TLCTC Blog - 2025/04/12
NIST CSF Integration with TLCTC Framework
The NIST Cybersecurity Framework (CSF) 2.0 claims to provide "guidance to industry, government agencies, and other organizations to manage cybersecurity risks." However, an analysis of the framework and its supporting documents reveals several significant gaps in how it addresses cyber threats specifically.
NIST's general threat definition from SP 800-30 states that a threat is:
"Any circumstance or event with the potential to adversely impact organizational operations and assets, individuals, other organizations, or the Nation through an information system via unauthorized access, destruction, disclosure, or modification of information, and/or denial of service."
While this definition mentions information systems, it does not distinguish cyber threats as a distinct category.
The framework's threat categorization, as outlined in SP 800-30 Table D-2, provides four broad categories: Adversarial, Accidental, Structural, and Environmental. These categories encompass all types of threats without specifically delineating cyber threats from other security threats.
For risk assessment, NIST SP 800-30 states that "Risk assessments are used to identify, estimate, and prioritize risk to organizational operations (i.e., mission, functions, image, and reputation), organizational assets, individuals, other organizations, and the Nation, resulting from the operation and use of information systems." This risk-based approach is further supported by the CSF Core structure, which organizes outcomes into Functions (GOVERN, IDENTIFY, PROTECT, DETECT, RESPOND, and RECOVER) rather than specific threat types.
The analysis reveals several critical limitations in the framework:
- Lacks a specific cyber threat definition
- Does not provide a cyber-specific threat categorization
- Does not provide threat-specific control mappings
- Takes a general risk-based rather than cyber-threat-specific approach
What makes this particularly interesting is that the framework still requires organizations to "identify threats" and then "apply controls" without providing specific guidance on what constitutes a cyber threat or which controls map to specific cyber threats. Funny isn't it?
This disconnect between the framework's stated cybersecurity focus and its actual content raises questions about its effectiveness in specifically addressing cyber threats versus general security risks.
A Path Forward: Embracing Structured Threat Categorization
As the cybersecurity community continues to evolve, it's crucial that our frameworks evolve with us. The adoption of a comprehensive threat taxonomy within the NIST CSF could significantly enhance its practical utility in cyber risk management.
Instead of bashing I propose the Top Level Cyber Threat Clusters[3]. This framework offers a structured, consistent method for categorizing threats that bridges the gap between high-level strategy and operational security.
The TLCTC approach addresses many of the shortcomings in the NIST definition by:
- Providing clear, distinct categories for different types of threats
- Separating threats from vulnerabilities and impacts
- Offering a logical hierarchy that can link high-level risks to specific technical controls
The Benefits of a Clear Threat Taxonomy
Integrating a structured threat taxonomy like TLCTC into the NIST CSF could offer several key benefits:
- Consistency: A standardized taxonomy ensures that all parts of an organization are speaking the same language when it comes to threats.
- Completeness: A well-designed taxonomy helps ensure that no significant threat categories are overlooked.
- Clarity: Clear categories make it easier to communicate about threats both within an organization and with external stakeholders.
- Actionability: A structured approach to threats makes it easier to link threat categories directly to specific controls and mitigation strategies.
- Scalability: A good taxonomy can be applied consistently across different scales, from individual systems to entire enterprises.
Integration Framework
Generic NIST Functions Framework
For each Threat Cluster, apply this structured approach:
| NIST Function | Control Objective | Local Controls | Umbrella Controls |
|---|---|---|---|
| IDENTIFY | Identify weaknesses enabling [Threat] Event | Specific measures targeting the threat | Overarching detection systems |
| PROTECT | Protect from [Threat] Event | Direct protection measures | Enterprise-wide protection systems |
| DETECT | Detect [Threat] Event | Local detection mechanisms | Security monitoring systems |
| RESPOND | Respond to [Threat] Event | Immediate response actions | Incident response platforms |
| RECOVER | Recover from [Threat] Event | Local recovery procedures | Business continuity systems |
Example: Exploiting Server (#2)
| NIST Function | Control Objective | Local Controls | Umbrella Controls |
|---|---|---|---|
| IDENTIFY | Try to identify failures in the code of your Server Software | Fuzzy Testing, Network based Vulscan | Threat Intelligence, CVE Subscriptions |
| PROTECT | Protect Server from being exploited | Patch Management, Secure Coding | Web Application Firewall (WAF) |
| DETECT | Detect Exploited Server | Local Event Logging | Security Information and Event Management (SIEM) |
| RESPOND | Respond to exploited server | Emergency Patch, CSIRT | Exploit Server Response Plan (Make WAF Rules) |
| RECOVER | Recover Server Exploit Event | Maintain your Repo, Restore | IT Service Continuity Management (IT-SCM) |
Integration with International Standards
While NIST functions provide an excellent structure for organizing controls and their objectives within each Top Level Cyber Threat Cluster, ISO standards can play a complementary role in this framework. Organizations can leverage ISO's comprehensive control sets (such as those in ISO 27002) and risk management methodologies (ISO 27005) to enhance control selection and implementation within the NIST function structure, thereby creating a more robust and internationally aligned approach to addressing each threat cluster.
Application
This framework can be applied to all 10 Top Level Cyber Threat Clusters:
- Abuse of functions
- Exploiting Server
- Exploiting Client
- Identity Theft
- Man in the middle
- Flooding Attack
- Malware
- Physical Attack
- Social Engineering
- Supply Chain (Attack)
For each cluster, specific Control Objectives, Local Controls, and Umbrella Controls should be defined according to the unique characteristics and risks associated with that threat type.
| IDENTIFY | PROTECT | DETECT | RESPONSE | RECOVER | ||
|---|---|---|---|---|---|---|
| GOVERN | #1 Abuse of functions | Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
| #2 Exploiting Server | Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
|
| #3 Exploiting Client | Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
|
| #4 Identity Theft | Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
|
| #5 Man in the middle | Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
|
| #6 Flooding Attack | Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
|
| #7 Malware | Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
|
| #8 Physical Attack | Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
|
| #9 Social Engineering | Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
|
| #10 Supply Chain (Attack) | Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Umbrella Controls Local Controls |
Where are the GOV controls?
The GOVERN (GV) function in NIST CSF 2.0 operates at a strategic level, focusing on establishing the overall cybersecurity risk management framework rather than addressing specific threats directly. Unlike functions such as PROTECT or DETECT, which have controls directly linked to mitigating or identifying particular cyber threats, GOVERN controls are "assurance controls" that ensure the organization has a comprehensive approach to cybersecurity. These controls create the structure and context within which other functions operate, including setting risk appetite, defining roles and responsibilities, and establishing policies. While the threat categorization, such as the 10 Top Level Cyber Threat Clusters, is indeed a crucial element in the risk register that GOVERN oversees, the GV controls themselves do not directly counter specific threats. Instead, they provide the strategic foundation that enables the organization to effectively manage and respond to the entire spectrum of cyber risks.
Conclusion: Time for Evolution
As we continue to face increasingly sophisticated cyber threats, it's time for our foundational frameworks to adapt. The NIST CSF has served us well, but its approach to threat identification and categorization is due for an upgrade.
By incorporating a structured threat taxonomy, the NIST CSF could provide organizations with a clearer path from threat identification to control implementation, ultimately leading to more robust and effective cybersecurity strategies.
References
- National Institute of Standards and Technology, "Framework for Improving Critical Infrastructure Cybersecurity, Version 2.0," 2024.
- B. Kreinz, "Top Level Cyber Threat Clusters," Barnes Projects White Paper, September 2024.
- NIST Special Publication 800-30, "Guide for Conducting Risk Assessments"