What Does the Executive Order on Supply Chain Security Mean for Your Business? Security Experts Weigh In on SBOMs

Steve Jurczak

In the wake of high-profile software supply chain attacks, the White House issued an executive order requiring more transparency in the software supply chain. The Executive Order (14028) on Improving the Nation’s Cybersecurity requires software vendors to provide a software bill of materials (SBOM). An SBOM is a list of ingredients used by software — that is, the collection of libraries and components that make up an application, whether they are third-party, commercial off-the-shelf, or open source software. By providing visibility into all the individual components and dependencies, SBOMs are seen as a critical tool for improving software supply chain security.

The new executive order affects every organization that does or seeks to do business with the federal government. To learn more about the requirements and implementation, MongoDB invited a few supply chain security experts for a panel discussion. In our conversation, Lena Smart, MongoDB’s Chief Information Security Officer, was joined by three expert panelists: Dr. Allan Friedman, PhD, senior advisor and strategist, CISA; Clinton Herget, principal solutions engineer, Snyk; and Patrick Dwyer, CycloneDX SBOM project co-lead, Open Web Application Security Project.


In early 2020, hackers broke into Texas-based SolarWind's systems and added malicious code to the company's Orion software system, which is used by more than 33,000 companies and government entities to manage IT resources. The code created a backdoor into affected systems, which hackers then used to conduct spying operations.

In December 2021, a vulnerability in the open source Log4J logging service was discovered. The vulnerability enables attackers to execute code remotely on any targeted computer. The vulnerability resulted in massive reconnaissance activity, according to security researchers, and it leaves many large corporations that use the Log4J library exposed to malicious actors.

Also in late 2021, the Russian ransomware gang, REvil, exploited flaws in software from Kaseya, a popular IT management application with MSPs. The attacks multiplied before warnings could be issued, resulting in malicious encryption of data and ransom demands as high as $5 million.

In our panel discussion, Dr. Friedman kicked off the conversation by drawing on the “list of ingredients” analogy, noting that knowing what’s in the package at the grocery store won’t help you keep your diet or protect you from allergens by itself — but good luck doing so without it. What you do with that information matters. So the data layer is where we will start to see security practitioners implement new intelligence and risk-awareness approaches, Friedman says.

SBOM Use Cases

The question of what to do with SBOM data was top-of-mind for all of the experts in the panel discussion. Friedmans says that when the idea of SBOMs was first introduced, it was in the context of on-premises systems and network or firewall security. Now, the discussion is centered on SaaS products.

What should customers expect from an SBOM for a SaaS product? As Senior Advisor and Strategist at the Cybersecurity and Infrastructure Security Agency (CISA), Friedman says this is where the focus will be over the next few months as they engage in public discussions with the software community to define those use cases.

A few of the use cases panelists cited included pre-purchase due diligence, forensic and security analysis, and risk assessment. “At the end of the day, we're doing this hopefully to make the world of software more secure,” Smart says.

No one wants to see another Log4J, the panelists agreed, but chances are we'll see something similar. A tool such as an SBOM could help determine exposure to such risks or prevent them from happening in the first place.

Dwyer waded into the discussion by emphasizing the need for SBOM production and consumption to fit into existing processes. “Now that we're automating our entire software production pipeline, that needs to happen with SBOMs as well,” Dwyer says.

Herget agreed on the need to understand the use cases and edge cases, and to integrate them. “If we're just generating SBOMs to store them in a JSON file on our desktop, we’ve missed the point,” he says. “It's one thing to say that Maven can generate an SBOM for all Java dependencies in a given project, which is amazing until you get to integrating non-Java technologies into that application.”

Hergert says that in the era of microservices, you could be working with an application that has 14 different top-level languages involved, with all of their corresponding sets of open source dependencies handled by an orchestrated, cloud-based continuous integration pipeline.

“We need a lot more tooling to be able to do interesting things with SBOMs,” Herget continued. “Wouldn't it be great to have search-based tooling to be able to look at dependency tree relationships across the entire footprint?”

For Herget, future use cases for SBOM data will depend on a central question: What do we have that is a scalable, orchestrated way to consume SBOM data that we can then throw all kinds of tooling against to determine interesting facts about our software footprint that we wouldn't necessarily have visibility into otherwise?


In the past few years, Smart has been heavily involved in FedRAMP (Federal Risk and Authorization Management Program), which provides a standardized approach to government security authorizations for Cloud Service Offerings. She asked the panelists whether SBOMs should be part of the FedRAMP SSP (System Security Plan).

Friedman observed that FedRAMP is a “passed once, run anywhere” model, which means that once a cloud service is approved by one agency, any other government agency can also use it. “The model of scalable data attestations that are machine-readable I think does lend itself as a good addition to FedRAMP,” Friedman says.

Herget says that vendors will follow if the government chooses to lead on implementing SBOMs. “If we can work toward a state where we're not talking about SBOMs as a distinct thing or even an asset that we're working toward but something that’s a property of software, that's the world we want to get to.”

The Role of Developers in Supply Chain Security

As always, the role of the developer is one of the most critical factors in improving supply chain security, as Herget points out. “The complexity level of software has exceeded the capacity for any individual developer, even a single organization, to understand where all these components are coming from,” Herget says. “All it takes is one developer to assign their GitHub merge rights to someone else who's not a trusted party and now that application and all the applications that depend on it are subject to potential supply chain attack.”

Without supply chain transparency or visibility, Herget explains, there’s no way to tell how many assets are implicated in the event of an exploit. And putting that responsibility on developers isn’t fair because there are no tools or standardized data models that explain where all the interdependencies in an application ultimately lead. Ingredient lists are important, Herget says, but what’s more important are the relationships between them, which components are included in a piece of software and why, who added them and when, and to have all that in a machine-readable and manipulable way.

“It's one thing to say, we have the ingredients,” Herget says, “But then what do you do with that, what kind of analysis can you then provide, and how do you get actionable information in front of the developer so they can make better decisions about what goes into their applications?”

SBOM Minimum Requirements

The executive order lays out the minimum requirements of an SBOM, but our panelists expect that list of requirements to expand. For now, there are three general buckets of requirements:

  1. Each component in an SBOM requires a minimum amount of data, including the supplier of the component, the version number, and any other identifiers of the component.

  2. SBOMs must exist in a widely used, machine-readable format, which today is either CycloneDX or SPDX.

  3. Policies and practices around how deep the SBOM tree should go in terms of dependencies.

Moving forward, the panelists expect the list of minimum requirements to expand to include additional identifiers, such as a hash or digital fingerprint of a component, and a requirement to update an SBOM anytime you update software. They also expect additional requirements for the dependency tree, like a more complete tree or at least the ability to generate the complete tree. “Log4j taught people a lot about the value of having as complete a dependency tree as possible,” Friedman said, “because it was not showing up in the top level of anyone's dependency graph.”

SBOMs for Legacy Systems

One of the hurdles with implementing SBOMs universally is what to do with legacy systems, according to Smart. Johannes Ullrich, Dean of Research for SANS Technology Institute, has said that it may be unrealistic to expect 10- or 20-year-old code to ever have a reasonable SBOM.

Friedman pointed to the use of binary analysis tools to assess software code and spot vulnerabilities, noting that an SBOM taken from the build process is far different from one built using a binary analysis tool. While the one taken from the build process represents the gold standard, Friedman says, there could also be incredible power in the binary analysis model, but there needs to be a good way to compare them to ensure an apples-to-apples approach.

“We need to challenge ourselves to make sure we have an approach that works for software that is in use today, even if it's not necessarily software that is being built today,” Herget says.

As principal solutions engineer at Snyk, Herget says these are precisely the conversations they’re having around what is the right amount of support for 30-year-old applications that are still utilized in production, but were built before the modern concept of package management became integrated into the day-to-day workflows of developers.

“I think these are the 20% of edge cases that SBOMs do need to solve for,” Herget says, “Because if it’s something that only works for modern applications, it's never going to get the support it needs on both the government and the industry side.”

Smart closed the topic by saying, “One of the questions that we've gotten in the Q&A is, ‘What do you call a legacy system?’ The things that keep me awake at night, that's what I call legacy systems.”

Perfect Ending

Finally, the talk turned to perfection, how you define it, and whether it’s worth striving for perfection before launching something new in the SBOM space. Herget, half-joking, said that perfection would be never having these talks again. “Think about how we looked at DevOps five or 10 years ago — it was this separate thing we were working to integrate within our build process,” he says. “You don’t see many panel talks on how we will get to DevOps today because it's already part of the water we’re all swimming in.”

Dwyer added that perfection to him is when SBOMs are just naturally embedded in the modern software development lifecycle — all the tooling, the package ecosystems. “Perfection is when it's just a given that when you purchase software, you get an SBOM, and whenever it's updated, you get an SBOM, but you actually don't care because it's all automated, Dwyer says. “That’s where we need to be.”

According to Friedman, one of the things that SBOMs has started to do is to expose some of the broader challenges that exist in the software ecosystem. One example is software naming and software identity. Friedman says that in many industries, we don't actually have universal ways of naming things. “And, it’s not that we don't have any standards, it’s that we have too many standards,” he explains. “So, for me, perfection is saying SBOMs are now driving further work in these other areas of security where we know we've accumulated some debt but there hasn't been a forcing function to improve it until now.”