What evidence do auditors commonly ask for on SC-35 External Malicious Code Identification?

System and communications protection policy; Procedures addressing external malicious code identification; System design documentation; System configuration settings and associated documentation; System components deployed to identify malicious websites and/or web-based malicious code; System audit records.

What is the most common gap auditors find on SC-35?

No components proactively seek network-based malicious code or malicious websites

NIST SP 800-53 Rev 5 · SC - System and Communications Protection

`SC-35` External Malicious Code Identification

Include system components that proactively seek to identify network-based malicious code or malicious websites.

Source: NIST SP 800-53 Rev 5, SC-35. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open NIST SP 800-53 Rev 5 in the compliance library.

Base controls and their enhancements. Which apply follows the baseline you are assessed against (for example FedRAMP Moderate or High, or the low, moderate and high baselines of SP 800-53B). Text in square brackets is a parameter your organisation sets.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

Test of Automated mechanisms supporting and/or implementing external malicious code identification · Document repository

periodic reviewEvidence produced at each review

System audit records · Policy repository / GRC workspace

governing documentDocuments that govern the control

System and communications protection policy · Policy repository / GRC workspace
Procedures addressing external malicious code identification · Policy repository / GRC workspace
System design documentation · Document repository
System configuration settings and associated documentation · Policy repository / GRC workspace
System components deployed to identify malicious websites and/or web-based malicious code · Document repository
System security plan · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Document repository on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

Common gaps auditors find

No components proactively seek network-based malicious code or malicious websites
Findings from proactive malicious code discovery are not acted upon

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

SC-34(2) Non-modifiable Executable Programs | Integrity Protection on Read-only Media · SC-36 Distributed Processing and Storage