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CMMC Certification for Organizations Using Open-Source Software

by Continuum GRC 0 Comment
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CMMC is a cornerstone of cybersecurity compliance for Defense Industrial Base organizations. With the increasing use of open-source software, aligning open-source practices with CMMC standards is a growing challenge. OSS offers flexibility, cost-efficiency, and innovation but also introduces unique risks that must be mitigated to achieve and maintain CMMC certification.

This article explores the viability of open-source software and CMMC, providing advanced insights and strategies to align OSS practices with the stringent requirements of this certification framework.

What Is Open Source Software?

Open Source software (OSS) refers to software that is distributed with its source code made available to the public. This allows anyone to view, modify, and distribute the code. OSS is developed and maintained collaboratively, often by a community of developers, and is governed by licenses that promote transparency and sharing.

 

Key Characteristics of Open Source Software

  1. Access to Source Code: The source code is openly shared, enabling users to study how the software works. Depending on the license, this code is redistributable or changeable to use in forked projects.
  2. Community Collaboration: Development is often a community effort involving contributions from developers worldwide. This leads to the idea that “with enough eyes, all bugs are shallow.”
  3. Distribution Freedom: OSS can be freely distributed, with some licenses allowing derivative works to be distributed under the same terms (e.g., copyleft licenses like the GNU General Public License).
  4. Cost Efficiency: Many OSS projects are free to use, making them cost-effective alternatives to proprietary software.

Some common open-source solutions you might find used by enterprises include:

  • Apache is a widely used open-source web server software developed and maintained by the Apache Software Foundation (ASF). Officially known as the Apache HTTP Server, it is one of the most popular web servers in the world, powering a significant percentage of websites and applications globally.
  • Kubernetes (often abbreviated as K8s) is an open-source platform designed to automate containerized applications’ deployment, scaling, and management. Google originally developed it, and is now maintained by the Cloud Native Computing Foundation (CNCF).
  • Linux is a family of open-source, Unix-like operating systems based on the Linux kernel, created by Linus Torvalds in 1991. It is known for its flexibility, security, and widespread use across various computing environments, from servers and desktops to embedded systems and mobile devices.
  • Git is a distributed version control system initially developed by Linus Torvalds in 2005 to manage the development of the Linux kernel. Git is released under the GNU General Public License v2 (GPLv2), allowing anyone to use, modify, and distribute the software.

These are just a few of hundreds of enterprise open-source projects covering communication, ERP management, security, and other operational aspects of IT systems–all of which could fall under CMMC assessment. 

Open-Source Software and Mapping to CMMC Practices 

open-source software CMMC

Many CMMC practices directly relate to OSS management. Below are some alignments and how to address them:

  • Access Control (AC): Restrict access to OSS repositories using Role-Based Access Control and multi-factor authentication. Implement network segmentation to isolate OSS environments handling sensitive data.
  • Media Protection (MP): Encrypt OSS distributions during storage and transfer to prevent tampering. Verify the integrity of OSS components using hash-based verification tools.
  • Audit and Accountability (AU): Log all OSS repositories and changes in dependencies. Use tools like Splunk or Elastic Stack to monitor OSS centralized activities.
  • Configuration Management (CM): Employ secure configuration management tools such as Ansible, Puppet, or Chef to automate and enforce baseline settings for OSS components.
  • Incident Response (IR): Develop a response plan addressing OSS-specific vulnerabilities, including rapid patch deployment and dependency replacement.

     

    The Challenges of Using Open-Source Software in CMMC Compliance 

    CMMC establishes strict requirements to protect CUI. While open-source software offers innovation and cost savings, its use introduces several challenges that must be addressed to meet CMMC compliance requirements.

    • Complex Dependency Trees: OSS often relies on multiple nested dependencies, increasing the risk of supply chain vulnerabilities–a problem that arises in shared libraries or tools, like the Log4Shell vulnerability. Supply chain integrity is critical under CMMC’s Risk Management and Configuration Management domains.
    • Unpatched Vulnerabilities: Many OSS projects lack consistent patching, leaving organizations exposed. Additionally, many OSS updates often require manual intervention, leading to delays. Timely remediation is required under the System and Communications Protection and System and Information Integrity domains.
    • Inadequate Security Testing: OSS may not undergo rigorous security assessments.
      CMMC’s Risk Management practices mandate continuous evaluation of security risks.
    • Unverified IP Ownership: OSS may include code with unclear intellectual property rights. Improper use of OSS could result in non-compliance with contractual and legal obligations.
    • No Vendor Support: OSS lacks centralized support for security updates or compliance needs. Incident Response domains require timely response capabilities, which may be lacking in OSS.
    • Integration Issues: OSS may need to integrate more easily with enterprise SIEM tools for monitoring. Continuous monitoring is a cornerstone of CMMC compliance.
    • Lack of Formal Documentation: Many OSS projects must provide detailed compliance documentation. Documentation and Reporting are critical to passing CMMC audits.
    • Limited Budget for Audits: Smaller organizations may need more resources to assess OSS thoroughly. Proper auditing and risk assessments are mandatory under CMMC.
    • Forked or Abandoned Projects: Forked or abandoned OSS may stop receiving updates and support. Using unsupported software violates CMMC’s requirement to maintain updated and secure systems.

     

    Addressing OSS Challenges in the Context of CMMC

    To align OSS usage with CMMC compliance, organizations must adopt a structured approach, integrating technical, procedural, and policy measures:

     

    Risk Management

    • Use tools like Snyk, or Sonatype Nexus to monitor OSS components for known vulnerabilities.
    • Ensure a patch management process for OSS, using CVE databases and tools like OWASP Dependency-Check to identify and address risks.
    • Analyze the role of OSS in handling CUI and assess associated risks.

    Secure Development Practices

    • Regularly audit OSS versions, ensuring they meet security benchmarks and align with CMMC controls.
    • Tools like SonarQube, Checkmarx, and Fortify can perform static analysis to identify vulnerabilities in OSS components.
    • Integrate secure coding and compliance principles into the development pipeline for any internal modifications of OSS.

    Open-Source Governance

    • Define a governance policy outlining permissible OSS usage, vetting processes, and maintenance standards.
    • The National Telecommunications and Information Administration (NTIA) recommends maintaining a software bill of materials to track OSS components. Tools like CycloneDX or SPDX formats can streamline this process.
    • Evaluate OSS licenses to ensure they do not conflict with contractual obligations or compliance requirements.

     

    Align Open-Source Software with Compliance Standards with Continuum GRC

    Continuum GRC is a cloud platform that stays ahead of the curve, including support for all certifications (along with our sister company and assessors, Lazarus Alliance). 

    We are the only FedRAMP and StateRAMP-authorized compliance and risk management solution worldwide.

    Continuum GRC is a proactive cyber security® and the only FedRAMP and StateRAMP-authorized cybersecurity audit platform worldwide. Call 1-888-896-6207 to discuss your organization’s cybersecurity needs and learn how we can help protect its systems and ensure compliance.

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