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CISA and FBI Call for Public Comment on Product Security Bad Practices to Enhance Cyber Resilience

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On October 12, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) and the Federal Bureau of Investigation (FBI) released a critical document for public comment: the “Product Security Bad Practices” catalog. This initiative, aimed at strengthening national cybersecurity, highlights harmful software development practices that expose critical infrastructure and organizations to malicious cyberattacks. By encouraging software manufacturers to avoid these risky practices, especially in systems supporting critical national functions (NCFs), this guidance is an essential step toward improving software security.

This announcement underscores the growing concern over the software vulnerabilities that continue to fuel cyberattacks against hospitals, schools, government facilities, and other key sectors. The public comment period runs until December 2, 2024, offering stakeholders the opportunity to contribute their insights to shape the future of cybersecurity.

The Push for Secure by Design

The “Product Security Bad Practices” catalog is part of CISA’s broader “Secure by Design” initiative, which promotes the development of secure software by default. With increasing attacks on critical infrastructure, ranging from healthcare facilities to energy providers, the emphasis on software manufacturers taking accountability for the security of their products is greater than ever.

In the last year alone, cybercriminals have exploited software vulnerabilities, leading to high-profile attacks like the disruption of hospital services and network breaches in major industries. Jen Easterly, Director of CISA, noted: “In 2024, preventable software defects should no longer be the norm, yet they continue to wreak havoc. The bad practices outlined in this catalog are all too common, but they pose unacceptable risks.”

Similarly, Bryan Vorndran, Assistant Director of the FBI’s Cyber Division, emphasized the national security implications of insecure software: “Bad practices in software development expose our infrastructure to vulnerabilities that are routinely exploited by malicious actors. Software manufacturers must take immediate action to prevent these vulnerabilities from being baked into their products.”

The Catalog: Three Key Categories of Bad Practices

CISA’s new catalog identifies specific software development pitfalls that need to be avoided to bolster security. The practices are divided into three primary categories:

  1. Product Properties: These refer to the inherent qualities of the software that can create security risks. Examples include software lacking secure default settings or those with unprotected default credentials.
  2. Security Features: The catalog also points out weaknesses in security functionalities, such as inadequate encryption mechanisms, lack of multifactor authentication, or insufficient patch management systems.
  3. Organizational Processes and Policies: This category targets the governance side of software development, urging manufacturers to foster transparency, implement security-first policies, and ensure continuous security assessments throughout the software development lifecycle.

A Collective Effort for Safer Products

The “Secure by Design” initiative already has over 220 software manufacturers committed to making security a priority. This latest step aims to expand that commitment globally. By encouraging public feedback, CISA and the FBI hope to further refine this list of bad practices and provide even more comprehensive guidance to software developers worldwide.

These bad practices are particularly critical in sectors that impact national critical functions (NCFs), such as telecommunications, healthcare, finance, and energy. The focus on public comment allows cybersecurity professionals, software developers, and stakeholders to share their expertise and help craft a robust final document that is both effective and practical.

Ten Tips to Avoid Security Risks in Software Development:

To prevent software vulnerabilities and reduce the threat of cyberattacks, software manufacturers and organizations can follow these essential practices:

  1. Adopt Secure by Design Principles: Integrate security into the development process from the beginning rather than adding it as an afterthought.
  2. Regular Security Audits: Conduct frequent security audits to identify and patch vulnerabilities in code before attackers can exploit them.
  3. Implement Multifactor Authentication (MFA): Ensure that products support and require MFA for all access points, making unauthorized access more difficult.
  4. Use Strong Encryption: Implement robust encryption protocols for data both in transit and at rest, minimizing the risk of data breaches.
  5. Frequent Patch Management: Establish a rapid patch management process to address vulnerabilities as soon as they are discovered.
  6. Test for Default Credentials: Ensure that default passwords and credentials are removed or changed, as these are frequently exploited by attackers.
  7. Provide Transparency in Security Practices: Communicate openly with users about security features and updates to build trust and empower users to protect their systems.
  8. Emphasize Threat Modeling: Conduct regular threat modeling to anticipate potential attack vectors and preemptively address weaknesses.
  9. Foster a Security Culture: Encourage a strong security-first mindset throughout the organization, with continuous training and awareness programs.
  10. Establish a Bug Bounty Program: Engage with ethical hackers through bug bounty programs to identify vulnerabilities that internal teams may overlook.

Conclusion:

CISA and the FBI’s “Product Security Bad Practices” catalog is an essential tool in the ongoing battle to secure our critical infrastructure and digital systems. By providing a clear framework for identifying and avoiding dangerous software development practices, this guidance not only supports the cybersecurity community but also reinforces the shared responsibility between software manufacturers and end-users.

As cyber threats continue to evolve, collaborative efforts between government agencies, the private sector, and the cybersecurity industry are vital. The public comment period represents a unique opportunity for professionals to contribute to the creation of stronger, more secure software, ensuring that products critical to national security are safeguarded against evolving threats.

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Ouaissou DEMBELE
Ouaissou DEMBELEhttp://cybercory.com
Ouaissou DEMBELE is a seasoned cybersecurity expert with over 12 years of experience, specializing in purple teaming, governance, risk management, and compliance (GRC). He currently serves as Co-founder & Group CEO of Sainttly Group, a UAE-based conglomerate comprising Saintynet Cybersecurity, Cybercory.com, and CISO Paradise. At Saintynet, where he also acts as General Manager, Ouaissou leads the company’s cybersecurity vision—developing long-term strategies, ensuring regulatory compliance, and guiding clients in identifying and mitigating evolving threats. As CEO, his mission is to empower organizations with resilient, future-ready cybersecurity frameworks while driving innovation, trust, and strategic value across Sainttly Group’s divisions. Before founding Saintynet, Ouaissou held various consulting roles across the MEA region, collaborating with global organizations on security architecture, operations, and compliance programs. He is also an experienced speaker and trainer, frequently sharing his insights at industry conferences and professional events. Ouaissou holds and teaches multiple certifications, including CCNP Security, CEH, CISSP, CISM, CCSP, Security+, ITILv4, PMP, and ISO 27001, in addition to a Master’s Diploma in Network Security (2013). Through his deep expertise and leadership, Ouaissou plays a pivotal role at Cybercory.com as Editor-in-Chief, and remains a trusted advisor to organizations seeking to elevate their cybersecurity posture and resilience in an increasingly complex threat landscape.

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