Security requirement
- a.Develop and implement anti-counterfeit policy and procedures that include the means to detect and prevent counterfeit components from entering the system.
- b.Report counterfeit system components to [Organization-defined: SELECTED PARAMETER VALUE(S)].
Discussion
Sources of counterfeit components include manufacturers, developers, vendors, and contractors. Anti-counterfeiting policies and procedures support tamper resistance and provide a level of protection against the introduction of malicious code. External reporting organizations include the Cybersecurity and Infrastructure Security Agency (CISA). This requirement is sourced to a control tailored out of the SP 800-53B .13 moderate baseline in SP 800-171.
Tailoring decisions required
Resolve these values through the governing organization’s approved tailoring and risk-management process before declaring the requirement implemented.
Protection strategies supported
These classifications are carried from the official SP 800-172 OSCAL record and help explain the enhanced requirement’s defensive purpose.
Implementation perspective
Treat Component Authenticity as an enhanced CUI protection outcome for elevated threat conditions that must be reflected in the system boundary, documented implementation, operational behavior, and assessment evidence. Pay particular attention to supply-chain governance, provenance, supplier risk, component authenticity, and dependency resilience.
- Confirm the federal agency selected this enhanced requirement for the critical program or high-value asset and identify the CUI system components, services, users, and external connections in scope.
- Resolve every organization-defined parameter through an approved governance and tailoring process.
- Map each clause of the requirement to an accountable owner, implementation mechanism, and evidence source.
- Verify that inherited and shared implementations are supported by current provider evidence and responsibility boundaries.
- Collect evidence during normal operation and review changes, exceptions, and deficiencies on a risk-based cadence.
Questions to ask
- Which critical-program or high-value-asset CUI, data flows, users, and services are protected by this enhanced requirement?
- Which portions are implemented locally, inherited, shared, or not applicable, and what evidence supports that determination?
- Do the system security plan, deployed configuration, operating process, and assessment evidence tell the same story?
- What change, incident, or threshold should trigger reassessment?
Evidence and validation
- supplier inventories and criticality ratings
- contract security clauses
- provenance and authenticity records
- supplier monitoring and incident records
Common failure patterns
- sub-tier dependencies ignored
- contracts lacking evidence and notification obligations
- open-source and service dependencies omitted
- supplier risk reviewed only during procurement
Assessment objectives and methods
Assessment objectives (5)
- a.
an anti-counterfeit policy is developed and implemented.
- a.
anti-counterfeit procedures are developed and implemented.
- a.
the anti-counterfeit policy and procedures include the means to detect counterfeit components entering the system.
- a.
the anti-counterfeit policy and procedures include the means to prevent counterfeit components from entering the system.
- b.
counterfeit system components are reported to [Organization-defined: SELECTED PARAMETER VALUE(S)].
Examine
- Supply chain risk management policy and procedures
- supply chain risk management plan
- system and services acquisition policy
- anti-counterfeit plan
- anti-counterfeit policy and procedures
- media disposal policy
- media protection policy
- incident response policy
- reports notifying developers, manufacturers, vendors, contractors, and/or external reporting organizations of counterfeit system components
- acquisition documentation
- service-level agreements
- acquisition contracts for the system, system component, or system service
- inter-organizational agreements and procedures
- records of reported counterfeit system components
- system security plan
- other relevant documents or records
Interview
- Personnel with system and service acquisition responsibilities
- personnel with information security responsibilities
- personnel with supply chain risk management responsibilities
- personnel with responsibilities for anti-counterfeit policies, procedures, and reporting
Test
- Processes for counterfeit prevention, detection, and reporting
- mechanisms supporting and/or implementing anti-counterfeit detection, prevention, and reporting
Source NIST SP 800-53 controls
These controls are referenced by the official SP 800-172 Rev. 3 OSCAL record. Open the corresponding control pages for complete control text, enhancements, D3FEND mappings, and related learning.
Authoritative sources
- NIST SP 800-172 Revision 3 official publication ↗
- NIST SP 800-172A Revision 3 official publication ↗
- NIST OSCAL Content release used for this import ↗
Bare Metal Cyber is an independent educational publisher and is not affiliated with or endorsed by NIST. The official publications, the responsible federal agency, and the governing contract or agreement determine applicability, tailoring, assessment depth, and required implementation.