Rethinking the Role of Compliance

The National Cybersecurity Strategy Implementation Plan

“The Biden-Harris Administration’s recently released National Cybersecurity Strategy calls for two fundamental shifts in how the United States allocates roles, responsibilities, and resources in cyberspace”

The newly released National Cybersecurity Strategy Implementation Plan signifies an unprecedented step towards fortifying the United States’ critical infrastructure protection and bolstering national security. This ambitious effort, while necessary, presents us with a significant challenge: How do we accurately capture the current risk posture across all the enterprise environments comprising the sixteen critical infrastructure sectors, which is an essential first step towards achieving enhanced security maturity?

Interestingly, we don’t need to reinvent the wheel. We already have robust models designed to measure and improve the security and risk posture of diverse environments at our disposal: security standards, frameworks, mandates, and operating directives. However, traditionally, these resources have been employed as lagging indicators, relegated to historical reporting rather than proactive risk management. Inherited from the fields of accounting and financial audit, cybersecurity compliance has unfortunately maintained the same retrospective focus, ignoring the radically different nature of cyberspace and the need for cyber risk management practices to match the dynamic pace of our threat environment.

Fortunately, private and public sector leaders are beginning to recognize this longstanding shortcoming and the implications of limiting our risk visibility to a historical view. As reflected in the National Cybersecurity Strategy Implementation Plan, the need to attain comprehensive, credible, evidence-based awareness of risk, threat, and defensive posture maturity across all critical infrastructure environments can no longer be treated as an optional requirement.

Ensuring real-time visibility is not without challenges, of course. Transitioning from historical reporting into real-time, continuous monitoring requires vision and strategy at organizational, enterprise, sector, and national levels. Existing compliance management investments can offer a springboard for the necessary transformation.

Imagine a scenario where all the broad-based and industry-specific comprehensive, well-crafted frameworks and standards are leveraged to manage risk in real-time. The perceived ‘costs’ of compliance could be reframed as strategic investments that offer real-time risk visibility.

How do we make this leap? Automation is key. End-to-end compliance automation can enhance internal visibility within enterprises. Simultaneously, data sharing automation can foster synergy and active private-private and public-private engagement.

The primary objective of the Implementation Plan is to bolster resilience and sustain, and hopefully enhance, trust in our core societal institutions, which form the bedrock of our digital economy. Despite this, the primary mechanisms for ensuring trust – compliance and audit – have largely relied on subjective assessments rather than objective evidence. Automation, therefore, is not merely a signpost of “organizational maturity” or a ticked box that shows we are “doing something” about security and risk. It represents a strategic move towards reducing our reliance on imperfect, slow, and unreliable human analysis, pushing us towards a future of evidence-based risk management at every scale: individual enterprises, critical infrastructure domains, and the nation at large.

The National Cybersecurity Strategy’s Implementation Plan offers us the tools and direction to transform our understanding of compliance from a historical reporting function to a powerful tool for managing risk in real-time. The challenge is significant, but so are the rewards: enhanced resilience, increased trust, and a more secure future for our nation’s critical infrastructure.

How Qmulos Adds Value

As we delve into the components of the Implementation Plan, it’s intriguing to recognize the underlying philosophy that is remarkably consistent with the strategic vision that has driven the Qmulos mission of revolutionizing enterprise compliance and risk management. In particular, three emergent themes mirror our long-held beliefs: understanding risk through comprehensive standards, collaboration through convergence, and automation as a transformative force.

Understanding the vast and complex digital ecosystem we operate within is a central tenet of the Plan. This sentiment strongly echoes our conviction in leveraging the detailed structures of compliance standards and frameworks to gain deep insights into an organization’s cybersecurity posture. It is through this informed perspective that we can shift from a reactive stance to proactively managing risk.

The Plan advocates for a shift from competition to collaboration, emphasizing the potential of private-private and private-public co-investment strategies. This correlates with our belief that risk management should not be seen as an isolated task, but as a shared responsibility. Viewing compliance as a strategic investment rather than a burdensome cost, aligns with this call for collaboration and shared understanding.

The third element, automation, is where the profound alignment occurs. The Plan envisions a future of comprehensive automation, reflecting our longstanding emphasis on technology’s potential to transform compliance from a historical reporting chore to an invaluable function for real-time risk management. The goal is to transition from subjective, slow, and unreliable human analysis towards objective, real-time, evidence-based risk management.

The spirit of the National Cybersecurity Strategy’s Implementation Plan aligns harmoniously with the approach we have been championing: real-time risk management, enabled by continuous compliance monitoring and end-to-end compliance automation, can revolutionize cybersecurity resilience. This strategic perspective brings us a step closer to turning what is traditionally considered a cost of doing business into a valuable investment in our future security and resilience.

Read the White House Press Release

Read the full implementation plan here

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