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Compensating Controls in OT Security

How and when to apply OT/ICS compensating controls when software patching is not an option in industrial cybersecurity.

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The Misguided Notion of Bypassing Patching in OT Systems

Patching Operational Technology (OT) systems is an undeniably challenging task. This difficulty leads those in the OT security industry to advocate for alternative security strategies, such as alerting technologies with a strong OT security incident response team

. This can lead OT security professionals to wonder why they should bother with patching.

This conclusion is flawed for several reasons and also glosses over a big factor that significantly complicates any response or remediation. Neglecting patching leaves systems vulnerable, resulting in potentially devastating consequences such as downtime, financial losses, and safety and environmental risks.

Fortunately, there is an alternative for critical infrastructure when patching isn’t an option—and it’s compensating controls. This post will dive into the need for patching, foundations for effective management, where compensating controls come into play, and a real-world example.

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Patching Is Hard But Necessary in OT Security

Ignoring Patching is Not an Option

The primary flaw in this advice is the notion to ignore OT patching. This is a dangerous misconception. Patching may be challenging, but it remains an essential line of defense. When immediate patching isn’t feasible, you should put alternative plans in place. Neglecting patching altogether can lead to severe consequences in a cyber incident, reminiscent of the outdated ‘M&M defense’ strategy – tough on the outside but vulnerable inside.

Challenges: OT Network Complexity and Skilled OT Security Resource Gap

Another critical oversight is the assumption that skilled OT security personnel are readily available for patching or response. This is far from the truth. In many cases, even when patches are ready, there may be a lack of qualified experts to implement them. This gap in resources raises questions about the viability of assembling an adequate incident response team, especially when proactive patch management is already struggling.

The complexities of OT networks add another layer of difficulty to patch management. The sheer number and intricacy of assets and network architecture present a significant challenge. Identifying which assets are affected by a specific patch or vulnerability is often a daunting task for organizations. Yet, an effective incident response strategy often demands this level of understanding and detailed asset profiling. Ironically, even those advocating against patching require a comprehensive, contextual asset inventory, which is, a fundamental component of a sound OT cybersecurity strategy.

Let’s not forget that critical infrastructure may be decades old and not have the capacity to support modern tech. In addition, shutting down this infrastructure can result in downtime—leading to a dip in productivity and lost revenue.

3 Elements of a Mature Industrial Control System Patch Management Program

While patching is challenging, it’s not impossible. A mature OT patch management program, success hinges on three key elements:

Real-time, contextual inventory
Automation of remediation
Effective use of compensating controls

Understanding and implementing these components can transform patching into a more feasible and successful process. Let’s delve into each of these components and see how they contribute to a robust patch management strategy.

Real-time Contextual Inventory: The Foundation of Effective Patch Management

In OT, standard scan-based patching tools like WSUS/SCCM are common but may often fall short of providing deep insights into the assets. What can be truly beneficial is an in-depth asset profile that includes operational context. This means going beyond basic details like IP addresses, models, and operating systems. The real value lies in understanding each asset’s criticality, location, and ownership. This comprehensive view is important for correctly assessing and managing emerging risks, as not all OT assets are equally vulnerable or critical.

As we build these detailed asset profiles, it is important to gather extensive information about each asset. This includes data on installed software, user accounts, network ports, services, registry settings, least privilege controls, antivirus status, allowlisting, and backup status. Such detailed information can greatly enhance our capacity to prioritize and strategize our response to new risks accurately. With a comprehensive understanding of your assets, you can begin to streamline the patching process through automation.

Automating Remediation: Streamlining the Patching Process

The task of deploying patches or compensating controls is often labor-intensive, involving the identification of target systems, configuring patch deployment, and troubleshooting failures. Consider a threat like BlueKeep, where files are pre-loaded onto targeted systems in preparation. A nimble OT security team could then strategically plan the order of patch updates, guided by the detailed asset profiles. This planning could consider factors such as the asset’s location or criticality.

Envision further a patch management system that bypasses the initial scanning phase, having already identified the assets needing patches. This system could facilitate remote or in-person installations, verifying their success and updating the global dashboard in real time.

Compensating Controls: The Alternative When Patching Isn’t Feasible

For high-risk assets that cannot be patched immediately, the creation of ad-hoc compensating controls becomes a pivotal strategy. An example includes disabling remote desktop services or guest accounts in light of a critical vulnerability. This may drastically reduce immediate risks and buy time for patch preparation.

Bottom line: Compensating controls in OT environments are not merely stop-gap measures but integral components of a well-rounded patch management strategy.

Compensating Controls: A Vital Layer in OT Cybersecurity

Defining and Implementing Compensation Controls in OT Security

Think of compensating controls like a multi-layered defense system that’s deployed when direct solutions are not viable or could harm critical infrastructure with uptime requirements.

On the simpler side, we have actions such as application allowlisting and ensuring antivirus software is always updated. Moving towards more complex measures, there’s endpoint management—keeping a vigilant eye on each network-connected device for security vulnerabilities, and system hardening—which involves reinforcing the defenses of individual systems against potential threats. These compensating controls are crucial because they give us the flexibility and strength to bolster our OT security against various types of cyber risks.

Types of Compensating Controls in OT Security

Compensating controls aren’t fallback options, but proactive measures to strengthen defenses and address vulnerabilities. Let’s break down their scope.

Endpoint Management

Endpoint management involves meticulously monitoring and managing endpoint devices

. The aim is to keep these devices updated and protected against known vulnerabilities, verifying they only have required access.

Why it matters: Endpoints are some of the weakest links in OT networks. Protecting these devices can reduce opportunities for attackers to access your critical systems.

You can implement this type of compensating control by:

Keeping an inventory of all hardware and software endpoint devices
Allowing only approved applications to run on the endpoints
Using tools to maintain compliance and implementing strict configuration baselines for endpoints
Collecting logs from endpoints to identify suspicious activity
Deploying passive scanning tools to further identify vulnerabilities

System Hardening

System hardening involves strengthening the systems to make them more resilient to cyberattacks.

Why it matters: Hardening can make systems more resistant to exploits and malware.

You can implement system hardening by:

Developing the minimum security requirements for baseline configurations for your OT systems
Disabling services not required for system operation
Closing unused network ports
Granting users the minimal necessary access
Conducting regular security audits to identify vulnerabilities and ensure requirements

Network Segmentation

Network segmentation is a defense in depth strategy that isolates critical systems by dividing the network into distinct segments

Why it matters: Segmentation helps protect systems by containing breaches and limiting the damages caused by them.

You can implement network segmentation by:

Identifying your most critical control and safety systems within your OT network
Using firewalls and VLANs to create separate network segments
Implementing strict access control policies between segments
Monitoring traffic between segments regularly to detect suspicious activity

User Account and Access Control

User account and access control regularly checks and adjusts user access rights through measures like multi-factor authentication (MFA) and regular access reviews.

Why it matters: Unauthorized access can lead to data breaches and system disruptions. By implementing and maintaining effective access control, organizations can lower their risk and help protect themselves from insider threats and external attacks

You can implement user account and access control by:

Requiring regular password changes
Implementing MFA for all critical systems and accounts
Assigning user access rights based on roles and responsibilities
Using centralized identity management systems to oversee user access

Regular Backups and Data Encryption

Regular backups and data encryption are just like they sound: They consistently backup data and encrypt it.

Why it matters: Backups allow you to restore systems and data after a cyberattack, while encryption helps protect sensitive data from unauthorized access.

You can implement regular backups and data encryption by:

Confirming the most critical data that needs to be backed up
Automating backups on a regular schedule
Storing backups offline or in a secure, separate network segment
Encrypting all in-progress or resting sensitive data
Conducting regular backup tests

Proactive and Situational Use of Compensating Controls

It’s important to deploy controls before a threat arises (proactively) and in response to specific situations (reactively). For instance, routine system checks might reveal dormant admin accounts or outdated software, which are vulnerabilities that can be mitigated through compensating controls.

Real-World Example: The BlueKeep Vulnerability Response

Imagine a scenario where a cybersecurity risk similar to the BlueKeep vulnerability emerges. For those unfamiliar, BlueKeep

was a significant security vulnerability discovered in Microsoft’s Remote Desktop Protocol, posing a serious risk to unpatched systems by potentially allowing unauthorized access.

Now, let’s walk through how a prepared team could effectively handle an OT security incident response, illustrating the strategic use of compensating controls and proactive patch management:

Proactive Preparation for Emergent Risks

Pre-Loading Patch Files: Suppose a new risk akin to BlueKeep is identified. Your first step could be to pre-load the necessary patch files onto all target systems. This preloading doesn’t mean immediate action, but it does prepare you for swift deployment.
Strategic Patch Deployment: Imagine your OT security team, agile and informed, assessing which industrial systems to update first. This decision is based on a range of factors from your robust asset profiles, like the location of the assets or their criticality.
Advanced Patch Management Technology: Now, envision a scenario where your patch management technology is so advanced that it doesn’t require a preliminary scan. Instead, it has already identified which assets are in the scope of the new patch. As you deploy these patches, whether remotely for low-risk assets or in person for high-risk ones, the technology verifies each patch’s success and updates your global dashboard in real time.

Implementing Compensating Controls for High-Risk Assets

But what about those high-risk assets you can’t patch immediately? This is where compensating controls come into play.

Ad-Hoc Measures for Immediate Risk Reduction: For a vulnerability like BlueKeep, you might disable remote desktop services or guest accounts on these high-risk assets. This simple yet effective action can significantly reduce the immediate risk, buying time for a more comprehensive patching strategy.
Fallback Actions When Patching Isn’t an Option: These compensating controls act as critical fallback actions. They’re not just stop-gap measures; they’re strategic choices that can allow you to maintain security even when immediate patching isn’t feasible.

By integrating these proactive and strategic approaches, your OT security team becomes capable of not just reacting to threats, but anticipating and preparing for them, bolstering the resilience and continuity of your operations in the face of potential cybersecurity challenges.”

Compensating Controls: A Key to Robust Cybersecurity

The strategy behind employing compensating controls is not merely a reactive stance to threats—it’s a proactive philosophy that complements traditional patching methods. These controls allow for an adaptable approach to securing OT systems, where understanding the network’s layout and each asset’s role informs the application of both patching and compensating controls. This method isn’t just about dealing with threats as they come; it’s about anticipating and preparing for them. The integration of these controls into your cybersecurity framework enhances resilience and helps protect critical infrastructure, helping to maintain operational continuity against a backdrop of evolving cyber threats.

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Published March 7, 2025