Practice RA.L3-3.11.7e Details

Source of Reference: The official CMMC Level 3 Assessment Guide from the Department of Defense Chief Information Officer (DoD CIO).

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RA.L3-3.11.7E – SUPPLY CHAIN RISK PLAN

SECURITY REQUIREMENT

Develop a plan for managing supply chain risks associated with organizational systems and system components; update the plan at least annually, and upon receipt of relevant cyber threat information, or in response to a relevant cyber incident.

ASSESSMENT OBJECTIVES [NIST SP 800-172A]

Determine if:

[a] Supply chain risks associated with organizational systems and system components are identified;

[b] Organizational systems and system components to include in a supply chain risk management plan are identified;

[c] A plan for managing supply chain risks associated with organizational systems and system components is developed; and

[d] The plan for managing supply chain risks is updated at least annually, and upon receipt of relevant cyber threat information, or in response to a relevant cyber incident.

POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A]

Examine

[SELECT FROM: Risk assessment policy; supply chain risk management plan; security planning policy and procedures; procedures addressing organizational assessments of risk; security plan; risk assessment; risk assessment results; risk assessment reviews; risk assessment updates; threat intelligence information; other relevant documents or records].

Interview

[SELECT FROM: Organizational personnel responsible for information security; organizational personnel responsible for risk assessments; organizational personnel responsible for supply chain risk management].

Test

[SELECT FROM: Automated mechanisms supporting, conducting, documenting, reviewing, disseminating, and updating risk assessments].

DISCUSSION [NIST SP 800-172]

The growing dependence on products, systems, and services from external providers, along with the nature of the relationships with those providers, present an increasing level of risk to an organization. Threat actions that may increase risk include the insertion or use of counterfeits, unauthorized production, tampering, theft, insertion of malicious software and hardware, and poor manufacturing and development practices in the supply chain. Supply chain risks can be endemic or systemic within a system element or component, a system, an organization, a sector, or the Nation. Managing supply chain risk is a multifaceted undertaking that requires a coordinated effort across an organization to build trust relationships and communicate with both internal and external stakeholders. Supply chain risk management (SCRM) activities involve identifying and assessing risks, determining appropriate mitigating actions, developing SCRM plans to document selected mitigating actions, and monitoring performance against plans. SCRM plans address requirements for developing trustworthy, secure, and resilient systems and system components, including the application of the security design principles implemented as part of life cycle-based systems security engineering processes.

[NIST SP 800-161 Rev. 1] provides guidance on supply chain risk management.

FURTHER DISCUSSION

An organization is required to have a supply chain risk management plan that assesses and responds to the identified risks from those organizations that provide IT products or services, including any cloud or other third-party services with a role in the operation of the system. The organization should be cognizant of services outside the scope of the system but required for the operation of the system as part of their plan. Since the cyber environment changes rapidly and continuously, it is equally important for the organization to update the plan in response to supply chain cyber incidents or emerging information.

Example

You are responsible for information security in your organization, and you have created a supply chain risk management plan [a,b,c]. One of the organization’s suppliers determines that it has been the victim of a cyberattack. Your security team meets with the supplier to determine the nature of the attack and to understand the adversary, the attack, the potential for corruption of delivered goods or services, and current as well as future risks. The understanding of the supply chain will help protect the local environment. Subsequently, you update the risk management plan to include a description of the necessary configuration changes or upgrades to monitoring tools to improve the ability to identify the new risks, and when improved tools are available, you document the acquisition of defensive tools and associated functionality to help mitigate any of the identified techniques [d].

Potential Assessment Considerations

• Does the organization’s current supply chain risk management plan apply across the enterprise, or does it only apply to a limited portion of the supply chain [b]?

KEY REFERENCES

• NIST SP 800-172 3.11.7e