As a Third Party Assessment Organization (3PAO), Schellman has been performing FedRAMP security assessments for Cloud Service Providers (CSPs) since 2014. During this time, we have seen our CSP clients pioneer technologies that provide federal agencies an opportunity to leverage new and innovative cloud services, all while modernizing their approach to building, deploying, and managing applications through containerization. Though this gradual shift to containerizing system components has increased CSPs’ operational efficiency and scale, it has also introduced new security risks to FedRAMP systems.

Yesterday, on May 12th, President Biden issued the “Executive Order (EO) on Improving the Nation’s Cybersecurity.” Given that the Order features 11 sections that include both policy and general provisions among others, its 8,080 words is arguably the equivalent of multiple EOs. Such an effort is, no doubt, purposeful by the President—this is significant, and will certainly impact the security worlds of both the government itself and those companies that provide it with software and services.

Though Amazon’s Relational Database Services (RDS) can make hosting a database much easier, using them can also present new challenges, including some that crop up when you’re trying to scan against security benchmarks or meet compliance initiatives.

Though vulnerability scanning is only one of the control requirements in FedRAMP, it is actually one of the most frequent pitfalls in terms of impact to an authorization to operate (ATO), as FedRAMP requirements expect cloud service providers (CSPs) to have a mature vulnerability management program. A CSP needs to have the right people, processes and technologies in place, and must successfully demonstrate maturity for all three. CSPs that have an easier time with the vulnerability scanning requirements follow a similar approach, which can be best articulated by breaking down the expectations into three stages.

When two alpinists approach the same rock wall, they may both have the goal of reaching the summit, but the process they take to get there likely diverges greatly. Maybe one hikes up the backside while the other opts to climb the rock face directly—it likely depends on their individual skills, their gear, etc.

Many cloud service providers (CSPs) are not fully addressing the database scanning requirements for FedRAMP and have questions related to database security and FedRAMP. This article details the issues associated with not meeting the database scanning requirement, the most common reasons why this occurs, what can be done to improve this and what to consider with database security beyond scanning.

Overview In the last 30 days, the FedRAMP Program Management Office (PMO) has published guidance for both vulnerability scanning and penetration testing. The updated guidance comes on the heels of PCI mandating the enhanced penetration testing requirements within its requirement 11.3 as part of the 3.0, now 3.1, version of the DSS. These augmented PCI requirements, introduced in the fall of 2013, took effect on June 30th. For many cloud service providers this means the requirements for vulnerability scanning and penetration testing are more thorough and will require additional resources for planning, executing and remediating findings. This article will walk through the updates and discuss the differentiation between FedRAMP and the PCI Data Security Standard (DSS).

I am delighted that Schellman is now an accredited FedRAMP 3rd Party Assessment Organization (3PAO). This is a testament to our extensive experience in the cloud service provider (CSP) space and the qualifications and experience of a licensed CPA firm, PCI QSA company, and ISO 27001 certification body.