Unlock Compliance Excellence: Harness the Power of an SBOM to Conquer Import and Export Controls, Including OFAC Regulations.

Last month I wrote about using a Software Bill of Material (SBOM) as a valuable tool for managing cybersecurity risk. This month I am expanding that conversation from cybersecurity risk to legal trouble. An SBOM can strengthen an organization’s compliance capabilities with import and export controls regulated by the Office of Foreign Assets Control (OFAC) by providing visibility and documentation of software components that may be subject to OFAC regulations.  

OFAC’s sanctions and embargoes on specific countries, encompassing individuals, organizations, and companies engaged in prohibited activities, can pose significant challenges for businesses involved in global trade. However, with the assistance of an SBOM, organizations gain a powerful tool to identify software components originating from or containing code developed by restricted entities. In addition, this proactive approach identifies any connections to blocked entities, ensuring steadfast compliance with OFAC regulations.

In today’s software landscape, dependencies on third-party libraries, frameworks, or modules are commonplace. However, ensuring compliance with OFAC restrictions and laws can be complex. In addition, OFAC regulations and Entity List designations can evolve. An SBOM provides a framework for continuously monitoring and updating software components regarding compliance with import and export controls. Customers can regularly review and update their SBOM to track any changes to OFAC regulations or Entity List designations that may impact the compliance status of their software.

Meeting the requirements of OFAC regulations necessitates meticulous record-keeping and documentation of compliance efforts. With an SBOM, organizations can maintain a comprehensive record of their software components and origins. In addition, this powerful resource enables customers to showcase their due diligence in adhering to OFAC regulations by providing well-documented evidence of the assessment and management of software components subject to import and export controls.

SBOMs facilitate efficient monitoring and tracking of software changes and updates, making it easier to identify and address any non-compliant software elements in a timely manner. Furthermore, by maintaining an up-to-date SBOM, organizations can demonstrate due diligence and easily respond to audit requests, streamlining compliance and reducing the risk of penalties or reputational damage. Overall, leveraging an SBOM for OFAC compliance provides organizations with the tools to proactively manage software-related risks and maintain a robust and compliant software ecosystem.

Dr. Georgianna Shea is the chief technologist of the Center on Cyber and Technology Innovation (CCTI) at the Foundation for Defense of Democracies (FDD). FDD is a Washington, DC-based, nonpartisan research institute focusing on national security and foreign policy.