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Number Title Impact Priority Subject Area
SA-12 Supply Chain Protection HIGH P1 System And Services Acquisition

The organization protects against supply chain threats to the information system, system component, or information system service by employing Assignment: organization-defined security safeguards as part of a comprehensive, defense-in-breadth information security strategy.
Information systems (including system components that compose those systems) need to be protected throughout the system development life cycle (i.e., during design, development, manufacturing, packaging, assembly, distribution, system integration, operations, maintenance, and retirement). Protection of organizational information systems is accomplished through threat awareness, by the identification, management, and reduction of vulnerabilities at each phase of the life cycle and the use of complementary, mutually reinforcing strategies to respond to risk. Organizations consider implementing a standardized process to address supply chain risk with respect to information systems and system components, and to educate the acquisition workforce on threats, risk, and required security controls. Organizations use the acquisition/procurement processes to require supply chain entities to implement necessary security safeguards to: (i) reduce the likelihood of unauthorized modifications at each stage in the supply chain; and (ii) protect information systems and information system components, prior to taking delivery of such systems/components. This control enhancement also applies to information system services. Security safeguards include, for example: (i) security controls for development systems, development facilities, and external connections to development systems; (ii) vetting development personnel; and (iii) use of tamper-evident packaging during shipping/warehousing. Methods for reviewing and protecting development plans, evidence, and documentation are commensurate with the security category or classification level of the information system. Contracts may specify documentation protection requirements.

SA-12 (1) Acquisition Strategies / Tools / Methods
The use of acquisition and procurement processes by organizations early in the system development life cycle provides an important vehicle to protect the supply chain. Organizations use available all-source intelligence analysis to inform the tailoring of acquisition strategies, tools, and methods. There are a number of different tools and techniques available (e.g., obscuring the end use of an information system or system component, using blind or filtered buys). Organizations also consider creating incentives for suppliers who: (i) implement required security safeguards; (ii) promote transparency into their organizational processes and security practices; (iii) provide additional vetting of the processes and security practices of subordinate suppliers, critical information system components, and services; (iv) restrict purchases from specific suppliers or countries; and (v) provide contract language regarding the prohibition of tainted or counterfeit components. In addition, organizations consider minimizing the time between purchase decisions and required delivery to limit opportunities for adversaries to corrupt information system components or products. Finally, organizations can use trusted/controlled distribution, delivery, and warehousing options to reduce supply chain risk (e.g., requiring tamper-evident packaging of information system components during shipping and warehousing).

The organization employs Assignment: organization-defined tailored acquisition strategies, contract tools, and procurement methods for the purchase of the information system, system component, or information system service from suppliers.

SA-12 (2) Supplier Reviews
Supplier reviews include, for example: (i) analysis of supplier processes used to design, develop, test, implement, verify, deliver, and support information systems, system components, and information system services; and (ii) assessment of supplier training and experience in developing systems, components, or services with the required security capability. These reviews provide organizations with increased levels of visibility into supplier activities during the system development life cycle to promote more effective supply chain risk management. Supplier reviews can also help to determine whether primary suppliers have security safeguards in place and a practice for vetting subordinate suppliers, for example, second- and third-tier suppliers, and any subcontractors.

The organization conducts a supplier review prior to entering into a contractual agreement to acquire the information system, system component, or information system service.

SA-12 (3) Trusted Shipping And Warehousing

Withdrawn: Incorporated into SA-12 (1).

SA-12 (4) Diversity Of Suppliers

Withdrawn: Incorporated into SA-12 (13).

SA-12 (5) Limitation Of Harm
Supply chain risk is part of the advanced persistent threat (APT). Security safeguards and countermeasures to reduce the probability of adversaries successfully identifying and targeting the supply chain include, for example: (i) avoiding the purchase of custom configurations to reduce the risk of acquiring information systems, components, or products that have been corrupted via supply chain actions targeted at specific organizations; (ii) employing a diverse set of suppliers to limit the potential harm from any given supplier in the supply chain; (iii) employing approved vendor lists with standing reputations in industry, and (iv) using procurement carve outs (i.e., exclusions to commitments or obligations).

The organization employs Assignment: organization-defined security safeguards to limit harm from potential adversaries identifying and targeting the organizational supply chain.

SA-12 (6) Minimizing Procurement Time

Withdrawn: Incorporated into SA-12 (1).

SA-12 (7) Assessments Prior To Selection / Acceptance / Update
Assessments include, for example, testing, evaluations, reviews, and analyses. Independent, third-party entities or organizational personnel conduct assessments of systems, components, products, tools, and services. Organizations conduct assessments to uncover unintentional vulnerabilities and intentional vulnerabilities including, for example, malicious code, malicious processes, defective software, and counterfeits. Assessments can include, for example, static analyses, dynamic analyses, simulations, white, gray, and black box testing, fuzz testing, penetration testing, and ensuring that components or services are genuine (e.g., using tags, cryptographic hash verifications, or digital signatures). Evidence generated during security assessments is documented for follow-on actions carried out by organizations.

The organization conducts an assessment of the information system, system component, or information system service prior to selection, acceptance, or update.

SA-12 (8) Use Of All-Source Intelligence
All-source intelligence analysis is employed by organizations to inform engineering, acquisition, and risk management decisions. All-source intelligence consists of intelligence products and/or organizations and activities that incorporate all sources of information, most frequently including human intelligence, imagery intelligence, measurement and signature intelligence, signals intelligence, and open source data in the production of finished intelligence. Where available, such information is used to analyze the risk of both intentional and unintentional vulnerabilities from development, manufacturing, and delivery processes, people, and the environment. This review is performed on suppliers at multiple tiers in the supply chain sufficient to manage risks.

The organization uses all-source intelligence analysis of suppliers and potential suppliers of the information system, system component, or information system service.

SA-12 (9) Operations Security
Supply chain information includes, for example: user identities; uses for information systems, information system components, and information system services; supplier identities; supplier processes; security requirements; design specifications; testing and evaluation results; and system/component configurations. This control enhancement expands the scope of OPSEC to include suppliers and potential suppliers. OPSEC is a process of identifying critical information and subsequently analyzing friendly actions attendant to operations and other activities to: (i) identify those actions that can be observed by potential adversaries; (ii) determine indicators that adversaries might obtain that could be interpreted or pieced together to derive critical information in sufficient time to cause harm to organizations; (iii) implement safeguards or countermeasures to eliminate or reduce to an acceptable level, exploitable vulnerabilities; and (iv) consider how aggregated information may compromise the confidentiality of users or uses of the supply chain. OPSEC may require organizations to withhold critical mission/business information from suppliers and may include the use of intermediaries to hide the end use, or users, of information systems, system components, or information system services.

The organization employs Assignment: organization-defined Operations Security (OPSEC) safeguards in accordance with classification guides to protect supply chain-related information for the information system, system component, or information system service.

SA-12 (10) Validate As Genuine And Not Altered
For some information system components, especially hardware, there are technical means to help determine if the components are genuine or have been altered. Security safeguards used to validate the authenticity of information systems and information system components include, for example, optical/nanotechnology tagging and side-channel analysis. For hardware, detailed bill of material information can highlight the elements with embedded logic complete with component and production location.

The organization employs Assignment: organization-defined security safeguards to validate that the information system or system component received is genuine and has not been altered.

SA-12 (11) Penetration Testing / Analysis Of Elements, Processes, And Actors
This control enhancement addresses analysis and/or testing of the supply chain, not just delivered items. Supply chain elements are information technology products or product components that contain programmable logic and that are critically important to information system functions. Supply chain processes include, for example: (i) hardware, software, and firmware development processes; (ii) shipping/handling procedures; (iii) personnel and physical security programs; (iv) configuration management tools/measures to maintain provenance; or (v) any other programs, processes, or procedures associated with the production/distribution of supply chain elements. Supply chain actors are individuals with specific roles and responsibilities in the supply chain. The evidence generated during analyses and testing of supply chain elements, processes, and actors is documented and used to inform organizational risk management activities and decisions.

The organization employs Selection (one or more): organizational analysis, independent third-party analysis, organizational penetration testing, independent third-party penetration testing of Assignment: organization-defined supply chain elements, processes, and actors associated with the information system, system component, or information system service.

SA-12 (12) Inter-Organizational Agreements
The establishment of inter-organizational agreements and procedures provides for notification of supply chain compromises. Early notification of supply chain compromises that can potentially adversely affect or have adversely affected organizational information systems, including critical system components, is essential for organizations to provide appropriate responses to such incidents.

The organization establishes inter-organizational agreements and procedures with entities involved in the supply chain for the information system, system component, or information system service.

SA-12 (13) Critical Information System Components
Adversaries can attempt to impede organizational operations by disrupting the supply of critical information system components or corrupting supplier operations. Safeguards to ensure adequate supplies of critical information system components include, for example: (i) the use of multiple suppliers throughout the supply chain for the identified critical components; and (ii) stockpiling of spare components to ensure operation during mission-critical times.

The organization employs Assignment: organization-defined security safeguards to ensure an adequate supply of Assignment: organization-defined critical information system components.

SA-12 (14) Identity And Traceability
Knowing who and what is in the supply chains of organizations is critical to gaining visibility into what is happening within such supply chains, as well as monitoring and identifying high-risk events and activities. Without reasonable visibility and traceability into supply chains (i.e., elements, processes, and actors), it is very difficult for organizations to understand and therefore manage risk, and to reduce the likelihood of adverse events. Uniquely identifying acquirer and integrator roles, organizations, personnel, mission and element processes, testing and evaluation procedures, delivery mechanisms, support mechanisms, communications/delivery paths, and disposal/final disposition activities as well as the components and tools used, establishes a foundational identity structure for assessment of supply chain activities. For example, labeling (using serial numbers) and tagging (using radio-frequency identification [RFID] tags) individual supply chain elements including software packages, modules, and hardware devices, and processes associated with those elements can be used for this purpose. Identification methods are sufficient to support the provenance in the event of a supply chain issue or adverse supply chain event.

The organization establishes and retains unique identification of Assignment: organization-defined supply chain elements, processes, and actors for the information system, system component, or information system service.

SA-12 (15) Processes To Address Weaknesses Or Deficiencies
Evidence generated during independent or organizational assessments of supply chain elements (e.g., penetration testing, audits, verification/validation activities) is documented and used in follow-on processes implemented by organizations to respond to the risks related to the identified weaknesses and deficiencies. Supply chain elements include, for example, supplier development processes and supplier distribution systems.

The organization establishes a process to address weaknesses or deficiencies in supply chain elements identified during independent or organizational assessments of such elements.