Updated 29 April 2024
Cloud Service Providers (CSPs) new to FedRAMP immediately stumble into one of FedRAMP’s most perplexing challenges: How to properly define an authorization boundary.
Boundary definition is always tricky. It’s especially complicated when it comes to development environments. Security measures in dev environments obviously impact production security posture. But applying all the FedRAMP controls to dev complicates life for modern development teams.
In part one of this two post series, we’re going to discuss how to build and maintain a FedRAMP-friendly development environment.
Yes, You Need a Dev Environment
Let’s get this out of the way early on: we’ve seen CSPs that want to die on the “don’t-need-a-dev-environment” hill. Which is exactly what their FedRAMP hopes and dreams will do without a dedicated development environment.
Can I point to any single control in the FedRAMP baseline or NIST 800-53a that states “thou-shalt-separate-dev-and-prod”? No.
But, from patch testing requirements in SI-2, to the entire Configuration Management family and even extending to elements of Access Control, there are numerous FedRAMP controls that you won’t realistically pass without a dedicated development environment.
So yes, you will need to separate dev and prod if you want to earn FedRAMP-authorization, at any level.
A Modern Approach to Dev Security
However, this does not mean that you need to bring dev within the system boundary and apply all the FedRAMP security controls. Per the current FedRAMP boundary guidance “Development environments that do not process, store, or transmit federal information” may be excluded from the authorization boundary, at the Authorizing Official (AO)’s discretion.
In practice, this conditionally frees development environments to adopt processes and tooling that would be difficult in-boundary. Love Agile development? No problem. Operate a slick CI/CD pipeline process? You do you (though, we’ll talk about the CD part in a sec). Wedded to a bunch of nifty DevOps tools? We can probably make it work.
Building a FedRAMP Friendly Dev Environment
But dev can’t be a free-for-all. There are two major caveats to the FedRAMP boundary guidance that can drag a dev environment back into scope.
Just Say No (to Fed Data)
Unless you want a one way ticket to boundaryville, dev environments can’t process, store or transmit federal information. At first glance this looks easy: don’t use live system data from federal customers in dev. Done.
Right?
Not quite. In FedRAMP world, the term “federal information” is pretty broad. It includes not just federal data directly owned by fed customers, but also system metadata. Hostnames, ticketing info, custom configs, security documentation, vulnerabilities and a whole slew of other system-related data can all count as federal information.
You can probably start to see how this complicates things.
AO God Mode
Agency AOs get to decide if dev will be excluded from the boundary. Your AO having a bad day? Dev is in.
So if you want to keep dev out, you’re going to need to show a lot of security maturity around development processes. This will be especially true after the Biden administration’s Executive Order on Cybersecurity, which encourages enhanced scrutiny of software development processes.
So you’re going to need to bring your A game to dev security if you want to keep your AO happy.
What To Do
Here at 38North, we separate our guidance into required minimums and best practices. Required minimums will likely get you past an audit, while best practices will showcase maturity and fast track your authorization.
You Gotta Get Down to Get Out
These are the bare minimum requirements your dev environment needs to meet if you don’t want it dragged back into the boundary.
CD-Light
In the post NotPetya/SolarWinds/Etc. era, controls surrounding the push from dev-to-prod are getting intense scrutiny. This does put somewhat of a damper on fully-automated continuous deployment models. You will need to prove to an auditor that push to prod is strictly controlled, and can’t be hijacked by a malicious user. This gets complicated fast, but one of 38North’s specialties is helping CI/CD processes stay compliant with FedRAMP. So contact us to chat more about this unique challenge.
No Live System Data
You will not be able to use actual data from prod in your dev and test environments. This includes customer data, but also things like server hostnames, unique configurations and client identifiers of any kind. Your development environment will need to be genericized and not easily mappable to the production environment.
No Custom Configs in Dev
The hardest part of the no live system data rule is that some CSPs use test environments that simulate OSs and infrastructure in production. No problem. However, if you’re applying custom configurations to that infrastructure to meet federal requirements, those will need to be applied in a staging environment that’s within the boundary. These configurations are sometimes considered federal information, and can drag a development environment in scope.
No Vulnerability Ticketing
This is a tricky one. You need your developers to fix security issues discovered in your production code. But you won’t be able to document this in an out-of-boundary ticketing system.
As an example, you won’t be able to write a ticket outside of the boundary to the effect of “application testing shows that we’re totally hosed because of a stored XSS vulnerability in our latest release, version 3.2.” Instead, this level of detail needs to be tracked in-boundary, with only a genericized feature / fix request, handled in whatever development workflow tracks bug fixes. Or you can have a specialized team of developers with access to the boundary who handle these issues.
Tight Control Over Open Source
CSPs new to the US government often think that open source software is a no-go. False. Use of open source software isn’t only permitted, it’s often embraced as a best practice. But that doesn’t mean you can just go to Github, grab random code and slap it into production without a second thought. You’ll need to prove to auditors that you have a controlled process, one that draws from established open source communities, considers and respects licenses, and tests and scans all code prior to integration. Additionally, you’re going to need to show understanding of all libraries and dependencies used by your code, and any security issues hiding there.
Static and Dynamic Scanning
Both static and dynamic scans will need to be conducted. It’s a hard requirement, enshrined in the Systems and Services Acquisition (SA) control family. You have leeway to select tools – though tools will be scrutinized to ensure that they provide full code coverage – but you will need to consistently scan all code prior to release.
Integrity Verification / Code Signing
Code integrity will need to be validated before and after it is pushed to the system boundary. There are a number of ways to do this, from manual file hashing and verification, to code signing, to fully automated solutions that seamlessly operate across the build process. But regardless of which path you take, you will need to prove to an auditor and to AOs that you have a firm handle on software integrity, with a technical method for non-repudiation.
Best Practices
Satisfying the bare minimums above will likely keep your development environment out of the FedRAMP authorization boundary. In part 2, we’ll discuss additional best practices that will demonstrate maturity and help future proof your development environment against evolving security requirements.
Contact Us
Contact 38North to learn more about how you can secure and manage your development environment in a way that maximizing FedRAMP success.
Frequently Asked Questions:
1. How do Agency Authorizing Officials (AOs) assess the security maturity of a CSP’s development processes to determine whether the dev environment should be included in the authorization boundary?
Assessing the security maturity of a CSP’s development processes involves several key factors for Agency Authorizing Officials (AOs). Here’s how they might go about it:
- Documentation Review: AOs may request documentation outlining the CSP’s development processes, including policies, procedures, and controls in place for secure development. They would look for evidence of adherence to industry standards and best practices such as NIST guidelines.
- Security Controls Implementation: AOs would assess how well the CSP implements security controls within their development environment. This could involve examining the extent to which security measures are integrated into the development lifecycle, such as secure coding practices, vulnerability assessments, and regular security testing.
- Incident Response Preparedness: AOs may inquire about the CSP’s incident response capabilities specific to the development environment. This includes how the CSP detects, responds to, and mitigates security incidents during the development process.
- Training and Awareness Programs: AOs might evaluate the CSP’s training and awareness programs related to secure development practices. They would assess whether developers receive adequate training on security protocols and are aware of their responsibilities in maintaining the security of the development environment.
- Compliance with Standards and Regulations: AOs would verify that the CSP’s development processes align with relevant standards and regulations, such as FedRAMP requirements, NIST guidelines, and any other applicable industry-specific regulations.
- Continuous Improvement Practices: AOs may look for evidence of continuous improvement initiatives within the CSP’s development processes. This could include mechanisms for feedback, lessons learned from security incidents, and efforts to adapt to evolving threats and vulnerabilities.
Overall, AOs seek assurance that the CSP demonstrates a high level of security maturity in their development processes, which helps determine whether the development environment should be included in the authorization boundary.
2. Can you provide examples of specific types of system-related data that could inadvertently classify a development environment as processing, storing, or transmitting federal information, thereby impacting its exclusion from the authorization boundary?
Certainly, here are some examples of system-related data that could inadvertently classify a development environment as processing, storing, or transmitting federal information, potentially impacting its exclusion from the authorization boundary:
- Hostnames and Domain Information: Information related to the hostnames, domain names, or network configurations of federal systems could inadvertently classify a development environment. This includes details about servers, domains, subdomains, and network infrastructure.
- Ticketing Information: Any ticketing systems used to track issues, incidents, or tasks related to federal systems could contain federal information. This includes tickets for software bugs, security vulnerabilities, or system maintenance tasks.
- Custom Configurations: Custom configurations applied to the development environment to simulate federal system requirements may inadvertently classify it as processing federal information. This could include specific settings, configurations, or parameters tailored to match federal system requirements.
- Security Documentation: Documentation related to security policies, procedures, or configurations specific to federal systems could inadvertently classify the development environment. This includes security plans, risk assessments, security controls documentation, and security architecture diagrams.
- Vulnerability Information: Information about vulnerabilities, security assessments, or penetration testing results related to federal systems could inadvertently classify the development environment. This includes vulnerability scans, assessment reports, and remediation plans for federal system vulnerabilities.
- Data Metadata: Metadata associated with federal data, such as data classifications, sensitivity levels, or access controls, could inadvertently classify the development environment. This includes metadata tags, labels, or attributes used to classify and manage federal data.
- Client Identifiers: Any client identifiers or unique identifiers associated with federal systems, users, or entities could inadvertently classify the development environment. This includes user IDs, client keys, authentication tokens, or other identifiers used to access federal systems or data.
- Audit Logs and Monitoring Data: Audit logs, monitoring data, or security event records generated by federal systems could inadvertently classify the development environment. This includes logs of system activities, access attempts, security events, and audit trails related to federal data or systems.
These examples highlight the broad range of system-related data that could inadvertently classify a development environment as processing, storing, or transmitting federal information, potentially impacting its exclusion from the authorization boundary.
3. While the article outlines minimum requirements for dev environments to stay out of the FedRAMP authorization boundary, what are some examples of additional best practices that demonstrate maturity and could potentially fast track the authorization process?
Certainly! Here are some examples of additional best practices beyond the minimum requirements outlined in the article that demonstrate maturity and could potentially fast track the FedRAMP authorization process:
- Automated Compliance Monitoring: Implement automated tools and processes for continuous monitoring and compliance validation of the development environment. This includes automated scanning for security vulnerabilities, configuration drift detection, and real-time monitoring of security controls.
- Secure DevOps Integration: Integrate security practices into the DevOps pipeline to ensure that security is embedded throughout the software development lifecycle. This includes automated security testing, code analysis, and vulnerability scanning as part of the CI/CD pipeline.
- Immutable Infrastructure: Adopt immutable infrastructure principles to ensure consistency and reproducibility of the development environment. This involves treating infrastructure components as disposable and using automation to create and deploy consistent environments.
- Containerization and Microservices: Utilize containerization and microservices architecture to enhance agility, scalability, and security of the development environment. This allows for isolation of components, easier management of dependencies, and rapid deployment of updates.
- Zero Trust Networking: Implement a zero trust networking model to minimize the attack surface and enhance security posture within the development environment. This includes strict access controls, micro-segmentation, and continuous authentication and authorization mechanisms.
- Threat Modeling and Risk Assessment: Conduct regular threat modeling exercises and risk assessments to identify and mitigate potential security risks within the development environment. This involves analyzing potential threats, vulnerabilities, and impacts to prioritize security measures.
- Secure Supply Chain Management: Establish secure supply chain management practices to ensure the integrity and security of third-party components and dependencies used within the development environment. This includes vetting vendors, monitoring for supply chain attacks, and implementing secure update mechanisms.
- Continuous Security Training and Awareness: Provide ongoing security training and awareness programs for developers and personnel involved in the development process. This helps ensure that all stakeholders understand their security responsibilities and are equipped to mitigate security risks effectively.
- Security Incident Response Preparedness: Develop and regularly test incident response plans specific to the development environment to ensure timely detection, response, and recovery from security incidents. This includes defining roles and responsibilities, establishing communication channels, and conducting tabletop exercises.
- Engagement with FedRAMP Liaisons: Proactively engage with FedRAMP liaisons and stakeholders to stay informed about evolving requirements, best practices, and compliance guidelines. This demonstrates a commitment to continuous improvement and collaboration with regulatory authorities.
By implementing these additional best practices, cloud service providers can demonstrate a higher level of security maturity and readiness for FedRAMP authorization, potentially expediting the authorization process.
