Navigating the New Frontier: Understanding FedRAMP's Red Team Requirement

April 2, 2024
Bennett Warner

The New Frontier

In the evolving cybersecurity landscape, the latest iteration of the FedRAMP Revision  5 Baseline, along with National Institute of Standards and Technology (NIST) Special Publication 800-53 Revision 5 (SP 800-53 Rev 5), has introduced a heightened focus on proactive defense mechanisms. Among these, the inclusion of a specific control enhancement for red team exercises, as outlined in Control Enhancement CA-8(2), marks a pivotal shift in how organizations should approach their cybersecurity strategies. This article delves into the nuances of the new red team requirement, explores the concept of red teaming, and offers insights into how organizations can navigate the absence of explicit guidance to effectively implement this directive.

The Essence of Red Teaming

Red teaming is a comprehensive and adversarial approach designed to simulate real-world attacks on an organization's systems, processes, and people. Unlike traditional penetration testing, which often focuses on identifying and exploiting specific vulnerabilities, red team exercises aim to mimic tactics, techniques, and procedures (TTPs) used by genuine adversaries. This method provides a holistic view of an organization's defensive capabilities and uncovers potential weaknesses within technology-based defenses and human factors, such as susceptibility to social engineering.

The New Requirement: CA-8(2) Explained

The CA-8 control in Revision 5 mandates organizations to conduct penetration testing at a defined frequency on selected systems or components. The introduction of Enhancement (2) under this control calls explicitly for employing red team exercises. These exercises are intended to simulate attempts by adversaries to compromise organizational systems, adhering to applicable rules of engagement. However, Revision 5 stops short of detailing what these exercises should entail, leaving the specifics to be determined by the implementing organization.

The Challenge of Undefined Guidance

The lack of explicit guidance on conducting red team exercises as per CA-8(2) poses a unique challenge for organizations. It requires them to define their own "organization-defined red team exercises" without a standardized framework. This ambiguity necessitates a strategic approach, drawing on existing cybersecurity best practices and the collective experience of the cybersecurity community.

Implementing Red Team Exercises Internally

For organizations considering implementing red team exercises in-house, there are several benefits to this approach. Conducting red teaming internally allows for a deeper, more intimate understanding of the organization's unique systems, culture, and potential security vulnerabilities. It enables real-time feedback and iteration on security practices, fostering a proactive security culture that engages all levels of the organization.

What This Looks Like in Practice

An internal red team exercise might involve assembling a dedicated team from various departments, including IT, cybersecurity, and non-technical staff, to simulate a range of attack vectors. This team would operate under strict rules of engagement to ensure the safety and confidentiality of data and systems. By leveraging internal knowledge, the exercises can be highly tailored to the organization's specific operational environment, focusing on the most critical assets and likely threat scenarios.

However, this approach has limitations. Internal teams may lack the necessary objectivity to critically assess and challenge the organization's security posture effectively. There's also the risk of skill gaps, as internal teams may not always follow the latest adversarial tactics and techniques. Additionally, the scope of internal exercises may be limited by organizational biases or a lack of comprehensive threat intelligence.

Partnering with Trusted Experts

Given the potential limitations of internal red team exercises, many organizations partner with external providers specializing in red teaming and cybersecurity. Here's why considering a trusted partner like RISCPoint can be advantageous:

  • Expertise and Objectivity - External partners bring a level of knowledge and experience that is hard to match internally. They are professionals dedicated to understanding and simulating sophisticated cyber threats, equipped with the latest knowledge of adversarial tactics and techniques. Their objectivity allows for an unbiased assessment of your security posture, ensuring no stone is left unturned in identifying vulnerabilities.
  • Advanced Tools and Techniques - Specialized red team providers have access to advanced tools and methodologies that may not be readily available to internal teams. These include proprietary software, custom exploit development, and comprehensive threat intelligence databases. Utilizing these resources can provide a more in-depth and realistic simulation of potential cyber threats.
  • Efficiency and Focus - Outsourcing red team exercises allow your internal team to focus on their core responsibilities, ensuring that cybersecurity efforts do not detract from day-to-day operations. It also means that red team exercises can be conducted more efficiently, as external teams are ready to deploy without the need for extensive preparation or training.
  • Comprehensive Reporting and Support - Partnering with an external provider ensures you receive comprehensive reporting on the findings, along with actionable recommendations. Moreover, a trusted partner can offer ongoing support to address identified vulnerabilities and strengthen your security posture, providing value beyond the initial exercise.

Consideration of Future 3PAO Guidance for the Red Team Mandate

As Cloud Solution Providers (CSPs) await formal guidance from the FedRAMP Program Management Office regarding the red teaming mandate introduced in Revision 5, it's valuable to engage in some speculation of what red teaming guidance may look like. This exercise not only helps prepare for what's to come but also encourages proactive planning and strategy development. Here's what future 3PAO guidance on the red team mandate could potentially encompass based on current cybersecurity trends, best practices, and the underlying objectives of the mandate.

Drawing Parallels: FedRAMP Penetration Testing Requirements

FedRAMP mandates specific penetration testing activities to ensure the security of cloud services used by federal agencies. By examining the structure and requirements of FedRAMP penetration testing, we can infer potential elements of future 3PAO guidance on red team exercises. This evidence-based consideration suggests that guidance will likely emphasize realism, specificity, safety, and continuous improvement, drawing on established practices to enhance the effectiveness and relevance of red teaming in improving organizational cybersecurity posture.

Comprehensive Scenario Development

FedRAMP's emphasis on realistic test cases suggests that future 3PAO guidance for red team exercises will require detailed, real-world scenario development. We can anticipate guidance that demands Red Team Test Plans (RTTPs) cover a broad range of attack vectors tailored to organization-specific risks ensuring that organizations are prepared for the most relevant and potentially damaging threats. These scenarios could include a combination of the following and will often be informed by the results of initial reconnaissance:

  • Open-Source Intelligence (OSINT): This involves gathering data from publicly available sources to gather intelligence on the target organization. It's a non-intrusive method that helps in understanding the organization's digital footprint, identifying potential vulnerabilities, and planning attack vectors that mimic real-world threats.
  • Social Engineering
  • Phishing: Sending fraudulent communications that appear to come from a reputable source, usually via email, to steal sensitive data like credit card numbers or login information.
  • Spear Phishing: A more targeted form of phishing in which the attacker customizes their message to fit the victim, often using personal information to increase their credibility.
  • Vishing: Voice phishing where attackers use phone calls to trick individuals into revealing sensitive information.
  • Smishing: Similar to phishing, but through SMS texts. Attackers send messages to coax personal information from victims or to install malware on their mobile devices.
  • Internal and External Network Exploitation: This involves identifying and exploiting vulnerabilities in both the internal and external networks of an organization. Red teams may use various techniques to breach defenses, escalate privileges, and move laterally through the network to access sensitive information.
  • Credential Stuffing: This attack method involves using stolen account credentials (obtained from breaches of other services) to gain unauthorized access to user accounts through large-scale automated login requests. It relies on the fact that people often reuse passwords across multiple services, aiming to compromise accounts on the targeted system.

Implementation of Red Team Exercises

A red team exercise is distinct from a penetration test because its primary goal is not merely to discover and exploit as many vulnerabilities as possible within a set timeframe. Instead, it aims to uncover weaknesses within the organization and offer insights that contribute to enhancing its cybersecurity maturity and the ongoing improvement process. Once testing scenarios have been selected based on organizational relevance, the testing phase of the exercise is conducted. Red Team methodology usually follows the following phases:  

  • Reconnaissance: This initial phase involves gathering information about the target organization. Red team members collect data on the organization's systems, networks, and employee behaviors to identify potential vulnerabilities and entry points. This phase sets the groundwork for planning the attack strategy.
  • Exploitation / Initial Access: In this phase, the red team exploits the vulnerabilities identified during the reconnaissance phase to gain initial access to the organization's systems or network. The goal is to breach the perimeter defenses without detection, using various techniques to exploit software vulnerabilities, weak passwords, or social engineering tactics.
  • Persistence / Lateral Movement: Once inside, the red team works to maintain their presence within the system (persistence) and move across the network to gain access to critical assets or information (lateral movement). This phase involves escalating privileges, creating backdoors, and circumventing internal security measures to reach high-value targets within the organization.
  • Data Exfiltration: The final phase focuses on extracting sensitive information or critical assets from the target organization without detection. The red team demonstrates the potential impact of a real-world attack by showing what data could be compromised. This phase highlights the importance of securing data at rest and in transit, and the need for effective detection and response strategies.

These exercise phases are designed to replicate attackers and advanced persistent threats (APT) as described in Lockheed Martin’s Cyber Kill Chain.

Continuous Improvement and Integration

The iterative nature of FedRAMP's authorization process, which requires regular re-assessment and continuous monitoring, supports the speculation that 3PAO guidance will emphasize integrating red team findings into an ongoing improvement process. By leveraging the framework established for penetration testing, future guidance could advocate for using red team exercise outcomes to drive security enhancements and risk management decisions.


While the guidance for Revision 5’s red team exercises are pending, organizations have a unique opportunity to tailor these activities to their specific needs and threats. By adopting a strategic approach grounded in best practices and leveraging skilled resources, organizations can significantly enhance their cybersecurity resilience. As the cybersecurity landscape continues to evolve, embracing the challenge of red teaming will undoubtedly position organizations to better defend against and adapt to sophisticated threats.


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