On the Cyber Safety Review Board
When an airplane crashes, impartial investigatory bodies leap into action, empowered by law to unearth what happened and why. But there is no such empowered and impartial body to investigate CrowdStrike’s faulty update that recently unfolded, ensnarling banks, airlines, and emergency services to the tune of billions of dollars. We need one. To be sure, there is the White House’s Cyber Safety Review Board. On March 20, the CSRB released a report into last summer’s intrusion by a Chinese hacking group into Microsoft’s cloud environment, where it compromised the U.S. Department of Commerce, State Department, congressional offices, and several associated companies. But the board’s report—well-researched and containing some good and actionable recommendations—shows how it suffers from its lack of subpoena power and its political unwillingness to generalize from specific incidents to the broader industry.
Some background: The CSRB was established in 2021, by executive order, to provide an independent analysis and assessment of significant cyberattacks against the United States. The goal was to pierce the corporate confidentiality that often surrounds such attacks and to provide the entire security community with lessons and recommendations. The more we all know about what happened, the better we can all do next time. It’s the same thinking that led to the formation of the National Transportation Safety Board, but for cyberattacks and not plane crashes.
But the board immediately failed to live up to its mission. It was founded in response to the Russian cyberattack on the U.S. known as SolarWinds. Although it was specifically tasked with investigating that incident, it did not—for reasons that remain unclear.
So far, the board has published three reports. They offered only simplistic recommendations. In the first investigation, on Log4J, the CSRB exhorted companies to patch their systems faster and more often. In the second, on Lapsus$, the CSRB told organizations not to use SMS-based two-factor authentication (it’s vulnerable to SIM-swapping attacks). These two recommendations are basic cybersecurity hygiene, and not something we need an investigation to tell us.
The most recent report—on China’s penetration of Microsoft—is much better. This time, the CSRB gave us an extensive analysis of Microsoft’s security failures and placed blame for the attack’s success squarely on their shoulders. Its recommendations were also more specific and extensive, addressing Microsoft’s board and leaders specifically and the industry more generally. The report describes how Microsoft stopped rotating cryptographic keys in early 2021, reducing the security of the systems affected in the hack. The report suggests that if the company had set up an automated or manual key rotation system, or a way to alert teams about the age of their keys, it could have prevented the attack on its systems. The report also looked at how Microsoft’s competitors—think Google, Oracle, and Amazon Web Services—handle this issue, offering insights on how similar companies avoid mistakes.
Yet there are still problems, with the report itself and with the environment in which it was produced.
First, the public report cites a large number of anonymous sources. While the report lays blame for the breach on Microsoft’s lax security culture, it is actually quite deferential to Microsoft; it makes special mention of the company’s cooperation. If the board needed to make trades to get information that would only be provided if people were given anonymity, this should be laid out more explicitly for the sake of transparency. More importantly, the board seems to have conflict-of-interest issues arising from the fact that the investigators are corporate executives and heads of government agencies who have full-time jobs.
Second: Unlike the NTSB, the CSRB lacks subpoena power. This is, at least in part, out of fear that the conflicted tech executives and government employees would use the power in an anticompetitive fashion. As a result, the board must rely on wheedling and cooperation for its fact-finding. While the DHS press release said, “Microsoft fully cooperated with the Board’s review,” the next company may not be nearly as cooperative, and we do not know what was not shared with the CSRB.
One of us, Tarah, recently testified on this topic before the U.S. Senate’s Homeland Security and Governmental Affairs Committee, and the senators asking questions seemed genuinely interested in how to fix the CSRB’s extreme slowness and lack of transparency in the two reports they’d issued so far.
It’s a hard task. The CSRB’s charter comes from Executive Order 14208, which is why—unlike the NTSB—it doesn’t have subpoena power. Congress needs to codify the CSRB in law and give it the subpoena power it so desperately needs.
Additionally, the CSRB’s reports don’t provide useful guidance going forward. For example, is the Microsoft report provides no mapping of the company’s security problems to any government standards that could have prevented them. In this case, the problem is that there are no standards overseen by NIST—the organization in charge of cybersecurity standards—for key rotation. It would have been better for the report to have said that explicitly. The cybersecurity industry needs NIST standards to give us a compliance floor below which any organization is explicitly failing to provide due care. The report condemns Microsoft for not rotating an internal encryption key for seven years, when its standard internally was four years. However, for the last several years, automated key rotation more on the order of once a month or even more frequently has become the expected industry guideline.
A guideline, however, is not a standard or regulation. It’s just a strongly worded suggestion. In this specific case, the report doesn’t offer guidance on how often keys should be rotated. In essence, the CSRB report said that Microsoft should feel very bad about the fact that they did not rotate their keys more often—but did not explain the logic, give an actual baseline of how often keys should be rotated, or provide any statistical or survey data to support why that timeline is appropriate. Automated certificate rotation such as that provided by public free service Let’s Encrypt has revolutionized encrypted-by-default communications, and expectations in the cybersecurity industry have risen to match. Unfortunately, the report only discusses Microsoft proprietary keys by brand name, instead of having a larger discussion of why public key infrastructure exists or what the best practices should be.
More generally, because the CSRB reports so far have failed to generalize their findings with transparent and thorough research that provides real standards and expectations for the cybersecurity industry, we—policymakers, industry leaders, the U.S. public—find ourselves filling in the gaps. Individual experts are having to provide anecdotal and individualized interpretations of what their investigations might imply for companies simply trying to learn what their actual due care responsibilities are.
It’s as if no one is sure whether boiling your drinking water or nailing a horseshoe up over the door is statistically more likely to decrease the incidence of cholera. Sure, a lot of us think that boiling your water is probably best, but no one is saying that with real science. No one is saying how long you have to boil your water for, or if any water sources more likely to carry illness. And until there are real numbers and general standards, our educated opinions are on an equal footing with horseshoes and hope.
It should not be the job of cybersecurity experts, even us, to generate lessons from CSRB reports based on our own opinions. This is why we continue to ask the CSRB to provide generalizable standards which either are based on or call for NIST standardization. We want proscriptive and descriptive reports of incidents: see, for example, the UK GAO report for the WannaCry ransomware, which remains a gold standard of government cybersecurity incident investigation reports.
We need and deserve more than one-off anecdotes about how one company didn’t do security well and should do it better in future. Let’s start treating cybersecurity like the equivalent of public safety and get some real lessons learned.
This essay was written with Tarah Wheeler, and was published on Defense One.