Third-Party Risk Management: Moving from Reactive to Proactive

In today’s interconnected world, cyber threats are more sophisticated, with 83% of cyberattacks originating externally, according to the 2023 Verizon Data Breach Investigations Report (DBIR). This has prompted organizations to rethink third-party risk management. The 2023 Gartner Reimagining Third Party Cybersecurity Risk Management Survey found that 65% of security leaders increased their budgets, 76% invested more time and resources and 66% enhanced automation tools to combat third-party risks. Despite these efforts, 45% still reported increased disruptions from supply chain vulnerabilities, highlighting the need for more effective strategies.

Information vs Actionable Alerts

The constant evolution and splintering of illicit actors pose a challenge for organizations. Many threat groups have short lifespans or re-form due to law enforcement takedowns, infighting and shifts in ransomware-as-a-service networks, making it difficult for organizations to keep pace. A countermeasure against one attack may quickly become outdated as these threats evolve, requiring constant adaptation to new variations.

In cybersecurity, information is abundant, but decision-makers must distinguish the difference between information and actionable alerts. Information provides awareness but does not always drive immediate action, whereas alerts deliver real-time insights, enabling quick threat identification and response. Public data and real-time alerts help detect threats not visible in existing systems, allowing organizations to make proactive defense adjustments.

Strategies for Managing Third-Party Risk

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Managing third-party risk has become a critical challenge. The NIST Cybersecurity Framework (CSF) 2.0 emphasizes that governance must be approached holistically and highlights the importance of comprehensive third-party risk management. Many organizations rely on vendor surveys, attestations and security ratings, but these provide merely a snapshot in time and are often revisited only during contract negotiations. The NIST CSF 2.0 calls for continuous monitoring—a practice many organizations follow, though it is often limited to identifying trends and anomalies in internal telemetry data, rather than extending to third-party systems where potential risks may go unnoticed. Failing to consistently assess changes in third-party risks leaves organizations vulnerable to attack.

Many contracts require self-reporting, but this relies on the vendor detecting breaches, and there is no direct visibility into third-party systems like there is with internal systems. Understanding where data is stored, how it is handled and whether it is compromised is critical, but organizations often struggle to continuously monitor these systems. Government organizations, in particular, must manage their operations with limited budgets, making it difficult to scale with the growing number of vendors and service providers they need to oversee. Threat actors exploit this by targeting smaller vendors to access larger organizations.

Current strategies rely too heavily on initial vetting and lack sufficient post-contract monitoring. Continuous monitoring is no longer optional—it is essential. Organizations need to assess third-party risks not only at the start of a relationship but also as they evolve over time. This proactive approach is crucial in defending against the ever-changing threat landscape.

Proactively Identifying Risk

Proactively identifying and mitigating risks is essential for Government organizations, particularly as threat actors increasingly leverage publicly available data to plan their attacks. Transparency programs, such as USAspending.gov and city-level open checkbook platforms, while necessary for showing how public funds are used, can inadvertently provide a playbook for illicit actors to target vendors and suppliers involved in Government projects. Public data often becomes the first indicator of an impending breach, giving organizations a narrow window—sometimes just 24 hours—to understand threat actors’ operations and take proactive action.

To shift from reactive to proactive, organizations must enhance capabilities in three critical areas:

  1. Speed is vital for detecting threats in real time. Using AI to examine open source and threat intelligence data helps organizations avoid delays caused by time-consuming searches.
  2. The scope of monitoring must extend beyond traditional sources to deep web forums and dark web sites, evaluating text, images and indicators that mimic official branding.
  3. While real-time information is essential, excessive data can lead to alert fatigue. AI models that filter and tag relevant information enable security teams to focus on the most significant risks.

Proactively addressing third-party risks requires organizations to stay prepared for immediate threats. By leveraging public data, they can strengthen defenses and act before vulnerabilities are exploited.

While self-reporting and AI tools are valuable, organizations must take ownership of their risk management by conducting their own due diligence. The ability to continuously monitor, identify and mitigate risks presents not just a challenge but an opportunity for growth and improvement. Ultimately, it is the organization’s reputation and security at stake, making proactive risk management key to staying ahead of today’s evolving threats.

To learn more about proactive third-party risk management strategies, watch Dataminr’s webinar “A New Paradigm for Managing Third-Party Risk with OSINT and AI.”

Carahsoft Technology Corp. is The Trusted Government IT Solutions Provider, supporting Public Sector organizations across Federal, State and Local Government agencies and Education and Healthcare markets. As the Master Government Aggregator for our vendor partners, including Dataminr, we deliver solutions for Geospatial, Cybersecurity, MultiCloud, DevSecOps, Artificial Intelligence, Customer Experience and Engagement, Open Source and more. Working with resellers, systems integrators and consultants, our sales and marketing teams provide industry leading IT products, services and training through hundreds of contract vehicles. Explore the Carahsoft Blog to learn more about the latest trends in Government technology markets and solutions, as well as Carahsoft’s ecosystem of partner thought-leaders.

Rethinking and Modernizing the ATO Approval Process

The path to securing Authorization to Operate (ATO) approval presents a myriad of challenges, such as complex regulations, the potential for human error and the constant threat of cyberattacks. The role of an Authorized Official (AO) necessitates both speed and thoroughness to ensure an organization’s risk is minimized while also safeguarding sensitive information. Traditional manual, point-in-time assessments are proving insufficient, resulting in significant security risks. As digital transformation accelerates in both the Government and Private Sector, regulatory compliance requirements have also increased, yet the tools and processes used to meet these standards fall behind. This disconnect poses a challenge for AOs, underscoring the urgent need for innovation in the ATO approval journey.

Preventing Compliance Drift

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To stay ahead of the threats against the nation while simultaneously reducing the friction and corrosion in the compliance process, a proactive approach of implementing necessary measures and safeguards before they are mandated by regulatory requirements is essential. As Brandt Keller, Software Engineer at Defense Unicorns, stated during a recent webinar discussing the ATO approval process, “New technologies are coming, and we need to implement them and understand what they do, how they do it and what controls they do or do not satisfy.” The role of compliance within the DevSecOps process is pivotal, especially when switching from one technology to another. This decision must consider how the change impacts compliance, as the environment shift can alter the ATO posture. Such changes may result in drift or even expose the system to malicious actors seeking to escalate privileges or perform unauthorized actions. While compliance and security are often viewed as separate processes, they can and should be integrated to provide an additional layer of defense.

Preventing drift in IT systems is a crucial aspect of maintaining continuous compliance. AOs must actively collect and report data to accurately reflect the current state of their systems. Leveraging open standards on a platform is essential for effectively utilizing data. To achieve this, AOs need reliable methods for producing and regularly assessing data. Building a system from the ground up with compliance in mind involves meticulously implementing and automating controls that can be rerun consistently. The process must be both repeatable—able to redo tasks—and reproducible—able to collect evidence and achieve the same results. Any deviation indicates a potential issue, a change or an environmental modification that has made it less compliant. This approach allows AOs to confidently attest that their ATO meets all required controls and prevents any drift.

Implementing Automation

Automating processes within DevSecOps pipelines has emerged as a pivotal strategy, particularly streamlining compliance checks before system deployment. This approach allows decision-makers to assess risk before a system is even deployed. Moreover, the ability to continuously evaluate and update data in real time enhances accuracy and ensures timely access to critical information. However, accessibility of data remains a challenge due to the number of disconnected environments in existence. Open standards such as OSCAL solve this problem by providing a unified framework for continuous data integration. By adopting platforms that adhere to open standards, organizations can foster innovation and empower AOs with data in a familiar and actionable format, thereby optimizing efficiency and bolstering security measures.

ATO Risk Management Framework (RMF) artifacts represented in OSCAL machine-readable formats break down information silos, achieving effective communication across teams and facilitating seamless data handoffs. Automation is pivotal in expediting the decision-making process, alleviating the burden on the human workforce, enabling AOs to access better-quality data and making risk-based decisions more efficiently. While the potential for error is still present, automation significantly mitigates human error in data handoffs across all controls and systems. It also helps security professionals focus on managing risk rather than completing rudimentary compliance tasks.

Automating technical and administrative controls is not the same. While traditional approaches rely on application programming interface (API) data, nontraditional methods such as infrastructure as code (IaC)—managing computing infrastructure through provisioning scripts—or compliance as code—managing regulatory requirements by encoding them into automated scripts or code—offer alternative paths. These approaches allow organizations to establish rules and apply validations programmatically, mirroring the precision and speed of technical controls. However, not all controls are created equal; some function as checkboxes without mitigating risks. The critical controls that significantly impact an environment’s security posture should be the priority for automation. As emphasized by Travis Howerton, Co-founder and CEO at RegScale, “it is less important what percent of total controls are covered than what percentage of your total risk you are mitigating with automation.”

The cadence mismatch between cyber threats that move at lightspeed, and heavily manual compliance processes must be fixed. “The big part of what has to modernize,” according to Howerton, “is taking more automated approaches, leveraging advances in technology and thought leaders in this space to figure out how we can do things in a more automated manner to bring the principles of DevSecOps to compliance.” This strategic focus will ensure thorough and repeatable processes and prepare AOs for a future where compliance and security are dynamically intertwined, ultimately supporting better risk-based decisions and unlocking the full potential of digital transformation. By accepting early that ATOs should be more real-time and continuous, AOs can better position themselves for the future.

Watch RegScale and Carahsoft’s webinar, AO Perspectives: Managing Risks and Streamlining ATO Decision-Making, to learn more about modernizing the ATO approval process.