BOD 17-01 requires all federal executive branch departments and agencies to (1) identify the use or presence of “Kaspersky-branded products” on all federal information systems within 30 days of BOD issuance (i.e., by October 13); (2) develop and provide to DHS a detailed plan of action to remove and discontinue present and future use of all Kaspersky-branded products within 60 days of BOD issuance (i.e., by November 12); and (3) begin to implement the plan of action at 90 days after BOD issuance (i.e., December 12), unless directed otherwise by DHS in light of new information obtained by DHS, including but not limited to new information submitted by Kaspersky.
The Department of Homeland Security (DHS) National Cybersecurity and Communications Integration Center (NCCIC) reviewed the Independent Assessment, titled Information Security Risks of Anti-Virus Software (hereafter “BRG Assessment”), prepared by Berkeley Research Group, LLC (BRG), and dated November 10, 2017. Kaspersky Lab (hereafter “Kaspersky”) submitted the BRG Assessment to DHS as an exhibit to Kaspersky’s request for DHS to initiate a review of Binding Operational Directive (BOD) 17-01. The BRG Assessment, in part, responds to the NCCIC Information Security Risk Assessment (hereafter “NCCIC Assessment”) on commercial off-the-shelf (COTS) anti-virus software and Kaspersky-branded products, dated August 29, 2017. The NCCIC Assessment was attached as Exhibit 1 to an Information Memorandum from the Assistant Secreta1Y for DHS Cybersecurity and Communications (CS&C) to the Acting Secretary of DHS, dated September 1, 2017 (hereafter “Information Memorandum”). This document is a Supplemental Information Security Risk Assessment and will similarly be attached to an Information Memorandum from the Assistant Secretary for CS&C to the Acting Secretary of DHS.
This assessment presents the inherent information security concerns and security ramifications associated with the use of any commercial-off-the-shelf (COTS) antivirus solution in devices with access to a federal network. It also addresses specific risks presented by Kaspersky-branded products, solutions, and services (collectively, “Kaspersky-branded products”).