Maritime Cyber Security :third-party risk assessments

Of course. This is a critical and increasingly important topic. Here is a comprehensive overview of third-party risk assessments within the context of maritime cybersecurity.

Maritime Cyber Security: A Deep Dive into Third-Party Risk Assessments

The maritime industry is a highly interconnected ecosystem. A single vessel’s operation relies on a complex web of onshore and offshore partners, from satellite communication providers and engine manufacturers to port authorities and software vendors. This interconnectedness is a major source of cyber risk.

A third-party risk assessment is the process of identifying, analyzing, and mitigating the cybersecurity risks introduced to your organization (e.g., a shipping company, a vessel) by its external partners, suppliers, and vendors.

Why is Third-Party Risk So Critical in the Maritime Sector?

1. Interconnected OT and IT Systems: Third parties often have direct or indirect access to a vessel’s most critical systems.

   • Operational Technology (OT): Engine monitoring systems, navigation (ECDIS, GPS), ballast water systems, and cargo management systems are often maintained, updated, or monitored remotely by the manufacturer or a service provider.
   • Information Technology (IT): Crew welfare networks, vessel management software, and communication systems (VSAT) are managed by external entities.

2. The “Weakest Link” Principle: An attacker can bypass a vessel’s or company’s strong defenses by targeting a more vulnerable third party. A breach at a vendor’s office can become a direct threat to a fleet of ships.

3. Regulatory and Compliance Mandates:

   • IMO Resolution MSC.428(98): Requires ship owners and managers to address cyber risks in their Safety Management Systems (SMS) as of January 1, 2021. This implicitly includes risks originating from third parties.
   • Classification Societies (e.g., IACS UR E26 & E27): These new unified requirements mandate robust cybersecurity for a ship’s critical systems, and the responsibility for the security of supplied equipment and software lies with the system integrators and vendors.

4. Complex and Global Supply Chains: The maritime supply chain involves countless entities (ports, terminals, customs, logistics providers). A compromise at any point can have cascading effects, leading to delays, data breaches, or physical disruption.

Who Are the “Third Parties” in the Maritime Context?

Identifying your third parties is the first step. They can be categorized as follows:

The Third-Party Risk Assessment Process: A Step-by-Step Guide

A robust third-party risk management program is a continuous cycle, not a one-time check.

Step 1: Identify and Categorize Your Third Parties

• Inventory: Create a comprehensive inventory of all third parties.
• Tiering: Not all vendors pose the same level of risk. Categorize them based on the criticality of the data or systems they can access.
  • Tier 1 (High Risk): Direct access to critical OT/IT systems (e.g., engine OEM, VSAT provider).
  • Tier 2 (Medium Risk): Access to sensitive but non-critical systems (e.g., crew management software provider).
  • Tier 3 (Low Risk): No access to systems or sensitive data (e.g., office stationery supplier).

Step 2: Define Assessment Criteria

Establish a clear security baseline that you expect your vendors to meet. This should be based on industry standards and regulations:

• NIST Cybersecurity Framework (CSF)
• ISO 27001/27002
• BIMCO Cyber Security Clause 2019
• Guidelines from Oil Companies International Marine Forum (OCIMF)

Step 3: Conduct the Assessment (Due Diligence)

The depth of the assessment should correspond to the vendor’s risk tier.

• Questionnaires: Use standardized security questionnaires (e.g., Consensus Assessments Initiative Questionnaire - CAIQ) to gauge a vendor’s security posture. Ask specific maritime questions:

  • “Do your technicians use dedicated, hardened laptops for onboard service?”
  • “How do you secure your remote access connections to our vessel’s systems?”
  • “Describe your process for ensuring software updates are free of malware.”

• Documentation Review: Request and review security documentation, such as:

  • SOC 2 Type II reports
  • ISO 27001 certification
  • Penetration test results
  • Incident response plans

• Technical Assessments: For high-risk vendors, you may need to conduct more technical validation, such as reviewing the security architecture of their connection to your vessel.

Step 4: Analyze Findings and Remediate Risks

• Identify Gaps: Compare the assessment results against your defined criteria.
• Risk Register: Log all identified risks, their potential impact, and likelihood.
• Remediation Plan: Work with the third party to create a time-bound plan to address critical and high-risk findings. If they are unwilling or unable to fix a major vulnerability, you must decide whether to accept the risk or terminate the relationship.

Step 5: Contractual Agreements

Your legal contracts must include specific cybersecurity clauses.

• Right to Audit: The right for you to assess their security controls.
• Security Standards: The requirement for them to maintain a specific security baseline.
• Incident Notification: A clear requirement to notify you within a specific timeframe (e.g., 24-48 hours) of a security breach that could affect you.
• Liability: Clauses defining liability in the event of a breach caused by the vendor.
• The BIMCO Cyber Security Clause is an excellent industry-standard starting point.

Step 6: Continuous Monitoring and Offboarding

• Periodic Reviews: Re-assess high-risk vendors annually or after any significant change.
• Threat Intelligence: Monitor for public reports of breaches involving your vendors.
• Offboarding: When a contract ends, have a formal process to revoke all physical and logical access to your systems and data.

Challenges and Best Practices

• Challenge: Limited visibility into the “black box” systems provided by OEMs.

  • Best Practice: Push for greater transparency during procurement. Make security a key purchasing criterion.

• Challenge: Small shipping companies may lack the resources for extensive assessments.

  • Best Practice: Focus on the highest-risk vendors first (the Tier 1 group). Use industry-standard questionnaires to be efficient.

• Challenge: Technicians using personal or infected USBs/laptops onboard.

  • Best Practice: Enforce a strict onboard policy for third-party equipment. Provide a company-sanctioned, clean laptop for their use if necessary.

Conclusion

In modern maritime operations, cybersecurity is synonymous with safety and operational resilience. Because vessels and shipping companies do not operate in a vacuum, managing third-party risk is not optional—it is a fundamental component of any effective maritime cyber risk management program. By implementing a structured, risk-based assessment process, you can gain visibility into your extended cyber-attack surface and take proactive steps to protect your fleet, crew, cargo, and company.