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Cybersecurity Supply Chain Risk Management (C-SCRM) refers to the processes involved in identifying, assessing, and mitigating risks associated with the acquisition, use, and disposal of information and communications technology (ICT) products and services throughout the supply chain.
This concept lies at the intersection of information security and supply chain risk management. It encompasses a wide range of activities to ensure the security, quality, and resilience of the supply chain and its products and services.
DoDI 5200.44 defines Information and Communications Technology as:
“Any system that receives, transmits, collects, stores, processes, and reports information or data, including IT, information systems, and weapon systems.”
Cybersecurity supply chain risks encompass a variety of threats that can negatively impact an organization due to vulnerabilities within suppliers, their supply chains, or the cyber-related products and services they provide.
These risks may manifest through multiple channels, potentially compromising an organization's mission. They can lead to disruptions such as diminished service levels resulting in customer dissatisfaction, theft of intellectual property, or even severe degradation of critical mission and business processes
A critical aspect of these risks is the often limited visibility organizations have into the development, integration, and deployment processes of the products and services they procure.
This lack of visibility, as depicted in various figures and discussions in authoritative guides such as NIST SP 800-161r1, underscores the complexities involved in managing these risks effectively.
The introduction of cybersecurity threats into supply chains can occur in numerous ways. Counterfeit products or components can enter the supply chain, deceiving buyers and potentially introducing vulnerabilities.
Hardware or software may be delivered with malware intentionally embedded by malicious actors aiming to disrupt operations or steal data. Additionally, malware can be inserted into products post-delivery during maintenance or service processes, posing ongoing risks to users.
Another significant risk is the delivery of hardware or software that includes unwanted or undocumented functionalities. This can lead to unauthorized access or data leakage, further complicating the security landscape.
Insider threats, which include both adversarial and non-adversarial actions, are another source of risk. Employees or contractors with access to sensitive systems and data can unintentionally or intentionally cause significant damage.
Additionally, poor quality manufacturing, development, maintenance, or disposal practices can compromise the security and integrity of products, thereby affecting the entire supply chain.
Supply chain disruptions due to logistical issues, political instability, or natural disasters can further exacerbate these vulnerabilities. These disruptions lead to increased risks of theft or alteration of system data.
Such disruptions not only threaten the continuity of service but can also lead to long-term reputational damage if sensitive data is compromised.
In addressing these risks, organizations need to implement robust cybersecurity supply chain risk management (C-SCRM) practices. This includes thorough risk assessments, continuous monitoring of the supply chain, and the implementation of stringent security measures at all levels of procurement and throughout the lifecycle of the product or service.
The integration of advanced technologies such as AI and machine learning in monitoring tools can also provide deeper insights and enhance the detection of potential threats in real time. This significantly mitigates risks associated with the cybersecurity supply chain.
Get the full CSCRM guide to efficiently manage your supply chain risks and improve cybersecurity.
ICT/OT supply chains are increasingly vulnerable to an array of cybersecurity threats and other disruptive risks. These threats are rapidly evolving in sophistication, quantity, and diversity. They pose severe risks to the confidentiality, integrity, and availability of governmental data and information systems.
This array of threats includes but is not limited to, counterfeiting, tampering, theft, the introduction of unwanted functionalities, and the embedding of malicious content. Both intentional and unintentional threats exist.
Each has the potential to significantly undermine the security, resilience, and safety of the organization and its stakeholders.
Unintentional threats often stem from inadequate or subpar product security and integrity practices throughout the development lifecycle. This may lead to unintended access to critical systems and deficient procurement standards.
There can also be an overreliance on third-party providers for essential subcomponents and insufficient personnel vetting procedures.
Additionally, vulnerabilities that may be exploited by adversarial entities, malicious organizations, or nation-states often arise from poor process adherence during the product development lifecycle.
The frequency and magnitude of disruptions and attacks targeting ICT/OT supply chains are on the rise. Notable incidents include the SolarWinds hack, which involved the insertion of malware through software updates. This affected all users of the SolarWinds’ Orion platform, an infrastructure utilized by over 30,000 organizations globally, including numerous government organizations.
Another significant breach occurred through software provider Kaseya, which distributed ransomware affecting over 1,500 organizations. Furthermore, the exploitation of zero-day vulnerabilities in Microsoft Exchange compromised the systems of over 18,000 organizations worldwide.
External factors, such as the global disruptions caused by COVID-19, further exacerbate the vulnerability of these critical supply chains. Natural disasters, such as hurricanes, tsunamis, ice storms, and tornadoes, also add to these vulnerabilities.
The nature of cybersecurity risks in supply chains has evolved dramatically, influenced by several key trends:
The transformation in supply chain-related cybersecurity threats necessitates an agile, informed, and proactive stance on C-SCRM. This approach should incorporate not only technological defenses but also strategic collaborations and education initiatives to reinforce the entire network.
Federal, private, and corporate sectors must recognize that in the digital age, a secure supply chain is foundational to operational integrity and continuity.
The modern business ecosystem, especially within the government sector, demands an unprecedented focus on Cybersecurity Supply Chain Risk Management (C-SCRM). As the arteries of commerce and governance grow more digital and interconnected, the importance of safeguarding these lifelines from cyber threats cannot be overstated.
C-SCRM extends beyond safeguarding data—it’s integral to maintaining the operational heartbeat, protecting the company's innovations, and securing its reputation.
C-SCRM extends beyond safeguarding data—it’s integral to maintaining the operational heartbeat, protecting the company's innovations, and securing its reputation.
Exhibit 4: Cyber Threat Affecting Supply Chain Management
The globalization of supply chains has introduced complexities where a single weak link can cascade into systemic failures. For government entities, which often operate on an international scale, the ripple effects of a cyber incident can compromise national security and vital public services
Thus, C-SCRM becomes not just a protective measure but a strategic necessity to uphold global operations and maintain national interests.
Governments are bound by rigorous data protection and cybersecurity laws designed to fortify the security of intricate supply chains against emerging threats. Adherence to these regulations is non-negotiable, with the potential for severe legal and financial consequences in the event of non-compliance.
Implementing C-SCRM aligns government practices with standards such as NIST SP 800-161, ensuring that all supply chain activities meet the highest security benchmarks.
For government organizations, public trust is a currency as valuable as any budget allocation. A breach in cybersecurity can erode public confidence rapidly, leading to long-term reputational damage.
C-SCRM acts as a safeguard, ensuring that the integrity of public services remains untainted by cybersecurity threats, thereby preserving the trust placed in government institutions by the citizens.
Cybersecurity incidents in the supply chain can cause severe financial hemorrhage to businesses. When these systems are compromised, the effects can cascade, leading to:
Intellectual property is the lifeblood of innovation and competitive advantage. Cyber espionage can target this valuable asset through supply chain vulnerabilities. The stakes are:
Businesses operate within a framework of industry standards and regulations that include stiff penalties for non-compliance. Effective C-SCRM is vital for:
A brand is a promise of reliability. A breach can erode customer confidence, leading to:
Cybersecurity in the supply chain is not just a line item in the risk management budget; it's a comprehensive strategy that covers financial health, intellectual property protection, regulatory compliance, and the preservation of brand integrity.
By prioritizing C-SCRM, businesses can navigate this complex landscape, ensuring resilience against the multifaceted threats of the digital age. This proactive stance on cybersecurity becomes a keystone for sustained growth, innovation, and customer loyalty.
Cybersecurity Supply Chain Risk Management (C-SCRM) is an integral part of protecting an organization's supply chain from cyber threats and vulnerabilities that could compromise both the digital and physical security of goods and services.
This detailed analysis will break down the core components of a robust C-SCRM program, which includes safeguarding digital assets, ensuring physical security, and building reliable partnerships.
Software Supply Chain Risk Management (SCRM) focuses on protecting an organization's digital assets by managing and mitigating risks associated with the software supply chain.
This involves identifying vulnerabilities in software components, ensuring secure software development practices, and monitoring third-party suppliers to prevent security breaches and enhance overall digital security.
Software Supply Chain Risk Management ensures digital asset safety by identifying key risks, such as third-party vulnerabilities and malicious updates.
Mitigation strategies for software supply chain risks involve rigorous vendor security vetting to ensure compliance with security standards, implementing robust patch management to address vulnerabilities promptly, and employing software composition analysis tools to effectively identify and manage risks from third-party components.
Hardware Supply Chain Risk Management addresses the security challenges associated with technology's physical components. It involves rigorous supplier vetting, implementing secure transportation and storage practices, and utilizing tamper-evident packaging to protect against unauthorized access, counterfeiting, and tampering, thus safeguarding the integrity of physical assets throughout the supply chain.
Counterfeit components in the hardware supply chain compromise system integrity and introduce vulnerabilities. Tampering risks during manufacturing or transit can lead to malicious modifications that are hard to detect and pose severe security threats.
Rigorous supplier vetting ensures that manufacturing processes and security protocols meet high standards, reducing the risk of counterfeit or compromised components. Secure transportation and storage practices, alongside tamper-evident packaging, safeguard against unauthorized access and tampering, maintaining the integrity of hardware components throughout the supply chain.
Vendor Supply Chain Risk Management focuses on creating and maintaining secure and resilient partnerships with suppliers. It involves conducting thorough due diligence, establishing clear compliance and security expectations, and continuously monitoring vendor practices. This approach ensures that vendors align with an organization's security standards, thereby minimizing supply chain risks and enhancing overall reliability.
Opacity in security practices threatens vendor supply chains, making it challenging to assess vulnerabilities and variances in regulatory compliance. This can introduce legal and operational risks. Dependency on single sources for critical components creates vulnerabilities and potential disruptions.
Thorough due diligence on vendors' security practices and compliance, alongside diversifying supplier portfolios, mitigates these risks. Establishing clear compliance and security expectations with vendors ensures alignment on risk management practices, enhancing supply chain resilience and reliability.
When it comes to Cyber Supply Chain Risk Management (C-SCRM), understanding what's at stake is crucial for any business. The risks are not just theoretical but have real-world implications that can affect every aspect of an organization.
The potential impacts of not adequately managing cybersecurity risks within the supply chain may lead to operational disruptions, data breaches, and regulatory non-compliance.
Operational disruptions can have immediate and severe consequences for business continuity:
The implications of data breaches extend far beyond immediate financial losses:
Failing to comply with legal standards such as GDPR can lead to several issues:
Understanding and confronting the stakes involved with C-SCRM risks is essential for any business aiming to maintain a secure, reliable, and compliant operational framework.
By addressing these risks proactively, companies can safeguard their assets, preserve customer trust, and ensure regulatory compliance.
In Cyber Supply Chain Risk Management (C-SCRM), challenges can be transformed into significant business opportunities.
By proactively addressing C-SCRM challenges, companies can elevate their market standing, foster trust, and even pioneer new business models. Here's how businesses can convert C-SCRM risks into strategic advantages:
Enhancing security measures not only mitigates risks but also strengthens stakeholder confidence:
Robust C-SCRM practices can differentiate a company from its competitors:
Compliance with international standards and regulations can serve as a proof point of operational excellence:
Turning C-SCRM challenges into opportunities involves mitigating risks and leveraging these efforts to drive business growth, innovation, and competitive differentiation.
This approach secures the supply chain and aligns it with broader business objectives, turning potential vulnerabilities into catalysts for business enhancement
Bridging the gap between risk and security involves adopting integrated solutions, prioritizing C-SCRM education, and fostering continuous improvement to build a cohesive defense and adapt to evolving threats, enhancing organizational resilience.
Developing and enforcing strong security policies is crucial for effective C-SCRM:
Over the past decade, the escalation in both the frequency and severity of supply chain disruptions has catalyzed a significant shift in governmental policy across the United States. In response, a suite of legislative and executive measures has been rigorously implemented.
Key Legislative, Executive, and Regulatory Actions directing agencies to better manage Cybersecurity Supply Chain Risks:
Exhibit 10: Snapshot of Key Legislative, Executive, Regulatory Action to manage Cybersecurity Supply Chain Risks
Central to these efforts is the mandate that Federal executive branch organizations adopt Cybersecurity Supply Chain Risk Management (C-SCRM) practices grounded in the robust frameworks provided by the National Institute of Standards and Technology (NIST)
Furthermore, organizations are increasingly turning to commercial off-the-shelf (COTS) tools and services to bolster their in-house capabilities, ensuring these tools align with both overarching government directives and the nuanced needs of individual organizations.
Among the legislative cornerstones shaping these directives is the Federal Acquisition Supply Chain Security Act of 2018, encapsulated within the broader ambit of the Strengthening and Enhancing Cyber-capabilities by Utilizing Risk Exposure (SECURE) Technology Act.
This legislation obligates all federal organizations to establish comprehensive C-SCRM programs, emphasizing a strategic approach to prioritizing, assessing, and mitigating supply chain risks.
A pivotal aspect of this regulatory landscape is the prohibition under Section 889 of the National Defense Authorization Act (NDAA) for Fiscal Year 2019.
This section forbids executive organizations from contracting with entities utilizing telecommunications and surveillance equipment from specific manufacturers deemed security risks, such as Huawei Technologies and ZTE Corporation. This extends to any subcontractors, underlining the critical importance of transparency and vigilance in mapping out supply chains.
Further compounding the framework are several Executive Orders (EOs) from recent administrations that consolidate the strategic focus on protecting the Information and Communications Technology (ICT) supply chains vital to national security.
Notable among these are EO 13873, EO 14017, and EO 14028, which specifically address the resilience and security of America’s supply chains from external threats.
Supplementing these high-level directives, the Office of Management and Budget (OMB) Circular A-130 and various memoranda, including M-22-18 and its update M-23-16, lay out precise guidelines for federal organizations.
These documents mandate the adoption of secure software development practices as outlined in the NIST Secure Software Development Framework (SSDF) and the NIST Software Supply Chain Security Guidance.
Compliance is verified through self-attestation from software producers, ensuring adherence to these stringent standards before any software acquisition.
On a regulatory plane, the Federal Information Security Modernization Act of 2014 (FISMA) and the evolving Federal Acquisition Regulation (FAR), particularly the newly established FAR part 40, provide a structured framework for organizations to report on and enhance their C-SCRM practices.
These measures are designed not only to safeguard against the infiltration of counterfeit components but also to align product and service acquisitions with established cybersecurity and supply chain criteria.
As these layers of regulation and policy interlace, they form a comprehensive tapestry aimed at fortifying the United States against the multifaceted risks presented by an increasingly interconnected and potentially vulnerable global supply chain infrastructure.
The information below was provided in NIST SP 800-161r1 in Appendix E but is not a comprehensive list of all federal restrictions that prohibit the use of certain suppliers and the acquisition or use of certain items, services, or materials.
The Treasury Department, Office of Assets Control (OFAC), through EO 13694 and as amended by EO 13757, provided for the designation on the Specially Designated Nationals and Blocked Persons List (SDN List) of parties determined to be responsible for, complicit in, or to have engaged in, directly or indirectly, malicious cyber-enabled activities.
Any entity in which one or more blocked persons directly or indirectly holds a 50% or greater ownership interest in the aggregate is itself considered blocked by the operation of law. U.S. persons may not engage in any dealings, directly or indirectly, with blocked persons.
The sectoral sanctions imposed on specified persons operating in sectors of the Russian economy identified by the Secretary of the Treasury were done under EO 13662 through Directives issued by OFAC pursuant to its delegated authorities.
The SSI List identifies individuals who operate in the sectors of the Russian economy with whom U.S. persons are prohibited from transacting, providing financing for, or dealing in debt with a maturity of longer than 90 days.
OFAC publishes a list of foreign individuals and entities determined to have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions on Syria or Iran pursuant to EO 13608. It also lists foreign persons who have facilitated deceptive transactions for or on behalf of persons subject to U.S. sanctions.
Collectively, such individuals and companies are called “Foreign Sanctions Evaders” or “FSEs.” Transactions by U.S. persons or within the U.S. involving FSEs are prohibited.
The SAM contains the electronic roster of debarred companies excluded from federal procurement and non-procurement programs throughout the U.S. Government (unless otherwise noted), from receiving federal contracts or certain subcontracts, and from certain types of federal financial and non-financial assistance and benefits.
The SAM system combines data from the Central Contractor Registration, Federal Register, Online Representations and Certification Applications, and the Excluded Parties List System. It also reflects data from the Office of the Inspector General’s exclusion list (GSA) (CFR Title 2, Part 180).
The CAPTA List replaced the list of Foreign Financial Institutions Subject to Part 561. It includes the names of foreign financial institutions subject to sanctions, specific prohibitions, or strict conditions before a U.S. company may do business with them.
Pursuant to 31 CFR 560 and 31 CFR 560.304, property and persons included on this list must be blocked if they are in or come within the possession or control of a U.S. person.
Parties listed on the Unverified List (UVL) are ineligible to receive items subject to the Export Administration Regulations (EAR) by means of a license exception.
Unless a waiver or exception is granted, NDAA Section 889 prohibits the federal government, government contractors, and grant and loan recipients from procuring or using specific "covered telecommunication equipment or services" that are produced by Huawei, ZTE, Hytera, Hikvision, Dahua, and their subsidiaries as a "substantial or essential component of any system or as critical technology as part of any system."
Any other federal restriction or law that would restrict the acquisition of goods, services, or materials from a supplier.
The future of Cybersecurity Supply Chain Risk Management (C-SCRM) is marked by the integration of advanced technologies like AI, machine learning, and blockchain, which are set to significantly enhance security and transparency within supply chains.
AI and machine learning are being leveraged for predictive analytics, automated supplier assessments, and anomaly detection, offering a more proactive stance against vulnerabilities. Blockchain technology introduces unparalleled traceability, secure smart contracts, and decentralization, further bolstering supply chain resilience by removing single points of failure.
These innovations signal a shift towards a more secure, efficient, and transparent supply chain ecosystem.
Embarking on the journey of Cybersecurity Supply Chain Risk Management (C-SCRM) requires a systematic approach that blends analysis, strategy, and continuous refinement. This guide lays out the initial steps for integrating C-SCRM into your organizational fabric, ensuring a resilient supply chain against cyber threats.
Integrating Cybersecurity Supply Chain Risk Management (C-SCRM) into an organization is essential for safeguarding against the growing threats in today's digital and globally interconnected market. This guide provides a straightforward, step-by-step approach to implementing C-SCRM effectively within your organization, aimed at enhancing resilience and securing operations.
An important process in C-SCRM is executing cybersecurity SCRAs. Organizations perform SCRAs to identify and evaluate the supply chain-related risks that arise from using technology products and services.
The goal of a cybersecurity SCRA is ultimately to mitigate risks by addressing potential vulnerabilities that could be exploited by cyber attackers to compromise the confidentiality, integrity, and/or availability of organizations’ data, systems, and networks.
NIST SP800-161r1 identifies five components of SCRAs, found in Exhibit 11.
SCRAs are also required by FASCSA and other regulatory and executive actions. Organizations should conduct SCRAs prior to the acquisition or use of hardware, software, cloud services, and other technology-related services regularly throughout the system life cycle of those products and services and in case of a change in the risk environment (e.g., an incident, disruption, or change in regulation or guidance).
Organizations should perform SCRAs primarily to mitigate risks to their critical missions and sensitive data within their operational context, not simply to comply with mandates and regulatory requirements.
Note that even the service providers and tool providers that can support SCRAs should be assessed for cybersecurity supply chain risks.
Government mission and business process owners acquiring the product/service, in collaboration with the contracting officer (CO) or contracting officer representative (COR), should:
Organizations should select bids that offer the best value (not merely the lowest cost), considering all documented evidence (e.g., suppliers' demonstrated performance and past performance for the same or similar contracts) and the supplier risk assessment.
Mission and business owners should monitor risks based on the criticality of the supplier and its product or service. Triggers for conducting an SCRA include the following:
Organizations conduct analyses and assessments at the mission and systems levels in order to increase their visibility into their critical suppliers, products, and services.
A C-SCRM program management office (PMO) or team may assist other organization programs in developing SCRAs before entering those programs into a contractual agreement to acquire products or services.
An organization's enterprise-level C-SCRM strategy and policies may require programs seeking to acquire products and services to comply with SCRA. SCRA guidance in NIST SP 800-161r1 provides a step‐by‐step guide for business partners to follow in preparation for the C-SCRM PMO's assessment of suppliers
Exhibit 12 shows a sample SCRA process flow, showing when the process may be initiated and how information is collected and aggregated, leading to a risk assessment and monitoring of the risk environment.
Mission-level or program-level policy defines what integration activities require an SCRA. The process and requirements are described in the SCRA Standard Operating Procedure. The C-SCRM PMO may use all‐source information when conducting SCRAs.
Organizations should consider any information on the supplier that is pertinent to their trustworthiness; this could include information about the security, integrity, resilience, quality, and environmental, social, and governance (ESG) aspects of their services or products or of the processes and practices used throughout the supply chain.
As described in Appendix E of NIST SP 800-161r1, while certain SCRA functions are inherently governmental functions where the accountability and ultimate responsibility should not be outsourced (e.g., prioritizing SCRAs, evaluating impact, making risk response decisions, and taking actions based on the findings in an SCRA), organizations can and typically do acquire advisory services or commercially available data/tools for their supplier and product assessments.
Qualified technical advisory contract support can help organizations analyze suppliers, document findings, and review relevant information with appropriate requirements in place to safeguard classified or sensitive supply chain risk information.
NIST SP 800-161r1 also describes how information used for an assessment is comprised of up to three categories of inputs:
The NIST guidance also notes that the purpose and context, as well as when an assessment of a supplier and/or covered article is performed in the secure development life cycle (SDLC) or procurement life cycle, will drive variations in terms of focus and scope regarding what type, how much, and from what sources of information used in an assessment is obtained.
Organizations should consider applying this information against a consistent set of core baseline factors and assessment criteria based on organizations' risk tolerance and appetite. Each organization can use the risk factors listed and described in SP 800-161r1; depending on the specific context and purpose for which the assessment is being conducted, organizations may select additional factors. Organizations are cautioned regarding the quality of information (e.g., relevance, completeness, accuracy, etc.) relied upon for an assessment; organizations are recommended to document reference sources for assessment information and verify the information as appropriate.
Information about these baseline risk factors should be generally available from open sources. However, the type, quality, cost, and extent of information is likely to vary. Findings associated with these factors may reflect a mix of subjective and objective information regarding threats, vulnerabilities, or general "exposures" that, when assessed discretely or in the aggregate, indicate risk being possible or present. Government buyers of C-SCRM tools and services may choose to acquire more than one tool to obtain the needed data and analyses, as no one tool currently provides a comprehensive set of information that addresses all baseline risks.
To develop a tailored C-SCRM strategy, start by defining clear security and compliance objectives. Prioritize addressing critical vulnerabilities found during the assessment. Implement cybersecurity controls specific to your supply chain's needs and educate all stakeholders on their security roles to enhance overall protection.
Getting started with C-SCRM involves a commitment to thorough planning and continuous improvement. By assessing the current risk posture, developing a tailored strategy, and ensuring all stakeholders are engaged and educated, organizations can significantly enhance their supply chain resilience.
This not only protects against current threats but also prepares the organization to adapt to future challenges, maintaining the security and integrity of the supply chain in the long term.
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