce. Not only would these logs help the domain owner, but they would also help researchers who try to understand the WebPKI, and ultimately, it could help the root programs better manage the CA ecosystem.

This would go a long way to improving the transparency into CA operations and I hope we see this pattern or something similar to it adopted sooner rather than later.

Exploring the Potential of Domain Control Notaries for MPDV in WebPKI

In an earlier post on the Role of Multiple Perspective Domain Control Validation (MPDV) in the WebPKI, I discussed how there was an opportunity for CAs to work together to reduce the cost of meeting the upcoming requirements while also improving the security of the ultimate solution.

In this post, I want to talk a little about an idea I have been discussing for a while: specifically, Domain Control Notaries.

Before I explain the idea, let’s first look at how domain control verification (MPDV) happens. In short, the CA generates a random number and asks the certificate requestor to place that number in a location that only an administrator can access, for example, in a DNS record, in part of the TLS exchange, or in a well-known location.

If the CA is able to fetch the number, and the underlying network is living up to its promises, it can have confidence that the requestor is likely authorized for the given domain.

To understand Domain Control Notaries you will also need to have a basic understanding of what MPDV means. Thankfully, that’s easy: do that from multiple network locations and require a quorum policy to be met. This basically means that an attacker would have to tick enough of the quorum participants to bypass the quorum policy.

So that takes us back to the idea of Domain Control Notaries. As you can see, Domain Control Verification is super simple. That means you could put it on a very small computer, and it could be able to perform this simple task. For example, imagine a USB Armory that was fused at manufacturing time with firmware that only did these domain control checks. That this hardware also had a cryptographically unique key derived from the hardware fused to the device at manufacturing time.

Now imagine an aggregator handling admissions control for a network of these Domain Control Notaries. This aggregator would only allow devices that were manufactured to meet these basic requirements. It would enforce this because the manufacturer would publish a list of the public keys of each of the devices to the aggregator, which would use for admission control.

This aggregator would expose a simple REST API that would let the requestor specify some basic policy on how many of these Domain Control Notaries to broadcast their request to, what domain control methods to use, and a callback URL to be used by the aggregator when the verification is complete.

These aggregators would only accept responses from the Domain Control Notaries that signed their responses and whose keys were on this authorized list and were not added to their deny lists.

This basic framework sets you up with a network of very cheap network endpoints that can be used to perform domain control verification. You could even have a few of these aggregators each with its own Domain Control Notaries. CAs could use multiple of these aggregator networks to reduce centralization risk.

You might be asking yourself how these tiny computers could deal with the scale and performance of this task! The reality is that in the grand scheme of things, the WebPKI is relatively small! It is responsible for only 257,035 certificates every hour. The real number is actually smaller than this too because that includes some pre-certificates and in the context of domain control verification. CAs are also allowed to do some re-use of past validations if recent enough. This means we should be able to use this as a worst-case number safely. Simply put, that is only 1.18 certificates every second. That is tiny. If you spread that out over a few hundred Domain Control Notaries, the number of transactions gets that much smaller.

Then there is the question of who would run these Domain Control Notaries? A lesson learned from Certificate Transparency is that if you make it easy and cheap to participate and make it easy to both come and go, most organizations are willing to help. You’re basically asking an operator to provide a few lightbulbs of electricity and a tiny amount of network connectivity. This is easy for most organizations to sign up for since there is no tax in turning it down, and no impact if there is an outage.

Remember how I said there could be multiple aggregators? These aggregators could also expose more expensive heavy-weight nodes that were not reliant on Domain Control Notaries to provide a more reliable substrate to power such a network.

That’s Domain Control Notaries. Maybe they can be a tool to help us get to this world of MPDV everywhere.

Strengthening Domain Control Verification: The Role of Multiple Perspectives and Collaboration

The security and stability of encryption on the web rely on robust domain control verification. Certificate Authorities in the WebPKI are increasingly facing attacks that exploit weaknesses in the Border Gateway Protocol (BGP) ecosystem to acquire certificates for domains they do not legitimately control.

While Resource Public Key Infrastructure (RPKI) has the potential to mitigate these threats, its adoption is hindered by several structural barriers that have slowed its adoption.

In response, larger more security-minded CAs have started embracing the concept of Multiple Perspective Domain Control Verification (MPDV) to enhance their defenses. The fundamental idea of MPDV is that before issuing a certificate, the CA will require numerous network perspectives to agree that the domain control verification criteria have been met.

Researchers at Princeton University have played a significant role in this journey in various ways, including raising awareness about the issue, evaluating the effectiveness of different MPDV implementations, and helping determine efficient quorum policies.

This combination has led to Google Chrome signaling an intention to require MPDV from all CAs. This indicates that there is enough data to demonstrate this is both valuable and doable and I agree with this conclusion.

This new requirement will have several consequences. This is because implementing a competent MPDV solution is more difficult than it appears on the surface. For instance, these network perspectives need to be located in different networks for this to be an effective tool to mitigate these risks. One of the most expensive aspects of operating a transactional service is managing the environment in which the service runs. This means that if CAs distribute the entire MPDV checking process to alternative network perspectives, they will need to manage multiple such environments. The cost and complexity of this go up as the number of perspectives is added.

This should not be a problem for the largest CAs, and since the top 10 CAs by issuance volume account for 99.58% of all WebPKI certificates, achieving broad coverage of the web only requires a few companies to make these investments and they should be able to assume those costs. But what about the smaller CAs?

These smaller, regional CAs are often focused on language-specific support in the markets they operate in, assisting with local certificate-related product offerings such as document signing or identity certificates, and adhering to regional regulations. These are much smaller markets and leave them with far fewer resources and skills to tackle problems like this. The larger CAs on the other hand will also end up duplicating much of the same infrastructure as they worked toward meeting these requirements. 

This suggests there is an opportunity for CAs to collaborate in building a shared network of perspectives. By working together, CAs can pool resources to create a more diverse network of perspectives. This can help them meet the new requirements more efficiently and effectively, while also strengthening the internet’s overall security.

Key Management and preparing for the Crypto Apocalypse

Today, keeping sensitive information secure is more critical than ever. Although I’m not overly concerned about the looming threat of quantum computers breaking cryptography, I do worry about our approach to key management, which significantly impacts how we will ultimately migrate to new algorithms if necessary.

Traditional key management systems are often just simple encrypted key-value stores with access controls that release keys to applications. Although this approach has served us well in the past, moving away from bearer tokens to asymmetric key-based authentication and, ultimately, the era of post-quantum cryptography (PQC) demands a different approach.

Why am I concerned about bearer tokens? Well, the idea of a long-lived value that is passed around, allowing anyone who sees the token to impersonate its subject, is inherently risky. While there are ways to mitigate this risk to some extent, most of the time, these tokens are poorly managed or, worse, never changed at all. It’s much easier to protect a key that no one sees than one that many entities see.

The old key-value approach was designed around this paradigm, and although some systems have crude capabilities that work with asymmetric keys, they leave much to be desired. If we want seamless, downtime-free rollover of cryptographic keys across complex systems, we need a model that keeps keys isolated even from the entities that use them. This change will significantly improve key rollover.

This shift will require protocol-level integration into the key management layer, but once it’s done in a reusable way, keys can be changed regularly. A nice side effect of this transition is that these components will provide the integration points allowing us to move to new algorithms in the future.

What does this have to do with PQC? Unlike the shift from DES to AES or RSA to ECC, the post-quantum algorithms available now are substantially larger and slower than their predecessors, meaning the gradual migration from the once state-of-the-art to the new state-of-the-art won’t start until it absolutely has to. Instead, the migration to PQC starts by changing the way we build systems, specifically in how we architect key rollover and the lifecycle of keys. I personally believe the near-term impetus for this change will be the deprecation of bearer tokens.

The importance of seamless and automated rollover of keys is crucial for making systems secure, even if the post-quantum apocalypse never happens.

I also think we will see PQC readiness in credentialing systems. For example, we may see ACME clients support enrolling for PQC certificates simultaneously as they enroll for their ECC certificates, or perhaps support the (more bloated) hybrid certificates.

In conclusion, rethinking our key management approach is increasingly important. So far, I have not seen anyone come to market with what I would call a different approach to key management, and we need one.

The Growing Security Concerns of Modern Firmware and the Need for Change.

Today’s firmware is larger and more complex than ever before. In 1981, the IBM PC BIOS was a mere 8 KB, but now UEFI, even without considering machines with BMCs, can be 32 MB or even larger! To illustrate the magnitude of the problem, Intel will soon release its next-generation SoCs with support for 128 MB of firmware!

Essentially, UEFI has become a real-time OS with over 6 million lines of code and is still growing. This is larger than most modern operating systems. Furthermore, the various boot phases and hardware layers create significant complexity for defenders. Increased surface area leads to more vulnerabilities.

The most impactful and difficult-to-patch vulnerabilities reside in the underbelly of technology. Firmware, file systems, BGP, and other foundational aspects of technology that we often take for granted are becoming more vulnerable to attacks. It’s time to prioritize security for the very foundation of our tech. Benjamin Franklin once said, “A failure to plan is a plan to fail.” This adage often applies to long-term vulnerabilities in technology. Insufficient planning can lead to an inability to detect issues, inadequate data to assess their true severity, and a lack of responsiveness.

Firmware serves as a prime example. Many firmware-level issues remain unpatched because firmware often lacks the measurement and patching middleware we expect from software. Moreover, hardware vendors frequently behave as if their job is complete once they release a patch. Imagine if, in 2023, software vendors merely dropped a patched piece of software into a barely discoverable HTTP-accessible folder and proclaimed, “Thank goodness we’ve done our part.” This scenario largely reflects the current state of firmware.

One reason for this situation is that the problem on the surface appears intractable. A typical PC may house dozens of firmware components, with no inventory of what exists. This firmware often originates from multiple vendors and may include outdated chips that have not been updated.

Another fitting saying is, “You can’t manage what you can’t measure.” Combine this with the exponential growth of firmware surface area and the increasing number of internet-connected devices containing firmware, and you have a massive security issue arising from decades of neglect.

There is no silver bullet here. One aspect to address is the way firmware is built. USB Armory aims to solve this by making firmware memory safe, easy to read, and with minimal dependencies. While this is a positive step, it is not sufficient on its own. has created the best automation available for detecting firmware issues automatically, which is invaluable considering that old approaches will persist for decades.

To drive change, we need better measurement and widespread adoption of automatic update mechanisms for firmware of all sizes. These mechanisms must be safe, reliable, and robust. Misaligned incentives contribute to the problem, often resulting from a lack of accountability and transparency. This is why I dedicated as much time as I could to while at Google.

The momentum around software supply chain security is essential, as it sheds some light on the problem, but alone it is not enough to bring about the necessary change. If you create a chip with firmware that has a vulnerability, your responsibility does not end with shipping a patch. If you ship devices without providing a way to seamlessly patch all firmware, you are failing.

Relying on the next hardware refresh cycle to update firmware on your devices in the field is insufficient. With cloud adoption, refresh cycles might even lengthen. A long-term strategy to support your devices is necessary; not doing so externalizes the consequences of your inaction on society.

If you have devices in the field that are in use, and you don’t have a confident inventory of the dependencies that exist in them, and you’re not monitoring those dependencies and the firmware itself for issues, you are part of the problem, externalizing consequences on society.

We can do better.

To improve firmware security, the industry must collaborate and adopt best practices. This includes embracing transparency, robust patch management systems, and long-term support strategies for devices. By working together to address these challenges, we can build a more secure foundation for the technology that underpins our modern world.

In conclusion, it’s crucial that we prioritize firmware security, as it plays a fundamental role in the safety and reliability of our devices and systems. By implementing more effective measurement, automatic update mechanisms, and long-term support strategies, we can reduce the risks associated with outdated and vulnerable firmware. This will help create a safer digital environment for everyone.

P.S. Thanks to @matrosov and @zaolin for their insights on the problem on Twitter.

Global Trend in Tech Regulation and its Consequences for the EU and the US

The United States has long been a leader in technological innovation, with companies such as Google, Apple, Facebook, and Amazon paving the way. As of October 2021, 62% of global tech unicorns have emerged from the US, with China accounting for 19%, while only 12% have come from the EU. One explanation for this delta is the size of the regulatory regime in the EU, which is known to favor larger companies and make it more expensive and harder for small companies to enter the market.

It’s been only 29 years since the EU transitioned from a trading bloc to a union of 27 member states with coordinating policies. Considering the complications that such a transition represents, it’s not surprising that, relative to the US and China, the EU has more bureaucracy. However, things are changing, as there is now an adult generation that has grown up with the EU as part of their national identity. They have also seen the benefits of that partnership manifest for much of their lives. While the member states of the EU will continue to evolve how they work with each other, they have come a long way in terms of coordination and cooperation and have a solid foundation to build upon.

Another argument that I have heard is that the EU’s focus on creating a stable and cooperative union took away from the focus on technological and market growth. That may be true but over the last decade, they have focused on creating regulations they hope will create a Digital Single Market which they hope will address this problem. During this same period, the US regulatory framework largely stood still, but they also experienced the most rapid growth of technology companies of any nation during this time.

It’s worth noting that the EU’s approach to regulation has been very implementation-specific when compared to the U.S. approach to similar regulation, as seen with the EIdAS, the EU’s digital signature legislation, and the associated supporting efforts which choose which technologies must be used. The first version of which left the topic of interoperability as a footnote and ignored the concept of reciprocity. This essentially created member-state monopolies around the legislation where country-to-country transactions would still be signed on pen and paper. That did change a few years ago, but better technological approaches to solving the associated problems were established and proven since the initial legislation was proposed two decades ago, and their adoption was held back due to this legislation’s technical specificity.

On the other hand, there is a credible argument to be made that the US has failed when it comes to creating meaningful legislation to protect its citizens from the overreach of tech giants and the increasingly online nature of daily life. In fact, many would argue that, at least for the last decade, they have failed when it comes to creating meaningful legislation, period. This failure has created an opportunity for the EU to step up and leave its mark on the global technology industry, which it certainly has been doing.

What is noteworthy here is that many of these regulations are being framed as globally binding. The concept being applied here is called extraterritoriality, which basically means that the jurisdiction of the law extends beyond the physical borders of the country or region that has enacted it. The argument is that by extending the reach of its laws to cover EU citizens wherever they may be, they are protecting the rights of its citizens and promoting a level playing field for all companies, regardless of where they are based.

But what is a regulation without teeth? This is why these regulations usually empower the EU member states to impose fines on companies, regardless of where they exist, if the associated regulations are found not to have been met. The trend to leverage extraterritoriality is sure to continue and likely accelerate. In the case of security, one such upcoming regulation from the EU is NIS2, which is looking to regulate incident response handling, again with potential fines for non-compliance.

It’s not to say that all of this EU legislation is bad, though I would argue that the more explicit it is on technical details, the worse it is. For example, consider the EU Cookie legislation–it has resulted in the online equivalent of graffiti all over the internet with no meaningful improvement for users.

As I think about this, one of the things I struggle with is that the geographic nexus of a business is increasingly not relevant to users. In one respect, this is an argument for exactly what the EU is doing. But there are also 195 sovereign nations, each with its own cultural norms and political interests. Can they all regulate online businesses regardless of where they are located? What will the long-term effects of this global regulatory trend be?

Of course, the answer is that only those countries that have enough financial clout to get away with this, but even then, would the EU want its businesses regulated in this way by the US or China? And what do you do when the regulations conflict? Does the future require proof of citizenship before using any online service?

The Importance of Proper Measurement in Enterprise IT Management: Lessons from Cloud Deployments

Peter Drucker once said, “You cannot manage what you cannot measure.” This quote is applicable in many aspects of technology development and business management. Neglecting measurement often leads to problems. Another relevant saying is “Lies, damned lies, and statistics.” The importance of what we measure and how we measure it cannot be overstated when using data to manage complex systems.

In enterprise IT, endpoint management systems are often touted as the source of truth for the environment, but this is misleading. They measure the intended state of the devices, not their actual state. In other words, they track what they believe they have done, rather than whether the change was correctly and successfully deployed. This might seem similar or sufficient, but it is not. Endpoint systems have many different software and settings that can interact in unexpected ways, making the data they provide nearly useless for risk assessment, according to most security professionals.

As for EDR systems, I would argue that they are simply advanced anti-viruses. They try to protect the operating system which is largely intractable. give the enterprise visibility to attacks and infections, while providing minimal tools for a response. To be clear EDR is valuable, but its overhead is high and it is not designed for device intelligence or observability; its purpose is detection and response.

If enterprises had proper investments in observability, they could discover outages before users report them. They could use the intelligence about the state and usage of their devices to proactively defend and isolate their assets, turning what has been a reactive and inaccurate dataset into a tool to protect their networks and improve user productivity.

There is a lot to learn from Cloud deployments when looking at how to solve these problems. For example, unlike most IT departments, cloud assets are heavily instrumented with logs being centralized, with dashboards reporting real-time uptime and health. There is an entire market of solutions focused on enabling this visibility, just consider how many log aggregation and analytics offerings such as Stackdriver, CloudWatch, and New Relic exist. 

Additionally, these assets typically have cross-platform machine identities that are used to facilitate security domain separation, and interestingly these identities are increasingly using hardware-backed keys to secure those credentials. These credentials are also used to help each endpoint in those deployments achieve some basic level of self-protection, where the credentials used by these assets will capture the posture of the machines and the peers they interact with, particularly when crossing security domains and enforcing policy based on these interactions.

I believe that over the next decade, enterprise IT deployments will increasingly resemble cloud deployments, with a focus on zero-trust design patterns. However, for that to happen there are product gaps that will need to be filled. For example, there is no turnkey solution for desktop state observability with structured data that can be used for real-time policy decisions. The big tech companies have built these solutions for their own deployments but there is nothing turnkey in the market that addresses this need. Then there is the issue of how to authenticate the device and its state. There are lots of pieces in this area but no solutions. If you are going to use the observed device state for the policy you also have to worry about the validity of the associated data, while this is not possible in existing systems to totally solve this problem there are lots of things that can be done to make data more reliable.

Finally, as we see this evolution, there is a need to rethink the way enterprises approach identity. It will become an alternative to Active Directory. No security practitioner would design their source of truth in the enterprise in the same way as Active Directory is today.

The Changing Landscape of Internet Protection

The United States government and big companies like Google have both played a significant role as protectors in their respective spheres. The US government, as the world’s leading military power, has tried to serve as a global peacekeeper and defender of democracy through its high military spending. Similarly, Google, as a success in the technology industry, has leveraged its financial power from advertising to fund various initiatives to protect and grow the internet and the web.

However, in recent years, Google has undergone significant changes. The COVID-19 pandemic accelerated the need for companies to adapt and re-envision themselves, and Google was no exception. The company, in a relatively short period, hired many externally sourced professional managers and underwent a series of re-organizations and corresponding cultural changes that have fundamentally changed the company forever. This, combined with recent fiscal irresponsibility in hiring, and inability to drive a cohesive and integrated product strategy (how many messengers does one company need after all?), led to Google’s first-ever layoffs, which included a significant impact on internet investments, and being transparent my own job.

This raises important questions about the future of internet protection. While Google was clearly not the exclusive protector of the internet, its direct and indirect investments in the internet have played a significant role in protecting it. It seems unlikely that moving forward, they can be counted on in the same way. We need to see other large organizations whose businesses similarly take a critical dependency on a safe and secure internet step up and fill the gap.

This is problematic for a number of reasons, one of the largest being that public companies are, to a fault, focused on quarter-to-quarter growth. That is of course the right thing for their shareholders, at least in the near term, but the sort of infrastructure investments necessary to secure the Internet can take a decade or more of investment. That’s quite hard for an organization to justify when the most valuable resource they have is engineers when those engineers can be spent working on securing and improving their private networks or directly generating revenue.

Many of these organizations already donate to security non-profits such as ISRG and OpenSSF and work through them to make some of these improvements to the Internet, but the funding to these organizations is often piecemeal and usually only aligned with the latest security trends. Furthermore, these investments are often associated with pet projects of the sponsoring companies rather than taking a strategic and proportional investment into different problem areas. A great example of this is how many of the most important open-source projects lack the basic funding necessary to sufficiently secure them long-term.

One approach to mitigating this is to lean on these security non-profits more and give them more autonomy and funding. This would allow them to take on a larger and more independent role via a larger commitment to funding with appropriate multi-year roadmaps, milestones, and success criteria approved by some mix of funding stakeholders invited experts in the specific areas in question and key engineering participants from relevant funding organizations. This would create predictable funding and a space where long-term roadmaps for research, securing, and improving the internet can be established without relying on a small number of companies with business models that support direct investment in those activities.

This approach would have its own challenges, for example, like most non-profits, these organizations will struggle to be impact focused rather than focused on their own pet projects or philosophies. That said, this is largely part of the human condition and something that always needs to be managed. The answer to how to manage this is surely buried in what systematic approach is used for choosing initiatives, measuring their success, and having lots of meaningful milestones along the way to enable them to checkpoint, course correct and the will power kill projects as appropriate.

In summary, the role of a protector comes with great responsibility. The recent changes at Google highlight the need for a diverse set of stakeholders to come together to safeguard the internet and the web and take less dependency on one company carrying too large of the load when it comes to protecting the internet.