The [organization] shall perform penetration testing/analysis: (1) On potential system elements before accepting the system; (2) As a realistic simulation of the active adversary’s known adversary tactics, techniques, procedures (TTPs), and tools; and (3) Throughout the lifecycle on physical and logical systems, elements, and processes.{SV-SP-3,SV-SP-4,SV-AV-7,SV-SP-11}{CA-8(1),SA-9,SA-11(5),SR-5(2)}
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Penetration testing should be performed throughout the lifecycle on physical and logical systems, elements, and processes including: (1) Hardware, software, and firmware development processes; (2) Shipping/handling procedures; (3) Personnel and physical security programs; (4) Configuration management tools/measures to maintain provenance; and (5) Any other programs, processes, or procedures associated with the production/distribution of supply chain elements.
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The [organization] shall maintain a list of suppliers and potential suppliers used, and the products that they supply to include software.{SV-SP-3,SV-SP-4,SV-SP-11}{CM-10,PL-8(2),PM-30,SA-8(9),SA-8(11)}
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Ideally you have diversification with suppliers
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The [organization] shall develop and implement anti-counterfeit policy and procedures designed to detect and prevent counterfeit components from entering the information system, including support tamper resistance and provide a level of protection against the introduction of malicious code or hardware.{SV-SP-3,SV-SP-4,SV-AV-7,SV-SP-11}{CM-3(8),CM-7(9),PM-30,SA-8(9),SA-8(11),SA-9,SA-10(3),SA-19,SC-51,SR-4(3),SR-4(4),SR-5(2),SR-11}
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The [organization] shall conduct a criticality analysis to identify mission critical functions and critical components and reduce the vulnerability of such functions and components through secure system design.{SV-SP-3,SV-SP-4,SV-AV-7,SV-MA-4}{CP-2,CP-2(8),PL-7,PM-11,PM-30(1),RA-3(1),RA-9,SA-8(9),SA-8(11),SA-8(25),SA-12,SA-14,SA-15(3),SC-7(29),SR-1}
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During SCRM, criticality analysis will aid in determining supply chain risk. For mission critical functions/components, extra scrutiny must be applied to ensure supply chain is secured.
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The [organization] shall report counterfeit information system components to [organization] officials. {SV-SP-4}{IR-6,IR-6(2),PM-30,SA-19,SR-11}
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The [organization] shall use all-source intelligence analysis of suppliers and potential suppliers of the information system, system components, or system services to inform engineering, acquisition, and risk management decisions.{SV-SP-3,SV-SP-4,SV-AV-7,SV-SP-11}{PM-16,PM-30,RA-2,RA-3(1),RA-3(2),RA-7,SA-9,SA-12(8),SR-5(2)}
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* The Program should also consider sub suppliers and potential sub suppliers.
* All-source intelligence of suppliers that the organization may use includes: (1) Defense Intelligence Agency (DIA) Threat Assessment Center (TAC), the enterprise focal point for supplier threat assessments for the DOD acquisition community risks; (2) Other U.S. Government resources including: (a) Government Industry Data Exchange Program (GIDEP) – Database where government and industry can record issues with suppliers, including counterfeits; and (b) System for Award Management (SAM) – Database of companies that are barred from doing business with the US Government.
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The [organization] shall request threat analysis of suppliers of critical components and manage access to and control of threat analysis products containing U.S.person information.{SV-SP-3,SV-SP-4,SV-SP-11}{PM-16,PM-30(1),RA-3(1),SA-9,SA-12,SR-1}
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The intent of this requirement is to address supply chain concerns on hardware and software vendors. Not required for trusted suppliers accredited to the Defense Microelectronic Activity (DMEA). If the Program intends to use a supplier not accredited by DMEA, the government customer should be notified as soon as possible. If the Program has internal processes to vet suppliers, it may meet this requirement. All software used and its origins must be included in the SBOM and be subjected to internal and Government vulnerability scans.
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The [organization] shall maintain documentation tracing the strategies, tools, and methods implemented to mitigate supply chain risk .{SV-SP-3,SV-SP-4,SV-AV-7}{PM-30,RA-3(1),SA-12(1),SR-5}
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Examples include: (1) Transferring a portion of the risk to the developer or supplier through the use of contract language and incentives; (2) Using contract language that requires the implementation of SCRM throughout the system lifecycle in applicable contracts and other acquisition and assistance instruments (grants, cooperative agreements, Cooperative Research and Development Agreements (CRADAs), and other transactions). Within the DOD some examples include: (a) Language outlined in the Defense Acquisition Guidebook section 13.13. Contracting; (b) Language requiring the use of protected mechanisms to deliver elements and data about elements, processes, and delivery mechanisms; (c) Language that articulates that requirements flow down supply chain tiers to sub-prime suppliers. (3) Incentives for suppliers that: (a) Implement required security safeguards and SCRM best practices; (b) Promote transparency into their organizational processes and security practices; (c) Provide additional vetting of the processes and security practices of subordinate suppliers, critical information system components, and services; and (d) Implement contract to reduce SC risk down the contract stack. (4) Gaining insight into supplier security practices; (5) Using contract language and incentives to enable more robust risk management later in the lifecycle; (6) Using a centralized intermediary or “Blind Buy” approaches to acquire element(s) to hide actual usage locations from an untrustworthy supplier or adversary;
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The [organization] shall protect against supply chain threats to the system, system components, or system services by employing security safeguards as defined by NIST SP 800-161 Rev.1.{SV-SP-3,SV-SP-4,SV-AV-7,SV-SP-11}{PM-30,RA-3(1),SA-8(9),SA-8(11),SA-12,SI-3,SR-1}
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The chosen supply chain safeguards should demonstrably support a comprehensive, defense-in-breadth information security strategy. Safeguards should include protections for both hardware and software. Program should define their critical components (HW & SW) and identify the supply chain protections, approach/posture/process.
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The [organization] shall develop and implement anti-counterfeit policy and procedures, in coordination with the [CIO], that is demonstrably consistent with the anti-counterfeit policy defined by the Program office.{SV-SP-4,SV-SP-11}{SR-11}
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The [organization] shall employ [organization]-defined techniques to limit harm from potential adversaries identifying and targeting the Program supply chain.{SV-SP-3,SV-SP-4,SV-AV-7,SV-SP-11}{SR-3(2),SC-38}
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Examples of security safeguards that the organization should consider implementing to limit the harm from potential adversaries targeting the organizational supply chain, are: (1) Using trusted physical delivery mechanisms that do not permit access to the element during delivery (ship via a protected carrier, use cleared/official couriers, or a diplomatic pouch); (2) Using trusted electronic delivery of products and services (require downloading from approved, verification-enhanced sites); (3) Avoiding the purchase of custom configurations, where feasible; (4) Using procurement carve outs (i.e., exclusions to commitments or obligations), where feasible; (5) Using defensive design approaches; (6) Employing system OPSEC principles; (7) Employing a diverse set of suppliers; (8) Employing approved vendor lists with standing reputations in industry; (9) Using a centralized intermediary and “Blind Buy” approaches to acquire element(s) to hide actual usage locations from an untrustworthy supplier or adversary Employing inventory management policies and processes; (10) Using flexible agreements during each acquisition and procurement phase so that it is possible to meet emerging needs or requirements to address supply chain risk without requiring complete revision or re-competition of an acquisition or procurement; (11) Using international, national, commercial or government standards to increase potential supply base; (12) Limiting the disclosure of information that can become publicly available; and (13) Minimizing the time between purchase decisions and required delivery.
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The [organization] shall employ the [organization]-defined approaches for the purchase of the system, system components, or system services from suppliers.{SV-SP-3,SV-SP-4,SV-AV-7,SV-SP-11}{SR-5}
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This could include tailored acquisition strategies, contract tools, and procurement methods.
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The [organization] (and Prime Contractor) shall conduct a supplier review prior to entering into a contractual agreement with a contractor (or sub-contractor) to acquire systems, system components, or system services.{SV-SP-3,SV-SP-4,SV-AV-7,SV-SP-11}{SR-6}
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The [organization] shall employ [Selection (one or more): independent third-party analysis, Program penetration testing, independent third-party penetration testing] of [Program-defined supply chain elements, processes, and actors] associated with the system, system components, or system services.{SV-SP-3,SV-SP-4,SV-AV-7,SV-SP-11}{SR-6(1)}
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The [organization] shall employ [Program-defined Operations Security (OPSEC) safeguards] to protect supply chain-related information for the system, system components, or system services.{SV-SP-3,SV-SP-4,SV-AV-7,SV-SP-11}{SR-7,SC-38,CP-2(8)}
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OPSEC safeguards may include: (1) Limiting the disclosure of information needed to design, develop, test, produce, deliver, and support the element for example, supplier identities, supplier processes, potential suppliers, security requirements, design specifications, testing and evaluation result, and system/component configurations, including the use of direct shipping, blind buys, etc.; (2) Extending supply chain awareness, education, and training for suppliers, intermediate users, and end users; (3) Extending the range of OPSEC tactics, techniques, and procedures to potential suppliers, contracted suppliers, or sub-prime contractor tier of suppliers; and (4) Using centralized support and maintenance services to minimize direct interactions between end users and original suppliers.
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