Update to the Trusted Internet Connections (TIC) Initiative
MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES
SUBJECT: Update to the Trusted Internet Connections (TIC) Initiative
As a part of the Cloud Smart strategy, OMB has posted this draft policy for public feedback. You may provide feedback in three ways:
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Due to the partial lapse in appropriations, the deadline for submitting comments has been extended.
A. Purpose of the TIC Initiative
The purpose of the TIC initiative is to enhance network security across the Federal Government. Accordingly, this memorandum provides an enhanced approach for implementing the TIC initiative that provides agencies with increased flexibility to use modern security capabilities. This memorandum also establishes a process for ensuring the TIC initiative is agile and responsive to advancements in technology and rapidly evolving threats. To this end, this memorandum rescinds a number of OMB Memoranda that previously required agency traffic to flow through a physical TIC access point. In accordance with Office of Management and Budget (OMB) Memorandum M-17-26, Reducing Burden for Federal Agencies by Rescinding and Modifying OMB Memoranda, OMB is rescinding the following memoranda:
M-08-05, Implementation of Trusted Internet Connections (TIC) (November 20, 2007)
M-08-16, Guidance for TIC Statement of Capability Form (SOC) (April 4, 2008)
M-08-27, Guidance for TIC Compliance (September 30, 2008)
M-09-32, Update on the TIC Initiative (September 17, 2009)
B. Removing Barriers to Cloud and Modern Technology Adoption
This memorandum affirms that agencies may use modern and emerging technologies to meet TIC initiative requirements. The Department of Homeland Security (DHS) will define TIC initiative requirements in documentation called TIC Use Cases. The TIC Use Case documentation will outline which alternative security controls, such as endpoint and user-based protections, must be in place for specific instances where traffic is not required to flow through a physical TIC access point. The capabilities used to meet TIC Use Case requirements may be separate from an agency’s existing network boundary solutions provided by a Trusted Internet Connection Access Provider (TICAP) or Managed Trusted Internet Protocol Services (MTIPS).
- Agencies shall meet the requirements of the TIC Use Cases. See Appendix A for the initial list of approved TIC Use Cases.
Given the diversity of platforms and implementations across the Federal Government, the TIC Use Cases will highlight proven, secure scenarios, where agencies are not required to route traffic through a TICAP/MTIPS solution to meet the requirements for government-wide intrusion detection and prevention efforts, such as the National Cybersecurity Protection System (including the EINSTEIN suite of capabilities). For example, some TIC Use Cases may include application deployments where full-packet inspection is not necessary to achieve proper situational awareness.
C. Collaborative and Iterative Updates
Due to the rapid pace that technology and threats change, it is critical that the TIC Use Cases, as well as other TIC reference architecture documentation, are reviewed and updated on a continuous basis. This memorandum establishes a collaborative and iterative process, which includes input from both industry and Federal agencies. The process includes the following elements:
Developing Pilots: The Chief Information Security Officer (CISO) Council will solicit and review agency and industry TIC pilot proposals on an ongoing basis, participate in the approval process for updates to TIC Use Cases and other TIC reference architecture documentation, and establish the timeline for DHS to review pilot results and approve updates to TIC Use Cases and other TIC reference architecture documentation;
Initiating Pilot Activity: OMB, DHS, the General Services Administration (GSA), and the CISO Council will oversee and support agency TIC pilots, as appropriate;
Approving Use Cases: DHS, in coordination with OMB and the CISO Council, will review pilot results and approve updates to TIC Use Cases and other TIC reference architecture documentation;
Soliciting Feedback: DHS, in coordination with GSA, will establish a process for soliciting agency and industry input on approved TIC Use Cases and other TIC reference architecture documentation. DHS will ensure TIC Use Cases and other TIC reference architecture documentation are kept up to date as changes are approved; and
Acquisitions: GSA, in coordination with DHS, will update government-wide procurement vehicles, as appropriate, within 6 months of the approval of new TIC Use Case requirements and other TIC reference architecture documentation.
D. Streamlining and Automating Verification Processes
DHS, in coordination with agencies, should streamline and automate processes to validate agency compliance with TIC Use Cases, where possible. The goal is to shift from burdensome, point-in-time spot checks to a scalable, comprehensive, and continuous validation process.
- Within 90 days of the release of each TIC Use Case, DHS, in coordination with GSA, will develop a compliance verification process to validate that agencies are implementing the security controls required by TIC Use Cases. DHS will update this verification process as necessary to promote continuous improvement.
E. Agency Implementation
Agency Chief Information Officers shall maintain an accurate inventory of agency network connections, including details on the service provider, cost, capacity, traffic volume, logical/physical configurations, and topological data for each connection in the event OMB, DHS, or others request this information to assist with government-wide cybersecurity incident response or other cybersecurity matters.
- Within one year of the release of this memorandum, agencies will complete updates to their own network and system boundary policies to reflect this memorandum. OMB and DHS will track agency implementation through the Federal Cybersecurity Enhancement Act of 2015 and Federal Information Security Modernization Act of 2014 (FISMA) reporting.
Appendix A - Initial Common Trusted Internet Connections (TIC) Use Cases
The following list of TIC Use Cases are released in concert with this memorandum. The expectation is that the process described under Section C of this memorandum results in the continuous improvement and development of updated TIC Use Cases that account for emerging technologies and evolving cyber threats.
Cloud: These sets of TIC Use Cases cover some of the most prevalent cloud models used by agencies today.
a. Infrastructure as a Service (IaaS)
b. Software as a Service (SaaS)
c. Email as a Service (EaaS)
Agency Branch Office: This use case assumes that there is a branch office of an agency, separate from the agency headquarters (HQ), which utilizes HQ for the majority of their services (including generic web traffic). This case supports agencies that want to enable Software-Defined Wide Area Network (SD-WAN) technologies.
Remote Users: This use case is an evolution of the original FedRAMP TIC Overlay (FTO) activities. The use case demonstrates how a remote user connects to the agency’s traditional network, cloud, and the Internet using government furnished equipment (GFE).
Traditional TIC: For instances not covered in other DHS TIC Use Cases, agencies are required to continue following the Traditional TIC use case. The Traditional TIC use case may include agency use of TICAP and MTIPS providers. This memorandum, as described in Section C – Collaborative and Iterative Updates, encourages agencies to propose TIC pilots on an ongoing basis to demonstrate new ways in which agencies can achieve the security goals of the TIC initiative using state-of-the-practice methods as well as emerging technologies.