Guidance
Executive Order 14028, issued by President Biden, is a significant step towards enhancing the nation's cybersecurity infrastructure. It introduces a series of complex requirements that software companies must adhere to, creating a challenging landscape for compliance. Our guidance aims to simplify these complexities, providing a clear path for software companies to follow.
We understand the intricacies of this order and the potential impact it can have on your business. Our guidance is designed to help you navigate these changes, ensuring your company remains compliant while also enhancing your cybersecurity practices. Key points include understanding the order's requirements, implications for software development, impact on supply chains, necessary changes to cybersecurity practices, and strategies for compliance.
- Decoding the order's requirements for enhanced software supply chain security.
- Implications for software development and deployment under the new mandate.
- Strategies for adapting cybersecurity practices to meet new regulations.
- Ensuring long-term compliance while optimizing business operations.
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Impact
The Executive Order 14028 has a profound impact on the software development lifecycle, particularly in areas of security and supply chain integrity. It mandates the adoption of security development practices such as code review, vulnerability scanning, and the use of automated tools for detecting vulnerabilities and dependencies.
This means software companies must integrate these practices into their development pipelines, necessitating changes in their DevOps processes and possibly their choice of development tools. Furthermore, the order emphasizes the need for transparency in the software supply chain, requiring companies to maintain detailed and accurate Software Bill of Materials (SBOM). This SBOM should include details about each component used in the software, its origin, and any known vulnerabilities, which can be a significant undertaking given the complexity of modern software applications.
The order also has implications for incident response and vulnerability disclosure. It stipulates that companies must have a coordinated vulnerability disclosure policy, and be able to respond swiftly and effectively to any security incidents. This requires not only technical capabilities, but also procedural and organizational changes.
Companies must establish clear lines of communication for reporting vulnerabilities, and processes for triaging and addressing these reports. They must also be able to conduct thorough post-incident reviews to identify and address the root causes of any security incidents. These requirements underscore the need for a robust, well-integrated security culture within software companies, extending beyond the IT department to encompass the entire organization.
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Cybersecurity is a crucial aspect of any organization's operations, especially for those working with government entities. EO 14028 has set forth a comprehensive set of requirements aimed at strengthening the cybersecurity posture of the United States.
As organizations navigate this landscape, understanding the specific requirements, effective implementation strategies, gaining insights from real-world experiences, and knowing how these integrate with existing standards such as FedRAMP and StateRAMP is key.
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In the realm of software security, understanding and meeting the requirements of Executive Order 14028 is paramount. These requirements encompass several key areas, including supply chain security, cybersecurity adaptation, and compliance assurance.
They mandate organizations to establish robust security practices, maintain transparency in their software supply chains, and ensure long-term compliance with the order.
Understand the need for transparency in your software supply chain. Maintain a detailed Software Bill of Materials (SBOM) to track components, origins, and vulnerabilities.
Adapt your cybersecurity practices to meet the order's requirements. Integrate security development practices such as code review and vulnerability scanning into your development pipelines.
Ensure long-term compliance with the order. Establish clear lines of communication for reporting vulnerabilities and processes for addressing these reports.
Prepare for the order's requirement for monthly reporting. This is a key difference from standards like SOC 2 and PCI-DSS, which do not require such frequent reporting.
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Implementing the requirements of EO 14028 involves adopting new security practices, maintaining a detailed Software Bill of Materials (SBOM), and establishing a coordinated vulnerability disclosure policy. It also necessitates the development of robust incident management capabilities.
Integrate security development practices into your DevOps processes. Use automated tools for detecting vulnerabilities and dependencies.
Maintain a detailed and accurate Software Bill of Materials (SBOM). Include details about each component used in the software, its origin, and any known vulnerabilities.
Establish a coordinated vulnerability disclosure policy. Set up clear lines of communication for reporting vulnerabilities and processes for triaging and addressing these reports.
Implement robust configuration management practices. Ensure systems are configured to a secure state and continuously monitor for any deviations.
Adhere to NIST standards for cybersecurity and risk management. Use the NIST Cybersecurity Framework to guide your security practices.
Establish processes for monthly reporting to meet the order's requirements. Ensure you have the capabilities to gather, analyze, and report the necessary data on a monthly basis.
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Gaining insights from real-world experiences and lessons can significantly enhance your efforts to comply with EO 14028.
Unlike SOC 2 and PCI-DSS, EO 14028 mandates monthly reporting. This frequency underscores the importance of having robust data collection and reporting mechanisms in place. It also highlights the need for continuous monitoring and improvement of cybersecurity practices."
Effective configuration management is crucial under EO 14028. Ensuring systems are configured to a secure state and continuously monitoring for any deviations can help prevent security incidents and improve your organization's overall cybersecurity posture.
Software Supply Chain Transparency
The order places a significant emphasis on software supply chain transparency, requiring a detailed Software Bill of Materials (SBOM). An SBOM provides visibility into the components used in your software, their origins, and any known vulnerabilities, enabling better risk management.
EO 14028 underscores the importance of being prepared for cybersecurity incidents. Having a clear incident response plan, conducting regular drills, and learning from each incident are key to minimizing the impact of any security breaches and ensuring swift recovery.
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FedRAMP and StateRAMP are both government programs designed to standardize security assessments and authorization for cloud products and services. While they are not directly part of EO 14028, they align with its goals of improving software security in the government sector.
Here are some points on how they integrate with the EO:
FedRAMP and StateRAMP provide unified security standards for cloud services, aligning with EO 14028's aim to standardize and improve cybersecurity practices across government agencies.
Both the EO and these programs emphasize risk-based decision-making. They encourage organizations to understand their digital environments, assess risks, and implement appropriate security measures.
EO 14028's focus on software supply chain security complements the security assessment and authorization processes of FedRAMP and StateRAMP, which evaluate the security practices of cloud service providers.
Continuous monitoring is a key component of both the EO and FedRAMP/StateRAMP. They all emphasize the need for ongoing assessment and improvement of cybersecurity practices.
EO 14028, FedRAMP, and StateRAMP all require robust incident response capabilities, underscoring the importance of being prepared for cybersecurity incidents and being able to respond effectively when they occur.
- Question: What is the purpose of EO 14028?
Answer: EO 14028, or the "Improving the Nation's Cybersecurity" order, was issued to enhance the cybersecurity defenses of the United States. It focuses on modernizing cybersecurity defenses, improving information sharing between the government and the private sector, securing the software supply chain, and standardizing the government's incident response procedures. - Question: How does EO 14028 affect software supply chain security?
Answer: EO 14028 calls for developing guidelines and standards to enhance the security of the software supply chain. It requires developers to maintain greater visibility into their software and make security data publicly available. This includes maintaining a Software Bill of Materials (SBOM) for each product, which provides transparency into the components used in the software, their origins, and any known vulnerabilities. - Question: What is the role of the Cyber Safety Review Board established by EO 14028?
Answer: The Cyber Safety Review Board is tasked with reviewing and assessing significant cybersecurity incidents across federal and non-federal systems. The board includes federal officials and representatives from private sector entities and is modeled after the National Transportation Safety Board, which investigates airplane crashes and other incidents. - Question: How does EO 14028 relate to other cybersecurity standards and regulations like NIST, FedRAMP, and StateRAMP?
Answer: While EO 14028 is a separate directive, it aligns with the goals of standards and regulations like NIST, FedRAMP, and StateRAMP. All of these initiatives aim to enhance cybersecurity practices and reduce risks. For example, EO 14028's emphasis on zero-trust architecture and secure cloud services aligns with the security controls and guidelines outlined in NIST and FedRAMP. - Question: What are the implications of EO 14028 for federal IT and OT service providers?
Answer: Federal IT and OT service providers must share breach information with the government under EO 14028. This is designed to enable faster and more effective government responses to cybersecurity threats. These service providers must also comply with the enhanced software supply chain security measures outlined in the order.
- Question: How does EO 14028 enhance the cybersecurity defenses of federal agencies and their contractors?
Answer: EO 14028 mandates several key enhancements for cybersecurity defenses. It requires federal IT and OT service providers to share certain breach information with the government, promotes the adoption of security best practices like Zero Trust Architecture and secure cloud services, and emphasizes the importance of software supply chain security. It also calls for the establishment of a Cyber Safety Review Board to review and assess threat activity and incident response activities. - Question: What implications does EO 14028 have on software development and product design?
Answer: EO 14028 places a significant emphasis on software supply chain security. It requires developers to maintain a detailed Software Bill of Materials (SBOM) and establishes standards for maintaining secure and transparent software supply chains. This means product design and development processes may need to be adjusted to ensure greater visibility into software components, their origins, and any known vulnerabilities. - Question: How does EO 14028 integrate with existing cybersecurity standards like NIST, FedRAMP, and StateRAMP?
Answer: EO 14028 aligns with the goals of standards like NIST, FedRAMP, and StateRAMP, all of which aim to enhance cybersecurity practices and reduce risks. For example, EO 14028's emphasis on Zero Trust Architecture and secure cloud services aligns with the security controls and guidelines outlined in NIST and FedRAMP. While it's a separate directive, its integration with these existing standards can support a holistic approach to cybersecurity.
- Question: How does EO 14028's monthly cyber incident reporting requirement differ from other standards?
Answer: EO 14028 mandates monthly cyber incident reporting, unlike many other standards. This means organizations must have robust data collection and reporting mechanisms in place. It underscores the importance of continuous monitoring and improvement of cybersecurity practices and the need for organizations to identify and address threats proactively. - Question: How can product teams adapt their processes to meet the software supply chain security requirements of EO 14028?
Answer: Product teams can start by creating a detailed Software Bill of Materials (SBOM) for each product, which provides transparency into software components and their origins. This can be integrated into the product development lifecycle. Teams should also consider tools and practices that support automated tracking and auditing of software components to ensure ongoing compliance with the order's requirements. - Question: How can organizations align their strategic technology roadmap with the directives of EO 14028?
Answer: Organizations can start by integrating the order's directives into their strategic planning. This could involve prioritizing investments in secure cloud services, Zero Trust Architecture, and continuous monitoring and incident response tools. It's also important to consider the order's implications for vendor relationships, as the software supply chain security requirements may necessitate closer scrutiny of vendors' security practices.
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Executive Takeaways
Executive Order 14028, "Improving the Nation's Cybersecurity," is a pivotal directive that has far-reaching implications for the cybersecurity landscape. It emphasizes a comprehensive, strategic approach to enhance the nation's cybersecurity defenses and underscores the importance of collaboration, transparency, and adoption of security best practices. The following executive takeaways distill the key aspects of EO 14028, providing a high-level understanding of its impact and the strategic considerations it brings to the forefront.
- EO 14028 signifies a strategic shift towards prioritizing cybersecurity at the highest levels of government. It mandates a comprehensive approach to enhance the nation's cybersecurity defenses, underscoring the importance of cybersecurity in national security and economic stability.
- The order places a significant emphasis on software supply chain security, requiring developers to maintain a detailed Software Bill of Materials (SBOM). This promotes greater visibility into software components, their origins, and any known vulnerabilities, ultimately enhancing the security of software products.
- EO 14028 mandates federal IT and OT service providers to share certain breach information with the government. This collaborative approach is designed to enable faster and more effective government responses to cybersecurity threats.
- The order promotes the adoption of security best practices like Zero Trust Architecture and secure cloud services, aligning with the security controls and guidelines outlined in existing standards like NIST and FedRAMP.
- EO 14028 calls for the establishment of a Cyber Safety Review Board to review and assess significant cybersecurity incidents. This board will play a crucial role in improving the nation's incident response capabilities.
- Unlike many other standards, EO 14028 mandates monthly cyber incident reporting. This underscores the importance of continuous monitoring and improvement of cybersecurity practices, and the need for organizations to be proactive about identifying and addressing threats.