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CISA Releases Catalog of Cybersecurity Vulnerabilities Along With a Plan for Remediation

Nov.04.2021

Yesterday, the Cybersecurity and Infrastructure Security Agency (CISA) released a catalog of almost 300 vulnerabilities in commonly used software known to be exploited by threat actors, along with a Binding Operational Directive (Directive or BOD) requiring Federal civilian agencies to remediate such vulnerabilities within prescribed deadlines. BOD 22-01, Reducing the Significant Risks of Known Exploited Vulnerabilities, applies to information systems operated by or for a Federal civilian agency and mandates that:

  1. Agencies review and update their internal vulnerability management procedures in accordance with the Directive by January 3, 2022;
  2. Remediate each vulnerability by the deadline set forth in the vulnerability catalog; and
  3. Report their vulnerability remediation status through CISA’s Continuous Diagnostics and Mitigation Federal Dashboard.

CISA intends to update the catalog with additional vulnerabilities once there is reliable evidence that the vulnerability has been actively exploited and there is a clear remediation action for the vulnerability, such as a vendor-provided update. Companies interested in receiving automatic updates when new vulnerabilities are added to the catalog can subscribe to the catalog update bulletin on CISA’s website.

For now, the Directive applies only to civilian agencies and contractors operating an information system on behalf of a civilian agency. It’s too soon to tell, however, whether the Department of Defense and/or the Intelligence Community will follow with similar actions. Regardless, CISA “strongly recommends” that private businesses voluntarily review the catalog, sign up to receive updates, and remediate the listed vulnerabilities in order to strengthen their cybersecurity defenses.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Christopher R. Hebdon
Associate – Washington, D.C.
Phone: +1 202.624.2645
Email: chebdon@crowell.com
Michael G. Gruden, CIPP/G
Associate – Washington, D.C.
Phone: +1 202.624.2545
Email: mgruden@crowell.com
Maida Oringher Lerner
Senior Counsel – Washington, D.C.
Phone: +1 202.624.2596
Email: mlerner@crowell.com
Evan D. Wolff
Partner – Washington, D.C.
Phone: +1 202.624.2615
Email: ewolff@crowell.com
Kate M. Growley, CIPP/G, CIPP/US
Partner – Washington, D.C.
Phone: +1 202.624.2698
Email: kgrowley@crowell.com