Archive for the ‘Security and Compliance’ category

Data security – how secure should we be?

December 9th, 2017

The back story to this is that a British politician (Damian Green) is presently in hot water for allegedly accessing porn on his gov PC. U.K> politician https://twitter.com/NadineDorries recently tweeted :

Nadine Dorries
✔ @NadineDorries

My staff log onto my computer on my desk with my login everyday. Including interns on exchange programmes. For the officer on @BBCNews just now to claim that the computer on Greens desk was accessed and therefore it was Green is utterly preposterous !!

10:03 PM – Dec 2, 2017 “

So Nadine is implying it could have been someone else on his PC using his identity.

So should politicians share passwords? What are the problems with doing so? So what about your own staff?
Well it seems the practice is widespread -read here for example: https://www.troyhunt.com/the-trouble-with-politicians-sharing-passwords/?utm_source=DBW&utm_medium=pubemail

It’s an interesting read, and certainly points out that the expediency for users to share a workload but it has plenty of downsides in accountability and auditing of actions.

I see little excuse for sharing security credentials in UK government – there are other solutions to handle this issue.

I am more sympathetic in real time environments, like hospitals, where the login process might literally cause a death in the event of a delay.

Authentication aside we often share data among individuals inside of an organization. Outside of sysadmins, not be many people really understand or consider who should have access, let alone who does have access, to some data.

Over time organizations tend to lean towards allowing an ever-growing number of people having access to data in file shares. Knowledge gives power to take decisions- functional silos are out ….but segmentation of duty, compliance, are the other side of the argument. In these days of self serve internet access and social connectedness people expect access to information.

While we might prevent database access and grant/revoke this at times, the output from our systems also often ends up in Excel sheets or other files, fg hard copy print out, and people that do not have direct access still see the data.

People may leave data lying around on desks or tacked to a wall or on printer, or just on screen in an open plan office to be viewed by passers by. Many do not log off or shutdown their pcs at night. Why? They have never been trained or told to do so, and there is no management oversight to enforce it.
The trend to BYOD means data leaves your premises and then you have no control over it. Removable usb devices, 0r just uploads to one drive or emails to a hotmail account are all possible holes in your security defences.

Credentials on a post-it stuck only your monitor? Server rooms that are not locked?

It’s not just your co-workers, but also janitorial staff, tradespeople, and others likely wander regularly through your office spaces.

Security is a tough battle, and most of the time we don’t need much more than good passwords. Most people don’t have the time or inclination to deal with their own data, much less yours. However, when an attack is targeted on your organization, from outside or within, it’s extremely difficult to ensure your data won’t get lost or corrupted.

There is no magic bullet. There are good reasons to limit access to data on our systems, not the least of which is auditing and accountability. Beyond that, inculcate users to exercise judgment about with whom they may share or to whom they expose reports and other data.

Data breaches and what it means for a Middle East Board of Directors

December 6th, 2017

The new wave of cyber-attacks does appear to be unstoppable. With the increase in data breaches across the world, the UAE holds the world’s highest increase in breaches. Data breaches in the region have risen by 20% from $4.12m in 2016 to $4.94m in 2017, according to a report by Ponemon Institute.

The Middle East also has the highest spend on data breach response, roughly costing $1.43m per organisation.
Early this year, approximately 15 government agencies and private institutions in the Kingdom of Saudi Arabia were attacked by the Shamoon virus. This was followed by a tidal wave of Wannacry and Petya ransomware attacks.

An IDC research states that organisations are expected to spend $101.6 billion by 2020 on security-related hardware, software, and services. Additionally, Gartner states that by 2018, 10% of all enterprise organisations will have adopted deception technologies into their security solutions. A board of directors must engage in a continuing balancing act between the cost of information security and potential risks.

Although information security is essential to corporate compliance with existing laws and regulations, directors are often required to focus less on ensuring “best security” in favour of “good enough” security. The lack of a clear definition of “best security” is largely responsible for this thinking.

What was previously viewed as good enough, will not keep up with the advanced or insider threats of today.

• Important messages that CISOs should communicate to their boards about the importance of focusing on information security:

Information security is now required, and disclosure is no longer solely at a company’s discretion. Between existing laws, insurance mandates, industry regulations, and shareholder demands, robust information security is now a corporate requirement.

• Information security is a significant corporate risk. It is nearly impossible to conduct any facet of a business today without a computer. As a result, the information that resides in an enterprise’s networks is the lifeblood of the business and if not protected, could result in financial damages and negative impact on the company’s brand. This makes information security a critical business issue. Any security strategy that does not include an adaptive security plan with in-network detection to detect attacks that have bypassed prevention solutions will result in a network breach sooner or later, if it hasn’t occurred already.

Some obvious things to consider:
- Policies, procedures, and awareness – Protection via data classification, password strengths, code reviews and usage policies
- Perimeter – Protection via firewalls, denial of service prevention, and message parsing and validation
- Internal network – Protection via transport layer security, such as encryption, and user identification and authentication
- Host/OS – Protection through OS patches and desktop malware
- Application – Protection through protocols such as single sign on (SSO) and identity propagation
- Data – Protection through database security (online storage and back up), content security, information rights management, message level security.

Do your systems still cater for the digital world of a mobile workforce with smart phones, BYOD social media, low cost, high capacity flash drives, and any time, anywhere connections?.

Data breach

December 5th, 2017

We have been asked to assist several companies targeted by ransomware ad phishing attacks in the last year.

The moments after you have experienced a breach are of the utmost importance and can significantly impact your organization and the effectiveness of an investigation.

How prepared is your information technology (IT) department or administrator to handle security incidents?
According to the Computer Security Institute, over 20% of organizations have reported
experiencing a computer intrusion, and common sense says that many more intrusions have
gone unreported. No matter how much detail you know about the network environment, the risk of being attacked remains.

Any sensible security strategy must include details on how to respond to different types of attacks. Many organizations learn how to respond to security incidents only after suffering attacks. By this time, incidents often become much more costly than needed. Proper incident response should be an integral part of your overall security policy and risk mitigation strategy.

There are clearly direct benefits in responding to security incidents. However, there might also be indirect financial benefits. For example, your insurance company might offer discounts if you can demonstrate that your organization is able to quickly and cost-effectively handle attacks. Or, if you are a service provider, a formal incident response plan might help win business, because it shows that you take seriously the process of good information security.

If you suspect a computer systems intrusion or breach, then Immediately Contain and Limit the Exposure – Stop the breach from spreading.
• Do NOT access or alter compromised systems (e.g., do not log on or change passwords).
• Do NOT turn off the compromised machine. Instead, isolate compromised systems from the network (e.g., unplug the network cable). If for some reason it is necessary to power off the machine, unplug the power source.
• Do NOT shutdown the system or push the power button (because it can sometimes create a “soft” shutdown), which modifies system files.
• Preserve logs and electronic evidence. A forensic hard drive image will preserve the state on any suspect machines. Any other network devices (such as firewalls, IDS/IPSes, routers, etc.) that have logs in the active memory should be preserved. Keep all past backup tapes, and use new backup tapes for subsequent backups on other systems.
• Log all the actions you have taken, including composing a timeline of any knowledge related to the incident.
• If using a wireless network, change SSID on the wireless access point (WAP) and other machines that may be using this connection (with the exception of any systems believed to be compromised).
• Be on high alert and monitor all systems.

Alert All Necessary Parties Within 24 Hours
All external disclosures should be coordinated with your Legal Representative. Potential agencies include local and national law enforcement, external security agencies, and virus experts. External agencies can provide technical assistance, offer faster resolution and provide information learned from similar incidents to help you fully recover from the incident and prevent it from occurring in the future.

For particular industries and types of breaches, you might have to notify customers and the general public, particularly if customers might be affected directly by the incident.

If the event caused substantial financial impact, you might want to report the incident to law enforcement agencies.

For higher profile companies and incidents, the media might be involved. Media attention to a security incident is rarely desirable, but it is often unavoidable. Media attention can enable your organization to take a proactive stance in communicating the incident. At a minimum, the incident response procedures should clearly define the individuals authorized to speak to media representatives.

Normally the public relations department within your organization will speak to the media. You should not attempt to deny to the media that an incident has occurred, because doing so is likely to damage your reputation more than proactive admission and visible responses ever will. This does not mean that you need to notify the media for each and every incident regardless of its nature or severity. You should assess the appropriate media response on a case-by-case basis.

Be sure to notify:
• Your internal information security group and incident response team, if applicable.
• The card associations and your merchant bank if the breach is part of a cardholder data segment.
• Your legal advisor

Maybe your auditors.
Maybe your insurers.
Maybe the authorities/police.

Synergy Software Systems support desk.

Consider what message you need to give to staff, and to your trading partners.
Update your policies and procedures, and tools.

Thank those who helped you – you may need them again.

Security, security

November 5th, 2017

The IRS fends off 4 million hacking attempts a day, Commissioner John Koskinen said last Tuesday

System accounts – security

October 29th, 2017

An Office 365-focused Botnet puts the spotlight on the security of System Accounts which are commonly overlooked

A botnet it dubbed “KnockKnock” aActive since at least May, and especially active from June through August, is relatively small botnet whose attack highly targeted for both: the types of accounts it attacks and the types of organizations. GThis is interesting is because it is trying to get into system accounts, that are commonly used to connect the Exchange Online e-mail system with marketing and sales automation software. In cases where the system accounts are compromised, KnockKnock exports data from the inbox, creates a new inbox rule and starts a phishing attack from the account against the rest of the organization.

The attacks analysed averaged only five e-mail addresses per customer. Additionally, the organizational targeting was extremely specific — aimed at infrastructure and Internet of Things (IoT) departments within the manufacturing, financial services, health care and consumer products industries, as well as U.S. public sector agencies.

Non-human system accounts are less likely to be protected by multi-factor authentication or security policies, such as recurring password reset requirements. Once such accounts are provisioned, they’re easy to overlook and can prove to be the weakest link in Office 365 and in general the security infrastructure.

Bad Rabbit – a virulent wave of data-encrypting malware is sweeping through Eastern Europe

October 28th, 2017

A new, potentially virulent wave of data-encrypting malware is sweeping through Eastern Europe and has left a wake of outages at news agencies, train stations, and airports, according to multiple security companies

A new ransomware outbreak similar to WCry is shutting down computers worldwide, Ransom:Win32/Tibbar.A or Bad Rabbit, as the outbreak is dubbed, is primarily attacking targets in Russia, but it’s also infecting computers in Ukraine, Turkey and Germany, researchers from Moscow-based Kaspersky Lab said. In a blog post, the antivirus provider reported that the malware is using hacked Russian media websites to display fake Adobe Flash installers, which when clicked infect the computer visiting the hacked site. Researchers elsewhere said the malware may use other means to infect targets.

Bad Rabbit appears to specifically target corporate networks by using methods similar to those used in a June data-wiping attack dubbed “NotPetya” that shut down computers around the world.
Bad Rabbit infects Windows computers and relies solely on targets manually clicking on the installer, Kaspersky Lab said. So far, there’s no evidence the attack uses any exploits.

The Ukrainian computer emergency agency CERT-UA posted an advisory on Tuesday morning reporting a series of cyberattacks.

Kevin Beaumont said on Twitter that Bad Rabbit uses a legitimate, digitally signed program called DiskCryptor to lock targets’ hard drives. Kaspersky Labs’ blog post said the executable file dispci.exe appears to be derived from DiskCryptor and is being used by Bad Rabbit as the disk encryption module.

Bad Rabbit relies on hard-coded credentials that are commonly used in enterprise networks for file sharing and takes aim at a particularly vulnerable portion of infected computers’ hard drives known as the master boot record. A malicious file called infpub.dat appears to be able to use the credentials to allow the Bad Rabbit to spread to other Windows computers on the same local network, The malware also uses the Mimikatz network administrative tool to harvest credentials from the affected systems.

Once Bad Rabbit infects a computer, it displays a message in orange letters on a black background. It directs users to a Dark Web site that demands about $283 in Bitcoin to decrypt data stored on the encrypted hard drive. The dark Web site also displays a ticking clock that gives victims 40 hours to pay before the price increases. It’s not yet known what happens when targets pay the ransom in an attempt to restore their data. The NotPetya malware was written in a way that made recovery just about impossible, a trait that has stoked theories that the true objectives of the attackers was to wipe data in an act of sabotage, as opposed to generate revenue from ransomware. It also remains unclear who is behind the attack.

The outbreak is the latest reminder that you should back up all their data on drives that are secured with a password or other measure to protect them from ransomware.

Windows Defender Antivirus detects and removes this threat with protection update 1.255.29.0 and higher.

This threat appears as a fake Adobe Flash Player update.

Microsoft advice:
Microsoft doesn’t recommend you pay the ransom. There is no guarantee that paying the ransom will give you access to your files. If you’ve already paid, then see our https://www.microsoft.com/en-us/mmpc/shared/ransomware.aspx for help on what to do.

Review logs and shutdown or run Windows Defender Offline.

This ransomware attempts to reboot your PC so it can encrypt your files. You might be able to stop your PC from rebooting and instead shut it down or run a Windows Defender Offline scan:
Check event logs for the following IDs: 1102 and 106
• Event 1102 indicates that the audit log has been cleared, so previous activities can’t be seen.
• Event 106 indicates that scheduled tasks “drogon” and “Rhaegel” have been registered (these are ransomware wipers)
• If events 1102 and 106 are present, then issue a shutdown with the parameter -a to prevent a reboot

You can also immediately inititate a Windows Defender Offline scan by using PowerShell or the Windows Defender Security Center app.

Run antivirus or antimalware software

Use the following free Microsoft software to detect and remove this threat:
• Windows Defender Antivirus for Windows 8.1 and Windows 10, or Microsoft Security Essentials for Windows 7 and Windows Vista
• Microsoft Safety Scanner – Run a full scan to look for anyhidden malware.

Advanced troubleshooting – To restore your PC, download and run Windows Defender Offline.

Ask us about how to use cloud protection to guard against the latest malware threats. It’s turned on by default for Microsoft Security Essentials and Windows Defender for Windows 10. Go to All settings > Update & security > Windows Defender and make sure that your Cloud-based Protection settings is turned On.

Indicators of compromise
Presence of the following files in %SystemRoot%:
• infpub.dat
• cscc.dat
• dispci.exe
• You can’t access your files or your PC
• A ransom message in red on a black background

Security security security

September 26th, 2017

You never know when some item that queries or alters data in SQL Server will cause issues.

Bruce Schneier recently commented on FaceID and Bluetooth security, the latter of which has a vulnerability issue. I was amazed to see his piece on infrared camera hacking. A POC on using light to jump air gaps is truly frightening. It seems that truly anywhere that we are processing data, we need to be thinking (see https://arstechnica.com/information-technology/2017/09/attackers-can-use-surveillance-cameras-to-grab-data-from-air-gapped-networks/)

Airborne attacks, unfortunately, provide a number of opportunities for the attacker. First, spreading through the air renders the attack much more contagious, and allows it to spread with minimum effort. Second, it allows the attack to bypass current security measures and remain undetected, as traditional methods do not protect from airborne threats. Airborne attacks can also allow hackers to penetrate secure internal networks which are “air gapped,” meaning they are disconnected from any other network for protection. This can endanger industrial systems, government agencies, and critical infrastructure. With BlueBorne, attackers can gain full control right from the start. Moreover, Bluetooth offers a wider attacker surface than WiFi, almost entirely unexplored by the research community and hence contains far more vulnerabilities

Finally, unlike traditional malware or attacks, the user does not have to click on a link or download a questionable file. No action by the user is necessary to enable the attack.

Fully patched Windows and iOS systems are protected

– the Equifax breach for example must worry everyone who has ever had credit in the USA. (Hackers broke into Equifax’s computer systems in March, which is two months earlier than the company had previously disclosed, according to a Wall Street Journal report.)

The Securities and Exchange Commission said Wednesday that a cyber breach of a filing system it uses may have provided the basis for some illegal trading in 2016. In a statement posted on the SEC’s website, Chairman Jay Clayton said a review of the agency’s cybersecurity risk profile determined that the previously detected “incident” was caused by “a software vulnerability” in its EDGAR filing system (which processes over 1.7 million electronic filings in any given year.) The agency also discovered instances in which its personnel used private, unsecured email accounts to transmit confidential information.

So let me suggest take a good look at your systems and be honest – do you feel safe?

Microsoft has released Microsoft 365, a complete, intelligent solution, including Office 365, Windows 10, and Enterprise Mobility + Security, that empowers everyone to be creative and work together, securely. Watch Satya introduce it.

What about your websites?
Although acts of vandalism such as defacing corporate websites are still commonplace, hackers prefer to gain access to the sensitive data residing on the database server and then to sell the data.

The costs of not giving due attention to your web security are extensive and apart form direct financial burden and inconvenience also risks:
• Loss of customer confidence, trust and reputation with the consequent harm to brand equity
• Negative impact on revenues and profits arising e.g. from falsified transactions, or from
employee downtime
• Website downtime – is in effect the closure of one of the most important sales and marketing channels
especially for an e-business
• Legal battles and related implications from Web application attacks and poor security
measures including fines and damages to be paid to victims.

Web Security Weaknesses
Hackers will attempt to gain access to your database server through any way they can e.g. out of date protocols on a router. Two main targets are :
• Web and database servers.
• Web applications.

Information about such exploits are readily available on the Internet, and many have been reported on this blog previously.

Web Security Scanning
So no surprise that Web security should contain two important components: web and database server security, and web application security.

Addressing web application security is as critical as addressing server security.

Firewalls and similar intrusion detection mechanisms provide little defense against full-scale web
attacks.
Since your website needs to be public, security mechanisms allow public web traffic to
communicate with your web and databases servers (i.e. over port 80).

It is of paramount importance to scan the security of these web assets on the network for possible vulnerabilities. For example, modern database systems (e.g. Microsoft SQL Server, Oracle and MySQL) may be
accessed through specific ports and so anyone can attempt direct connections to the databases to try and bypass the security mechanisms used by the operating system. These ports remain open to allow communication with legitimate traffic and therefore constitute a major vulnerability.

Other weaknesses relate to the database application itself and the use of weak or default passwords by
administrators. Vendors patch their products regularly, and equally regularly find new ways of
attack.

75% of cyber attacks target weaknesses within web applications rather than directly at the
servers. Hackers launch web application attacks on port 80 . Web applications are more open to uncovered vulnerabilities since these are generally custom-built and therefore pass through a lesser degree of
testing than off-the-shelf software.

Some hackers, for example, maliciously inject code within vulnerable web applications to trick users
and redirect them towards phishing sites. This technique is called Cross-Site Scripting (XSS) and may
be used even though the web and database servers contain no vulnerability themselves.

Hence, any web security audit must answer the questions “which elements of our network
infrastructure are open to hack attacks?”,
“which parts of a website are open to hack attacks?”, and “what data can we throw at an application to cause it to perform something it shouldn’t do?”

Ask us about Acunetix and Web Security
Acunetix ensures web site security by automatically checking for SQL Injection, Cross Site Scripting,
and other vulnerabilities. It checks password strength on authentication pages and automatically
audits shopping carts, forms, dynamic content and other web applications. As the scan is being
completed, the software produces detailed reports that pinpoint where vulnerabilities exist

CCleanup: hacked if you use this software then read on

September 20th, 2017

Hackerssuccessfully breached CCleaner’s security to inject malware into the app and distribute it to millions of users. Security researchers at Cisco Talos discovered that download servers used by Avast (the company that owns CCleaner) were compromised to distribute malware inside CCleaner. “For a period of time, the legitimate signed version of CCleaner 5.33 being distributed by Avast also contained a multi-stage malware payload that rode on top of the installation of CCleaner,” says the Talos team.

CCleaner has been downloaded more than 2 billion times according to Avast, making it a popular target for hackers. Dubbed “crap cleaner,” it’s designed to wipe out cookies and offer some web privacy protections. 2.27 million users have been affected by the attack, and Avast Piriform believes it was able to prevent the breach harming customers. “Piriform believes that these users are safe now as its investigation indicates it was able to disarm the threat before it was able to do any harm,” says an Avast spokesperson.

The Talos site update as of this week:
Update 9/18: CCleaner Cloud version 1.07.3191 is also reported to be affected
Update 9/19: This issue was discovered and reported by both Morphisec and Cisco in separate in-field cases and reported separately to Avast.
Update 9/19: There has been some confusion on how the DGA domains resolve.

http://blog.talosintelligence.com/2017/09/avast-distributes-malware.html

Piriform, the developer of CCleaner now owned by security firm Avast, says that its download servers were compromised at some point between 15 August, when it released version v5.33.6162 of the software, and 12 September, when it updated the servers with a new version. In that period, a trojan was loaded into the download package which sent “non-sensitive data” from infected users’ computers back to a server located in the US. The data, according to Piriform, included “computer name, IP address, list of installed software, list of active software, list of network adapters”.

As well as the data leak, however, the infection also resulted in a “second stage payload” being installed on to the affected computer – another piece of malware, which Piriform says was never executed.
“At this stage, we don’t want to speculate how the unauthorised code appeared in the CCleaner software, where the attack originated from, how long it was being prepared and who stood behind it,” the company’s vice president, Paul Yung, said.

The company says 2.27m users were infected, but added that “we believe that these users are safe now as our investigation indicates we were able to disarm the threat before it was able to do any harm”. By taking down the “command and control” server, Piriform may have prevented the infection being used to inflict further damage.

https://www.theguardian.com/technology/2017/sep/19/ccleaner-2m-users-install-anti-malware-program-security-avast-supply-chain-attack-hack

https://www.wired.com/story/ccleaner-malware-supply-chain-software-security/

GDPR Affects All European Businesses – What about the G.C.C. and U.A.E.?

August 19th, 2017

See our previous article on this topic for why your company may be affected if you are a branch of a European company, or have branches in Europe, or trade with a European company.

From May 25, 2018, companies with business operations inside the European Union must follow the General Data Protection Regulations (GDPR) to safeguard how they process personal data “wholly or partly by automated means and to the processing other than by automated means of personal data which form part of a filing system or are intended to form part of a filing system.”

The penalties set for breaches of GDPR are up to 4% of a company’s annual global turnover.
For large companies like Microsoft that have operations within the EU, making sure that IT systems do not contravene GDPR is critical. As we saw on August 3, even the largest software operations like Office 365 can have a data breach.

Many applications can store data that might come under the scope of GDPR. the regulation has a considerable influence over how tenants deal with personal data. The definition of personal data is “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
GDPR goes on to define processing of personal data to be “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.”

That means that individuals have the right to ask companies to tell them what of their personal data a company holds, and to correct errors in their personal data, or to erase that data completely.

Companies therefore need to:
- review and know what personal data they hold,
- make sure that they obtain consents from people to store that data,
– protect the data,
- and notify authorities when data breaches occur.

On first reading, this might sound like what companies do – or at least try to do – today. The difference lies in the strength of the regulation and the weight of the penalties should anything go wrong.

GDPR deserves your attention.

The definitions used by GDPR are broad. To move from the theoretical to the real world an organization first needs to understand what personal data it currently holds for its business operations, and where they use the data within software applications.

It is easy to hold personal information outside of business applications like finance and erp and crm e.g. inside Office 365 applications, including:
• Annual reviews written about employees stored in a SharePoint or OneDrive for Business site.
• A list of applicants for a position in an Excel worksheet attached to an email message.
• Tables holding data (names, employee numbers, hire dates, salaries) about employees in SharePoint sites.
• Outlook contacts, and emails. Skype business,
• Social media sites
• Loyalty programmes
• T@A systems
• E commerce sites
• Mobile apps e.g. What’s App

Other examples might include contract documentation, project files that includes someone’s personal information, and so on.

What backups do you have of the customer’s data?
What business data do your staff hold on BYOD devices e.g. in What’s App?

Data Governance Helps
Fortunately, the work done inside Office 365 in the areas of data governance and compliance help tenants to satisfy the requirements of GDPR. These features include:
• Classification labels and policies to mark content that holds personal data.
• Auto-label policies to find and classify personal data as defined by GDPR. Retention processing can then remove items stamped with the GDPR label from mailboxes and sites after a defined period, perhaps after going through a manual disposition process.
• Content searches to find personal data marked as coming under the scope of GDPR.
• Alert policies to detect actions that might be violations of the GDPR such as someone downloading multiple documents over a brief period from a SharePoint site that holds confidential documentation.
• Searches of the Office 365 audit log to discover and report potential GDPR issues.
• Azure Information Protection labels to encrypt documents and spreadsheets holding personal data by applying RMS templates so that unauthorized parties cannot read the documents even if they leak outside the organization.

Technology that exists today within Office 365 that can help with GDPR.

Classification Labels
Create a classification label to mark personal data coming under the scope of GDPR and then apply that label to relevant content. When you have Office 365 E5 licenses, create an auto-label policy to stamp the label on content in Exchange, SharePoint, and OneDrive for Business found because documents and messages hold sensitive data types known to Office 365.

GDPR sensitive data types

Select from the set of sensitive data types available in Office 365.
The set is growing steadily as Microsoft adds new definitions.
At the time of writing, 82 types are available, 31 of which are obvious candidates to use in a policy because those are for sensitive data types such as country-specific identity cards or passports.

Figure 1: Selecting personal data types for an auto-label policy (image credit: Tony Redmond)

GDPR Policy

The screenshot in Figure 2 shows a set of sensitive data types selected for the policy. The policy applies a label called “GDPR personal data” to any content found in the selected locations that matches any of the 31 data types.

Auto-apply policies can cover all Exchange mailboxes and SharePoint and OneDrive for Business sites in a tenant – or a selected sub-set of these locations.


Figure 2: The full set of personal data types for a GDPR policy (image credit: Tony Redmond)

Use classification labels to mark GDPR content so that you can search for this content using the ComplianceTag keyword (for instance, ComplianceTag:”GDPR personal data”).

Caveats:
It may take 1-2 week before auto-label policies apply to all locations.
An auto-label policy will not overwrite a label that already exists on an item.

A problem is that classification labels only cover some of Office 365. Some examples of popular applications where you cannot yet use labels are:
• Teams.
• Planner.
• Yammer.

Microsoft plans to expand the Office 365 data governance framework to other locations (applications) over time.
Master data management
What about all the applications running on SQL or other databases?
Master Data Management MDM is a feature of SQL since SQL 2012. However, when you have many data sources then you are relay into an ETL process and even with MDM tools the work is still significant.

If you have extensive requirements then ask us about Profisee our specialist, productized MDM solution built on top of SQL MDM that allows you to do much of the work by configuration.

Right of Erasure
Finding GDPR data is only part of the problem. Article 17 of GDPR (the “right of erasure”), says: “The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay.” In other words, someone has the right to demand that an organization should erase any of their personal data that exists within the company’s records.

Content searches can find information about someone using their name, employee number, or other identifiers as search keywords, but erasing the information is something that probably also needs manual processing to ensure that the tenant removes the right data, and only that data.

You can find and remove documents and other items that hold someone’s name or other identifier belonging to them by using tools such as Exchange’s v Search-Mailbox cmdlet, or Office 365 content searches.
What if the the data ahs to be retained because the company needs to keep items for regulatory or legal purposes, can you then go ahead and remove the items?
The purpose of placing content on-hold is to ensure that no-one, including administrators, can remove that information from Exchange or SharePoint.

The GDPR requirement to erase data on request means that administrators might have to release holds placed on Exchange, SharePoint, and OneDrive for Business locations to remove the specified data. Once you release a hold, you weaken the argument that held data is immutable. The danger exists that background processes or users can then either remove or edit previously-held data and so undermine a company’s data governance strategy.

The strict reading of GDPR is that organizations must process requests to erase personal data upon request.
What if the company needs to keep some of the data to satisfy regulations governing financial transactions, taxation, employment claims, or other interactions? This is a dilemma for IT. Lawyers will undoubtedly have to interpret requests and understand the consequences before making decisions and it is likely that judges will have to decide some test cases in different jurisdictions before full clarity exists.

Hybrid is even More Difficult

Microsoft is working to help Office 365 tenants with GDPR. However, I don’t see the same effort going to help on-premises customers. Some documentation exists to deal with certain circumstances (like how to remove messages held in Recoverable Items), but it seems that on-premises customers have to figure out a lot things for themselves.

This is understandable. Each on-premises deployment differs slightly and exists inside specific IT environments. Compared to the certainty of Office 365, developing software for on-premises deployment must accommodate the vertical and company specific requirements with integrations and bespoke developments.

On-premises software is more flexible, but it is also more complicated.
Solutions to help on-premises customers deal with GDPR are more of a challenge than Microsoft or other software vendors wants to take on especially given the industry focus of moving everything to the cloud.

Solutions like auto-label policies are unavailable for on-premises servers. Those running on-premises SharePoint and Exchange systems must find their own ways to help the businesses that they serve deal with personal data in a manner that respects GDPR. Easier said than done and needs to start sooner than later.

SharePoint Online GitHub Hub

If you work with SharePoint Online, you might be interested in the SharePoint GDPR Activity Hub. At present, work is only starting, but it is a nway to share information and code with similarly-liked people.

ISV Initiatives

There many ISV-sponsored white papers on GDPR and how their technology can help companies cope with the new regulations. There is no doubt that these white papers are valuable, if only for the introduction and commentary by experts that the papers usually feature. But before you resort to an expensive investment, ask yourself whether the functionality available in Office 365 or SQL is enough.

Technology Only Part of the Solution

GDPR will effect Office 365 because it will make any organization operating in the European Union aware of new responsibilities to protect personal data. Deploy Office 365 features to support users in their work, but do not expect Office 365 to be a silver bullet for GDPR. Technology seldom solves problems on its own. The nature of regulations like GDPR is that training and preparation are as important if not more important than technology to ensure that users recognize and properly deal with personal data in their day-to-day activities.

Malicious tech support ads – Windows 10 users beware.

August 13th, 2017

1. On Tuesday, Microsoft’s Malware Protection Center announced that it had learned about new strategies to target those using Windows 10 via links that lead to fraudulent tech support sites.
2. Zdnet reports that the scam involves a series of malicious ads that redirect victims to a fake tech-support page, in which Windows 10 users are presented with a display of fake Blue Screen of Death (BSOD) or other bogus Windows security alerts
3. Once users have clicked on the link that leads to the fraudulent website, they are presented with a host of security-alert popups that aim to drive users to contact the bogus support call center.
To report a scam https://support.microsoft.com/en-us/contactus/

To prevent these kinds of attacks, Microsoft’s Windows 10, Outlook.com, Edge, and Exchange Online Protection include security features to block the fake tech support sites and fraudulent emails.

According to Microsoft, Edge users can prevent dialog loops by blocking a certain page from multiplying.
A new Edge feature gives users the ability to shut down browsers or tabs when facing a suspicious-looking popup message.

According to Microsoft,each month “…at least three million users of various platforms and software encounter tech support scams”.
the scam new techniques introduce a different layer to the mix, and embed links in phish-like emails—and represent a step up from the previous methods used by scammers, potentially leading to a wider pool of victims

Docs.com – New Microsoft documentation portal

August 6th, 2017

Microsoft Corporation has provisioned a new portal for all their application/framework documentation and are also placing the ability to add to that content.

The new docs.microsoft.com rolled out recently for their documentation for each of the following topic groups arranged by product line/focus:
• SQL
• Windows
• Microsoft Azure
• Visual Studio
• Office
• .NET
• ASP.NET
• Dynamics 365
• Enterprise Mobility + Security
• nuget
• Xamarin

So no longer navigate to msdn.microsoft.com. The central portal leads to additional functionality and information sharing not previously offered.

Microsoft 365 – August 2017 – ask Synergy Software Systems, Dubai

July 31st, 2017

At Inspire, earlier this month Satya Nadella unveiled Microsoft 365, which brings together Office 365, Windows 10 and Enterprise Mobility + Security, delivering a complete, intelligent and secure solution to empower employees. It represents a fundamental shift in how we will design, build and go to market to address our customers’ needs for a modern workplace.

Microsoft introduced Enterprise and Business editions. It’s in public preview on 2nd August 2017, and will. generally available in autumn 2017, priced at $20 per user per month.

– Enterprise edition replaces Secure Productive Enterprise and will be available as an E3 or E5 plan from 1st August 2017.

– Business edition is new, and is aimed at organizations with less than 300 users who want Office 365 Business Premium with security/management features from Windows 10 and EMS, as well as some new applications such as Microsoft Connections.

The workplace is transforming—from changing employee expectations, to more diverse and globally distributed teams, to an increasingly complex threat landscape. A new culture of work emerging as companies look to empower their people with innovative technology. Think of Dubai’s ‘smart government” and trends like SMAC and BYOD.

Think also of the challenges for security in this ‘brave new world’ of organised ransomware and phishing attacks. With more than 100 million commercial monthly active users of Office 365, and more than 500 million Windows 10 devices in use, Microsoft 365 helps companies to empower their employees, to unlock business growth and innovation, while keeping the enterprise secure.

1, 2017.

Microsoft 365 Enterprise is built on the foundation of the highly successful Secure Productive Enterprise, which grew seats by triple digits in the last year.

Microsoft 365 Business is designed for small- to medium-sized businesses with up to 300 users and integrates Office 365 Business Premium with tailored security and management features from Windows 10 and Enterprise Mobility + Security. It offers services to empower employees, safeguard the business and simplify IT management.

Microsoft 365 Business:
• Helps companies achieve more together by better connecting employees, customers and suppliers.
• Empowers employees to get work done from anywhere, on any device.
• Protects company data across devices with always-on security.
•Simplifies the set-up and management of employee devices and services with a single

VAT for the U.A.E. some updates – July 2017

July 15th, 2017

Any taxable person must retain VAT invoices issued and received for a minimum of 5 years.

Imports
The place of supply will determine whether a supply is made within the UAE (in which case the UAE VAT law will apply), or outside the UAE for VAT purposes. For a supply of goods, the place of supply should be the location of goods when the supply takes place – with special rules for certain categories of supplies (e.g. water and energy, cross border supplies).

For the supply of services, the place of supply should be where the supplier is established – (with special rules for certain categories of supplies e.g. cross border supplies between businesses).

VAT shall be payable in addition to the custom duties paid by the importer of the goods and cannot be deducted against. VAT shall be computed on the value that includes the customs duties.

Some goods that are imported may be exempt from customs duties but be subject to VAT.

VAT is due on the goods and services purchased from abroad. In case the recipient in the State is a registered person with the Federal Tax Authority for VAT purposes, the VAT would be due on that import using a reverse charge mechanism. In case the recipient in the State is a non-registered person for VAT purposes, VAT would be paid on import of goods from a place outside the GCC. Such VAT will typically be required to be paid before the goods are released to the person.

Exempt and zero rate
- The VAT treatment of real estate will depend on whether it is a commercial or residential property.
Supplies (including sales or leases) of commercial properties will be taxable at the standard VAT rate (i.e 5%).
- Supplies of residential properties will generally be exempt from VAT to ensure that VAT does not constitute an irrecoverable cost to persons who buy their own properties. To ensure that real estate developers can recover VAT on construction of residential properties, the first supply of residential properties within 3 years from their completion will be zero-rated.

There is a difference between exempt goods and zero rate. (for example zero rate might be raised in future).
VAT will be charged at 0% in respect of the following main categories of supplies:
• Exports of goods and services to outside the GCC;
• International transportation, and related supplies;
• Supplies of certain sea, air and land means of transportation (such as aircrafts and ships);
• Certain investment grade precious metals (e.g. gold, silver, of 99% purity);
• Newly constructed residential properties, that are supplied for the first time within 3 years of their construction ;
• Supply of certain education services, and supply of relevant goods and services;
• Supply of certain Healthcare services, and supply of relevant goods and services.

The following categories of supplies will be exempt from VAT:
• The supply of some financial services (clarified in VAT legislation);
• Residential properties;
• Bare land;
• Local passenger transport

Financial Services
It is expected that fee based financial services will be taxed but margin based products are likely to be exempt.
Generally, insurance (vehicle, medical, etc) will be taxable.
Life insurance, we understand will be treated as an exempt financial service

The VAT treatment of standard financial services and Islamic finance products, the treatment of Islamic finance products will be aligned with the treatment of similar standard financial services

Businesses that meet requirements the Legislation (such as being resident in the UAE and being related/associated parties) will be able to register as a VAT group. For some businesses, VAT grouping will be a useful tool to simplify accounting for VAT.

Offsetting VAT.
VAT registered businesses will be able to reduce their output tax liability by the amount of VAT that relates to bad debt which has been written off by the VAT registered business. The legislation will include the conditions and limitations concerning the use of this relief.

A scheme will be introduced to allow a UAE national who is not registered for VAT to reclaim VAT paid on goods and services relating to constructing a new residence which will be privately used by the person and his family. This will allow the recovery of VAT on such expenses as contractor’s services and building materials.

To avoid double taxation (where second hand goods are acquired by a registered person from an unregistered person for the purpose of resale), the VAT-registered person will be able to account for VAT on sales of second hand goods with reference to: the difference between the purchase price of the goods, and the selling price of the goods (that is, the profit margin).

The VAT which must be accounted for by the registered person, will be included in the profit margin. The legislation will include the details of the conditions to be met in order to apply this mechanism.

VAT on expenses
A VAT registered person incurs input tax on its business expenses, and this input tax can be recovered in full when it relates to a taxable supply that was made, or intended to be made, by the registered person. In contrast, where the expense relates to a non-taxable supply (e.g. exempt supplies), then the registered person may not recover the input tax paid.

VAT will not be deductible in respect of expenses incurred for making non-taxable supplies. Furthermore, input tax cannot be deducted when it is incurred in respect of specific expenses such as entertainment expenses e.g. for employee entertainment.

VAT on expenses that were incurred by a business can be deducted in the following circumstances:
• The business must be a taxable person (the end consumer cannot claim any input tax refund).
• VAT should have been charged correctly (i.e. unduly charged VAT is not recoverable).
• The business must hold documentation showing the VAT paid (e.g. valid tax invoice).
• The goods or services acquired are used or intended to be used for making taxable supplies.
• VAT input tax refund can be claimed only on the amount paid or intended to be paid before the expiration of 6 months after the agreed date for the payment of the supply.

In certain situations, an expense may relate to both taxable and non-taxable supplies made by the registered person (such as activities of the banking sector). In these circumstances, the registered person would need to apportion input tax between the taxable and non-taxable (exempt) supplies.

Businesses will be expected to use input tax (ratio of recoverable to total) as a basis for apportionment in the first instance – (there will be the facility to use other methods where those are fair and agreed with the Federal Tax Authority).

Compliance and returns
Penalties will be imposed for non-compliance. Examples of actions and omissions that may give raise to penalties include:
• A person failing to register when required to do so;
• A person failing to submit a tax return or make a payment within the required period;
• A person failing to keep the records required under the issued tax legislation;
• Tax evasion offences where a person performs a deliberate act or omission with the intention of violating the provisions of the issued tax legislation.

No special rules are planned for small or medium sized enterprises. The FTA will provide materials and resources available for these entities to assist them in their enquiries.

A supplier registered or required to be registered for VAT must issue a valid VAT invoice for the supply. To be considered as a valid VAT invoice, the document must follow a specific format as mentioned in the legislation. In certain situations the supplier may be able to issue a simplified VAT invoice.

Government entities
Supplies made by government entities will typically be subject to VAT. This will ensure that government entities are not unfairly advantaged as compared to private businesses. Certain supplies made by government entities will, however, be excluded from the scope of VAT if they are not in competition with the private sector or where the entity is the sole provider of such supplies. It is likely certain government entities will be entitled to VAT refunds – this is designed to avoid budgeting issues and provide a level playing field between outsourced and insourced activities. For the supplies provided for government entities, the treatment of such supplies shall depend on the same supply and not on the recipient of the supply. Therefore, if the supply is subject to the standard tax rate, the treatment would remain the same even if it is provided to a government entity.

Transitional rules
Special rules will be provided to deal with various situations that may arise in respect of supplies that span the introduction of VAT. For example:
• Where a payment is received in respect of a supply of goods before the introduction of VAT, but the goods are actually delivered after the introduction of VAT. This means that VAT will have to be charged on such supplies. Likewise, special rules will apply with regards to supplies of services spanning the introduction of VAT.
• Where a contract is concluded prior to the introduction of VAT in respect of a supply, which is wholly or partly made after the introduction of VAT, and the contract does not contain clauses relating to the VAT treatment of the supply, then consideration for the supply will be treated as inclusive of VAT.

There will, however, be special provisions to allow suppliers to charge VAT in situations where their recipient is able to recover their VAT but where there is no VAT clause.

Payments and claims
Note that VAT will be payable in full not after netting off input tax which will then have to be claimed. This is more of a challenge for cash flow and business risk, especially given the penalties for late payments.
Refunds will be made after the receipt of the application and will be subject to verification checks, with a particular focus to avoid fraud.

The FTA may provide its views on various matters in the law. Taxpayers may choose to challenge these views. However, penalties may be imposed on taxpayers who are found to violate any tax laws and regulations.

Other Emirates
It is expected that businesses will need to complete additional information on their VAT returns to report revenues earned in each Emirate. Guidance will be provided to businesses with regards to this. It is expected that the rules will be relatively straightforward for most businesses and will be based, for example, for B2C transactions, on the location of the transaction (e.g. in a retail environment, the location of the shop).

European Union General Data Protection Regulation (GDPR) – 2018 what should GCC countries consider?

May 30th, 2017

The UAE Ministry of Economy is raising awareness among private sector companies of the need to be ready for new European data protection rules, which comes into force one year from now.

The European Union General Data Protection Regulation (GDPR) is set to become law by May 2018. The new rules govern all companies in Europe, as well as all companies trading with European companies and individuals.

The GDPR was drafted to “harmonise the protection of fundamental rights and freedoms of natural persons in respect of processing activities and to ensure the free flow of personal data between Member States

The law includes strong penalties for either misuse of data, or failure to protect the personal data of customers, with fines of up to 4% of annual turnover, or 20m euros ($22m).

HE Juma Mohammed Al Kait, Assistant Undersecretary for Foreign Trade at the Ministry of Economy, noted that the regulation issued by the EU aims to protect the data of every individual in the EU.

This not only impacts companies operating in European countries, but includes all institutions and companies that conduct business, trade and investment activities within EU countries, including the UAE business sector linked with European trade relations.

Due to this, the Ministry is working on deepening its knowledge about the new legislation, its provisions and requirements, and aims to reconcile its operational procedures with European authorities, in adherence with the framework of the GDPR, before May 2018.

Al Kait emphasized the EU is one of the UAE’s most important trade partners. Trade between the two sides generated $65.8 billion in 2016 alone. The UAE has become one of the top 10 destinations for EU exports, and is home to over 41,000 European companies, in addition to over 121,000 EU citizens.

Penalties will also apply to information controllers and processors, including cloud software companies.

The new legislation also outlines terms of approval for the use of data, to prevent companies from using legally illegitimate terms, and gives both parties the ability to easily withdraw if desired.

The compliance world will change dramatically for a number of GCC organizations on 25 May 2018. In just over one year’s time GCC organizations that:
1.have a branch, subsidiary or single representative in the European Union (“EU”);
2.do not have a physical presence in the EU, but offer goods or services to data subjects in the EU; or
3.neither have a physical presence in the EU nor offer goods or services to people in the EU, but monitor the online behavior of data subjects in the EU, will have to ensure that they are complying with the European Union General Data Protection Regulation (“GDPR”).

Who is likely to be affected?

Based on the test set out in the GDPR, the new regulations will likely apply to a significant number of entities in this region.
Obvious examples include:
– major airlines that fly to and from the EU,
- hotel and tourism operators who promote travel to the region to EU data subjects,
- regional banks and other financial service companies that have branches in the financial centres in the EU and online.

Less obvious examples include:
- e-commerce companies that are able to accept payments in euros and deliver to the EU
- mobile apps that can be downloaded by users in the EU and which have access to a user’s contacts, photos or location data.

All of these businesses may need to comply with the GDPR and to mitigate the risk and cost of failure to do so.
If your organization is affected it has three main options:
1. wait and see i.e. do nothing (not advisable);
2.consider what it needs to do to ensure that it does not fall within the scope of the GDPR;
3. take immediate steps to prepare to comply with the GDPR .

For option (2), if your organization does not have an establishment in the EU and does not need to target or monitor EU data subjects then you ight consider making it very clear that your website or app is not for use by EU users (e.g. including geo-blocking EU data subjects).

for option (3), if you have not started the process of ensuring compliance by now, then there is a lot to do.

1.monitor business to consumer business practices, including:
- conducting a data protection audit,
- examining the legal basis on which it processes personal data and updates its privacy policies;
2.monitor internal business practices, including:
- review and update of agreements with data processors,
- implement processes for adoption of pseudoanonymization and privacy by design
- considering the legal basis on which it transfers personal data between jurisdictions;
3.establish compliant accountability processes, including”
- processes for record keeping,
- appointment of a data protection officer or EU representative and dealing with data subjects;
4.invest in infrastructure, including:
- how to determine the severity, and impact on data subjects of a data breach
- to establish robust security processes and procedures for notifying regulatory authorities and data subjects -

The need for compliance, especially for longer-term projects such as records of processing and compliant contracting, must be addressed as soon as is practicable.

Businesses that either operate, target customers or monitor individuals in the EU should :
• Audit: to identify key remediation areas.
• Record of Processing: This mandatory record will require significant internal resources, but will also help to plan and implement GDPR processes. .
• Consider Contract Renegotiations: The GDPR requires that contracts with data controllers include additional obligations. As companies come to renegotiate contracts, ensure that adequate data protection clauses are added.
• Review and update, where necessary, employee notices to be GDPR compliant. If you currently conduct criminal records checks, then review national laws where you operate to ensure you can continue to do so . There is an emphasis on transparency in the GDPR. Notices must be clear, concise and informative. Employees must be adequately informed of all data processing activities and data transfers and the information set out in Articles 13 to 14 must be provided. Criminal records can no longer be processed unless authorized by member state law.

Consider whether your organization is processing any sensitive personal data and ensure the requirements for
processing such data are satisfied While the grounds for processing are broadly the same as those set out
in the current Data Privacy Directive, the GDPR imposes new requirements to gain valid consent. Consent can be withdrawn at any time and systems must be able to handle withdrawal request.

• Review and update, where necessary, customer notices to be GDPR compliant
• Consider whether your notices have to accommodate “child-friendly requirements”. he GDPR requires parental consent for the processing of data related to information society services offered to a “child” (ranging
from 13 to 16 years old depending on the member state.
• Data privacy rights. The current rights to request access to data or require it to be rectified or deleted have been expanded to include a much broader right to require deletion (“the right to be forgotten”), a right not just to access your data but have it provided to you in a machine readable format (“data portability”). Versions of the existing right to object to any processing undertaken on the basis of legitimate interests or for direct marketing and the right not to be subject to decision based on automated processing are also included and expressly refer a right to object to profiling.
These must be clearly communicated in the notices given to data subjects, e.g. privacy policy
• Privacy by design. Ensure processes are in place to embed privacy by design into projects (e.g. technical and organizational measures are in place to ensure data minimization, purpose limitation and security)

Consider what data you hold in emails, in CRM systems, Social media.
What should be your data access use and retention policies?

Personally I think it will be great if this is a way to prosecute the perpetrators of all the spam nd phishing emails I get or at least to remove data form their lists!

VAT registration nears for the GCC – what should you be doing now – contact Synergy Software Systems

May 29th, 2017

VAT (Value Added TAX), which is also called as ‘tax on consumption’ , is a tax that is payable while purchasing any product. VAT is applied as particular percentage of the cost of goods and services, hence it can not be considered as a charge on companies. It is a general tax amount, which is added by the producer to the inputs before they are sold as new offerings.

All UAE businesses subject to the Value-Added Tax have to submit their tax declaration statements on a quarterly basis after the VAT law goes into effect starting January 2018, according the Ministry of Finance.

The threshold for VAT registration put at Dh375,000 as per the ministry’s announcement this week.
It is optional to register between Dh187,500 and Dh375,000 .

UAE businesses will be able to start VAT registration in Q3 2017 and it is compulsory to be registered by Q4 2017.

Businesses will be able to register online using eServices.

The UAE businesses, subject to the tax, have to keep all files that allow competent authorities to audit their transactions and commercial activities, with the nature of the needed documents to be announced over the coming period. Businesses will be required to keep records which will enable the authorities to identify the details of the business activities and to review transactions. The specifics regarding the documents which will be required and the time period for keeping those will be communicated in due course.

Review your finance systems’ readiness for rapid implementation to meet these requirements. There will be a shortage of skilled consultants, and there are several holidays (EID, Diwali, Christmas, New Year, National Day etc. its also budget time, and preparation for year end audits,to fit in during the last quarter. Allow time for collection of your trading partners VAT registration ids, for report development and update, for testing and for staff training.

All six of the GCC member states: Saudi Arabia, Qatar, Oman, Kuwait, the UAE and Bahrain – have now signed and approved the VAT framework.

Registered businesses will be expected to submit VAT returns on a regular basis. It is expected that the default period for filing VAT returns will be three months for the majority of businesses. Registered businesses will be able to file their returns online using eServices.

Exemptions:
We understand that:
Health, education services, international transportation, import gold for investment purposes, commodities and exports are exempted from VAT in UAE.
Residential buildings for sale or lease during the first three years in which the building is completed, some financial services and empty plots of land are also exempted from VAT.

The GCC Member States will appreciate the VAT on financial provisions. The Banks and Financial House are ineligible for VAT in terms of the services provided, instead, they might be eligible for input tax based on tax recovery rates determined by each Member State.

The Federal Tax Authority has also announced a 100 per cent tax on tobacco, energy drinks and 50 per cent on carbonated beverages. This is separate from VAT.

The General Authority for Zakat and Income Tax (GAZT) in KSA reportedly warned businesses, during an awareness session that took place at the Riyadh Chamber of Commerce on Monday 16 May 2017, that penalties will be applicable in the cases of violation of VAT laws and regulations.

Penalties

The following types of Penalties will apply in each of the following cases:
• Case 1: Businesses required to register for VAT and that fail to register shall be liable to double the net tax due.
• Case 2: Committing an error in filling the tax return shall result in paying an additional 50% of net tax declared.

• Case 3: Exaggerated tax refund claims shall be subject to a penalty 50% of the original amount reported.
• Case 4: Late filing of tax return would result in a penalty of SAR 1,000 and an extra 5 to 20% of the unpaid tax. The percentage varies depending on the number of days of delay.
• Case 5: Non-registered person who issue an invoice with VAT shall pay SAR 1,000 or double the amount of the net tax (whichever is higher).
• Case 6: Not keeping records of the required documents shall result on a penalty of SAR 1,000 or 2% of the monthly average taxable supplies (whichever is higher).
• Case 7: Non-compliance with GAZT inquiries in providing relevant information shall result in a penalty of SRA 1,000 or 2% of the average monthly taxable supplies (SAR 20,000 maximum) or whichever is higher.