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Questions to be addressed:
4
Questions to be addressed:
1) What kinds of products would be described in proposed control list entries ECCN 4A005 and 4D004 that should not be controlled?
2) Is there a way to interpret the existing language to not control these things?
3) If not, what changes to the control text, including to the definition of "intrusion software," would be required to ensure that those items are not controlled?
Penetration Testing Software: An Annoying Amount of Detail in 15 Minutes
History: Immunity and Penetration Testing Tools
"Unauthorized"
History: Who am I?
Text cannot be "interpreted" to avoid penetration testing software
3) If not, what changes to the control text, including to the definition of "intrusion software," would be required to ensure that those items are not controlled?
Covered by "Intrusion Software"
CANVAS, INNUENDO and SILICA
We are in the unusual situation of regulating as "intrusion software" more things that are almost never used for real intrusions than things that are.
4.E.1.c.
“Technology” for the development of “intrusion software”.
“intrusion software”
“software” specially designed or modified to
AVOID DETECTION by 'monitoring tools' or to DEFEAT 'protective countermeasures'
and
Performing any of the following :
EXTRACTION of data or information or MODIFICATION of system or user data
or
MODIFICATION of the standard execution path of a program or process in order to allow the EXECUTION of externally provided instructions.
We are all more secure when we know the ground truth about our security
Potentially covered a lot of research software needed to understand risk.
The Unspoken Casualty: custom tools, which are often used for commercial consulting
Why not?
A word about El Jefe
Penetration Testing is explicitly as close to malware as possible, including avoiding counter-measures
While not aiming to defeat countermeasures initially, when you detect an intrusion, you often want to "go dark" and install things which cannot be easily detected or monitored - next-gen CrowdStrike/Mandiant/El Jefe are all potentially covered by the regulation!
Dave@immunityinc.com - 786-263-9749 - @daveaitel