Get FedRAMP without a sponsor! 

Ensure Compliance with a FedRAMP-Authorized Solution For CMMC SSP Solution

We’re Fedramp High Ready!

Blog
/
Article

Unpacking the FedRAMP Rev 5 SI-4 (18) Updates: Steganography and Covert Channels

FedRAMP Rev 5, particularly the update to SI-4 (18), emphasizes data exfiltration monitoring, focusing on covert channels like steganography. Kenny and Christian explore steganography's significance within the latest FedRAMP guidelines, reflecting th

Kenny Scott
|
53
min read

In This Article

FedRAMP 20x Process

Staying ahead of new threats like steganography can feel overwhelming, especially with FedRAMP Rev 5’s updated SI-4 (18) requirements.

Paramify’s expertise simplifies the process, helping you understand what covert channels to monitor and how to implement the right defenses. In this post, we’ll break it down and guide you toward effective compliance.

‍

Understanding Steganography

‍

‍

Steganography is the intricate method of concealing data within another dataset. In a tangible analogy, consider a regular shipping facility dispatching boxes daily. Using the steganography technique, one could covertly place an item inside an everyday box, ensuring it gets transported without drawing attention. The recipient, in the know, can then retrieve the hidden item from the box.

Digitally, steganography might involve embedding classified information within ordinary files like images or audio tracks. To the untrained eye (or system), this data seems like regular traffic, but to an informed receiver, the concealed data can be discreetly extracted.

Implications for FedRAMP Rev 5 SI-4 (18) Updates

With the inclusion of covert channel monitoring in the recent FedRAMP update, there's a spotlight on sophisticated data-smuggling methods like steganography. However, the nuances and specifics of this requirement have raised questions. If the main covert channel under scrutiny isn't steganography, which other methods demand attention?

This ambiguity emphasizes the need for clarity and precision. Given the covert channel's potential risks, it's vital for organizations to pinpoint what exactly they need to monitor. This understanding ensures the development and implementation of the most effective protective countermeasures.

Striking the Right Balance

In deciphering the FedRAMP's latest directives, experts find themselves at a crossroads. One path leans towards rigorous steganography monitoring due to its stealthy nature. The other suggests that while steganography is significant, there might be other covert channels also worthy of attention.

This dichotomy necessitates a balanced approach—combining vigilance for well-known methods like steganography with alertness for upcoming techniques.

Conclusion

The latest update in The FedRAMP Rev 5 SI-4 (18) is a testament to the ever-evolving challenges in cybersecurity. As threats grow in complexity, staying abreast of and adapting to guidelines like those around steganography becomes crucial. For organizations, the mantra remains clear: stay informed, stay adaptable, and above all, stay vigilant.

Kenny Scott
Kenny is an accomplished leader with a two decade tenure in Information Security and IT Audit. He's widely acknowledged in the industry and has a profound dedication to it. In addition to his technical expertise, Kenny's portfolio includes substantial experience in business strategy, investment, and programming. On the personal side, Kenny is a devoted husband to Angie Scott and a proud father of five. A music enthusiast, he relishes playing the guitar and enjoys surfing when a beach is within reach.
Jun 2023
Related posts

Paramify blog

Interviews, tips, guides, industry best practices, and news.

Don’t Overspend on Your Gap Assessment: 4 Common Mistakes to Avoid

A gap assessment identifies security gaps between your current state and compliance goals like FedRAMP or CMMC. Paramify’s 45-60 minute process delivers a dashboard to guide implementation, track progress, and automate documentation.
Read post

Top FedRAMP 3PAO Assessors to Use With Paramify

Find the best audit partner for your FedRAMP authorization with this list of the top 8 3PAO assessors, perfectly paired with Paramify to accelerate your compliance journey and save time and costs.
Read post

What are FedRAMP POA&Ms? Plan of Actions and Milestones Explained

POAM (Plan of Actions and Milestones) are vital for risk management and cybersecurity. It's a strategic roadmap for identifying, tracking, and resolving vulnerabilities and non-compliance, ensuring organizations maintain security and compliance.
Read post
View all posts
Once authorized, can I sell to any federal agency?

Yes — authorization can be reused by multiple agencies via the FedRAMP Marketplace, but some agencies may request additional requirements.

How is FedRAMP 20x different from traditional FedRAMP?

20x introduces automation, key security indicators (KSIs), continuous monitoring validation, and streamlined authorization (sometimes without sponsor requirements).

→ Compare KSIs to Rev 5 controls

What are the most common reasons for delays or failures in FedRAMP authorization?

Incomplete documentation, insufficient evidence, failing initial gap assessments, lack of executive support, and underestimating resource requirements.

→ How to create the most accurate documentation for audit success

What's the difference between FedRAMP and other frameworks (SOC 2, CMMC, ISO 27001)?

FedRAMP is U.S. government-specific and NIST-based, more prescriptive and granular than commercial standards.

How do inherited controls from my cloud infrastructure provider (e.g., AWS, Azure, GCP) work?

FedRAMP allows CSPs to “inherit” controls from IaaS providers; you must document and verify this inheritance with shared responsibility models.

What kind of technical controls are required under FedRAMP?

Controls follow NIST SP 800-53 Rev 5 (with additional FedRAMP overlays) — covering access control, incident response, risk assessment, configuration management, etc.

→ Get your custom accelerated FedRAMP implementation roadmap

How often do I need to update and submit security documentation?

At minimum: 

  • Monthly POAMs and vulnerability scans
  • Annual security assessments
  • Ad hoc submissions for significant changes.

‍

What is a POA&M?

Plan of Action and Milestones: a document tracking remediation plans for open vulnerabilities, findings, and compliance issues.

→ Learn more about POAMs

What is continuous monitoring (ConMon) and why is it important?

ConMon involves ongoing assessments, vulnerability scanning, reporting POAMs, and keeping security posture current post-authorization.

What documentation is required for FedRAMP?

Major deliverables include a System Security Plan (SSP), Security Assessment Plan (SAP), Security Assessment Report (SAR), Plan of Actions and Milestones (POA&M), Continuous Monitoring (ConMon) documentation, policies/procedures, and more.

Do I need an agency sponsor?

Yes, for now. But, agency sponsorship requirements are evolving — FedRAMP 20x does not require a sponsor.

How do I pick the best 3PAO for my project?

Consider experience with similar environments, references, price, and knowledge of specific cloud implementations.

→ Find the best assessor for your CSP with these tips

What is a 3PAO?

A Third Party Assessment Organization is an accredited independent assessor that conducts key security testing and assessment for FedRAMP. 

→ Find a recommended 3PAO

How much does FedRAMP Authorization cost?
  • Initial costs range from ~$150k to $3M+ for gap assessments, remediation, 3PAO audits, and documentation/reporting. 
  • Annual costs can range from $50k to $1m to maintain documentation, do continuous monitoring, and resource allocation. 

→ Learn more about what FedRAMP could cost your organization and whether or not it’s worth the effort

How long does it take to achieve FedRAMP Authorization?

Typical processes take 6–24 months. Paramify accelerates the process to take between 1-10 months with a fully prepared package in less than a month. 

Your timeline will vary depending on your impact level, whether you take a manual or automated approach to implementation & documentation, and PMO wait times.

→ Learn about the FedRAMP Authorization process and what it costs.

What’s the difference between FedRAMP Ready, FedRAMP In Process, and FedRAMP Authorized?
  • Ready: Preliminary review for capability and documentation.
  • In Process: CSP is actively working toward authorization, usually with an agency sponsor or as part of the JAB program.‍
  • Authorized: Successfully completed security assessment and continuous monitoring.
What are the different impact levels for FedRAMP?

Low, Moderate, and High — based on the type and sensitivity of federal data hosted (FIPS 199 categories: confidentiality, integrity, availability).

→ Get the details on impact level to know which impact level is right for you.

Do You Need FedRAMP?

Any cloud service provider (CSP) that wants to sell cloud products or services to U.S. federal agencies must be FedRAMP authorized.

→ Learn more to find out if FedRAMP is a good choice for your cloud-based business.

What is FedRAMP

FedRAMP stands for the Federal Risk and Authorization Management Program; it standardizes the security assessment, authorization, and continuous monitoring for cloud products and services used by U.S. federal agencies.

How long will it take to generate my SSP?

If you’re new to FedRAMP: The time required depends on how long it takes to implement your security controls. With Paramify’s living gap assessment dashboard, you can build your compliance roadmap and generate documents instantly with one click.

If you’re already FedRAMP authorized: It can take as little as 3.5 hours or up to a week.

‍

Can you help me transition from NIST 800-53 Rev 4 to Rev 5?

Yes! No one will help you transition to FedRAMP Rev 5 as affordably and painlessly as Paramify. Learn how you can make a seamless, inexpensive transition to Rev 5.

Can I use my existing SSP?

Yes, we offer this service and have provided it for many clients. Most of our customers, including those for whom we’ve ingested their SSP, have found that starting from scratch and adopting the full power of Risk Solutions was the better option.

‍