IT Audit has an article on 11 steps to an effective FTP audit. I like this article and gives some good steps to auditing FTP activity, however I think it misses a few things. While many people are likely already wondering why FTP should be so large-looking a project for such an old and probably under-utilized technology, it is still important, especially if this is a publicly open route into your network. Here are some steps I would add.

A. Audit user accounts and activity – Find out where user accounts are tracked and how expired accounts are handled. Do they linger for years and years without activity? Are client accounts even for active clients anymore? Once this audit is done, keep that list handy so that FTP admins can refer to it later and build upon it so that accounts are removed as needed and existing accounts are tracked. If an account has no activity in 4 years, raise questions on its continued need. I really like the rest of the author’s monitoring suggestions. Even if there is seemingly no value in knowing who consistently is the largest transferrer of files, it becomes more important when that consistency is broken one month and some other otherwise quiet account suddenly becomes very active. As part of the account audit, be sure to verify that FTP account access is limited only to their slice of the FTP server, and not overlapping other accounts or able to access other shared spaces. Twenty vendor accounts for 20 vendors that all dump into the same folder is a big risk. Try to also identify shared accounts or those accounts used by just one person, and identify the impact of regularly changing the passwords. Keep in mind that even legitimate users might use the FTP location for malicious reasons such as storing movies or games or other copyrighted property.

B. Recommend granular firewall policies for FTP account access – Whenever possible, require clients, vendors, and FTP users to provide their external IP or IP block to be included in access to the FTP server. It is better to only allow 1,000 IPs access to the FTP server through the firewall than to have all IPs allowed through. It has been my experience that most companies are amiable to providing this information when pressed.

C. Evaluate the patching and security state of the FTP server – Determine the FTP server in use and the version, then research any known vulnerabilities in the server. Recommend patching policy, someone to track patch availability ongoing, and perhaps recommend more secure FTP server solutions. Utilizing an old, insecure version of something like WarFTP or IIS5 should not be very acceptable.

D. Recommend including firewall logs of port 21 access in the audit – It could be beneficial for finding rogue or new FTP servers to include checking firewall logs for successful incoming port 21 occurrences outside the scope of known FTP servers.

FTP servers are still a necessary evil in many corporate environments, and far too many admins put them up, add new users per corporate requests, but otherwise don’t consider them with much more interest. As one of likely only a few inroads into your network, FTP servers should be taken as seriously as web and mail servers. The last thing you want to do is find out someone has been using one of your client’s accounts to store gigabytes of child pornography over the last 2 years…and be told about it by the client. And even if more secured file transfer options are utilized, such as SFTP or even SSH, most of these guidelines still apply.