Last month I wrote about using a Software Bill of Material (SBOM) as a valuable tool for managing cybersecurity risk. This month I am expanding that conversation from cybersecurity risk to legal trouble. An SBOM can strengthen an organization's compliance capabilities with import and export controls regulated by the Office of Foreign Assets Control (OFAC) by providing visibility and documentation of software components that may be subject to OFAC regulations.
OFAC's sanctions and embargoes on specific countries, encompassing individuals, organizations, and companies engaged in prohibited activities, can pose significant challenges for businesses involved in global trade. However, with the assistance of an SBOM, organizations gain a powerful tool to identify software components originating from or containing code developed by restricted entities. In addition, this proactive approach identifies any connections to blocked entities, ensuring steadfast compliance with OFAC regulations.
In today's software landscape, dependencies on third-party libraries, frameworks, or modules are commonplace. However, ensuring compliance with OFAC restrictions and laws can be complex. In addition, OFAC regulations and Entity List designations can evolve. An SBOM provides a framework for continuously monitoring and updating software components regarding compliance with import and export controls. Customers can regularly review and update their SBOM to track any changes to OFAC regulations or Entity List designations that may impact the compliance status of their software.
Meeting the requirements of OFAC regulations necessitates meticulous record-keeping and documentation of compliance efforts. With an SBOM, organizations can maintain a comprehensive record of their software components and origins. In addition, this powerful resource enables customers to showcase their due diligence in adhering to OFAC regulations by providing well-documented evidence of the assessment and management of software components subject to import and export controls.
SBOMs facilitate efficient monitoring and tracking of software changes and updates, making it easier to identify and address any non-compliant software elements in a timely manner. Furthermore, by maintaining an up-to-date SBOM, organizations can demonstrate due diligence and easily respond to audit requests, streamlining compliance and reducing the risk of penalties or reputational damage. Overall, leveraging an SBOM for OFAC compliance provides organizations with the tools to proactively manage software-related risks and maintain a robust and compliant software ecosystem.
March 19, 2024
Tern is an open source software composition analysis and SBOM generation tool that generates SBOMs from container images. However, upon running this tool and generating a CycloneDX SBOM, a problem arose.
Read More →March 4, 2024
As a member of the PCAST Working Group on Cyber-Physical Resilience, I was involved in crafting the recent report outlining crucial steps to fortify the intricate systems that underpin our daily lives. One of our key recommendations, "Recommendation 4B: Promote Supply Chain
Read More →December 15, 2023
Notably, the Health Information Sharing and Analysis Center (Health-ISAC) is entering into a partnership with Cybeats, a leading software supply chain intelligence company, marking a substantial advancement in healthcare cybersecurity.
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