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The NIST Risk Management Framework: Problems and recommendations
Cyber Security: A Peer-Reviewed Journal,
1
(3),
207-217
(2017)
Abstract
Cyber security assessment initiatives and frameworks abound in the US government, but their effectiveness is inconsistent. The most important law from which these frameworks and assessments arose is the Federal Information Systems Management Act (FISMA), passed in 2002, and updated as the Federal Information Systems Modernization Act in 2014. The law’s broad scope included a mandate to the US National Institute of Standards and Technology (NIST), charging it to create methods and standards to assess and optimise the cyber security posture of US government agencies. NIST’s flagship methodology, Risk Management Framework (RMF), is comprehensive and fundamentally sound, but years of experience have exposed many flaws — some stemming from lack of proper adoption and execution, some from unintended consequences, and others arising from the relentless pace of innovation in technology. This paper examines the RMF’s weaknesses, and offers recommendations for improvement.
Keywords: National Institute of Science and Technology; Risk Management Framework; Plan of Action and Milestones; Federal Information Systems Management Act; risk assessment; Authority to Operate
The full article is available to subscribers to the journal.
Author's Biography
Don Maclean is Chief Cyber Security Technologist for DLT and formulates and executes cyber security portfolio strategy, speaks and writes on security topics, and socialises his company’s cyber security portfolio. He has nearly 30 years’ experience working with US federal agencies. Before joining DLT in 2015, he managed security programmes for numerous US federal clients, including DOJ, DOL, FAA, FBI and the Treasury Department. This experience allowed him to work closely with the NIST Risk Management Framework featured in this paper, and to understand its strengths and weaknesses. In addition to CISSP, PMP, CEH and CCSK certificates, he holds a BA in music from Oberlin College and Conservatory, an MS in information security from Brandeis Rabb School, and is nearing completion of his second Bachelor’s in mathematics. An avid musician, he organises a concert for charity every year, and has been known to compete in chess and Shogi (Japanese chess) tournaments, both in person and online.
