Sunday, August 22, 2010

Inappropriate network access is a material weakness?

I recently found a very interesting KPMG audit findings report on Fema which is the Federal Emergency Management Agency. The reason for this audit report being interesting was not as much the auditing target as the content of the audit report.

What did KPMG find during their audit?
During our audit engagement, we noted certain matters in the areas of security management, access controls, configuration management, and contingency planning with respect to FEMA’s financial systems information technology (IT) general controls which we believe contribute to a DHS-level significant deficiency that is considered a material weakness in IT controls and financial system functionality. These matters are described in the IT General Control and Financial System Functionality Findings by Audit Area section of this letter.

This clearly sounds interesting. Now lets look in the "IT General Control and Financial System Functionality Findings" in the access control section and see what is says.
Password, security patch management, and configuration deficiencies were identified during the vulnerability assessment on hosts supporting the key financial applications and general support systems; 
Core IFMIS, G&T IFMIS, NEMIS, and PARS application and/or database accounts, network, and remote user accounts were not periodically reviewed for appropriateness, resulting in inappropriate authorizations and excessive user access privileges. For G&T IFMIS, we determined that recertification of user accounts had not been conducted since the application was implemented at FEMA in FY 2007; 
Financial application, network, and remote user accounts were not disabled or removed promptly upon personnel termination; 
Initial and modified access granted to Core and G&T IFMIS financial application and/or database, network, and remote users was not properly documented and authorized;
What does this really mean? A "material weakness" is something that can in the long run could lead to a financial misstatement occurring. If you are a US based public company this would be very bad as post SOX that could lead to your CFO having to go to prison. CFOs generally don't like prison, not even club Fed, so they tend to be motivated to have "material weaknesses" fixed as soon as possible.

Usually the CFO and the auditors will give you some respite if you show signs of material progress towards the goal but if you totally ignore the problem they will not be pleased.

The first thing that struck me when reading the report is that there seems to be a shift from "random data sampling auditing" to "auditing of the process".

Traditionally IT auditing has largely been done the same way as traditional financial auditing. When I was in college I helped out my student union by serving as an "amateur auditor" for the different societies that was run by the student union. This was mostly things like "the society that arranges parties" and "the other slightly different society that arranges parties as well". In many cases the societies where better at arranging parties than keeping books so my job was to try to make the treasurers to at least keep some kind financial records.

The audit process was quite simple. First you check that the general ledger exists and that there are transaction records connected to the general ledger (hundreds of receipts and income records in a shoebox does not count) . Secondly you picked a five to ten transactions at random and checked if the transactions sounded reasonable i.e. the beer that was bought was reasonable prized and it looked like most of it was sold to the students after a reasonable length of time (drunk by the party association members themselves does not count).

IT auditing has up until now largely followed the same pattern. First the very high level processes are checked for existence (i.e. a process for how to give out accounts to new employees exists) and then a number of provisioning events and termination events are controlled in detail. Even if your processes coverage is really bad and you have a lot of transactions that totally bypasses your "official" processes you usually won't be caught because in most cases the auditing is done based on events initiated by the trusted source, i.e. your HR system, and therefor followed your official processes.

If you look at the findings it is clear that KPMG looked substantially deeper at the core business processes such as initial provisioning, access level update and termination. They are also saying that a number of processes i.e. access recertification simply is mandatory and must be performed.

In my next postings I will take a little closer look at each issue found by KPMG and talk a bit about how to solve the issues that they point out.

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