Open-source software is the cornerstone of most IT platforms and infrastructure. This reliance extends beyond major applications; most software worldwide relies, in part, on even the smallest OSS library that solves a critical problem.
For businesses subject to FedRAMP, CMMC, and other federal jurisdictions, this is a solid way to plan their compliance. As we’re seeing, however, OSS is just as vulnerable as other software (if not more) due to the nature of decentralized development. This has become such an issue that even members of Congress are starting to pay attention.
Why Open Source Has Become a High-Value Target
Senator Tom Cotton sent a letter to the White House urging federal cyber leadership to address national security risks posed by America’s deep, largely unmanaged reliance on open-source software. The concern expressed was the realization that trust-based software ecosystems now sit squarely within adversaries’ operational reach.
The open-source model assumes good faith. This is the vector through which attackers make their move. As security experts note, it’s now common for hackers to infiltrate OSS groups on platforms like GitHub. They pose as legitimate contributors and, counting on the fact that few people will directly monitor them, put malicious code into trusted packages. More crudely, they may create repositories that mimic well-known libraries with slight spelling changes to trick users into downloading their code.
Over the past several years, attackers have demonstrated that they do not need to breach hardened perimeters if they can compromise trusted components upstream. By targeting widely used libraries, build tools, or maintainers themselves, adversaries can quietly embed access paths into thousands or millions of downstream systems.
A Short Timeline That Explains a Big Shift (2023–2025)
In 2023, large-scale supply-chain incidents, such as the MOVEit breach, demonstrated how third-party software dependencies could enable mass exploitation. While MOVEit itself was not open source, the lesson was unmistakable: modern organizations inherit risks they do not directly control, and visibility into software lineage is often shallow or nonexistent.
- As early as 2018, attackers have been using open-source development methods to undermine security. When the maintainer of a JavaScript library (EventStream) widely used in cryptocurrency wallets transferred control to another user, the new owner injected malicious code into the library that would automatically drain coins from an end user’s wallet.
- Throughout 2023, security researchers also documented explosive growth in malicious packages uploaded to public OSS registries such as npm and PyPI. These packages relied less on advanced exploits and more on human behavior to gain access to software.
- Then, in early 2024, the XZ Utils backdoor highlighted this problem. A widely trusted compression utility, embedded in countless Linux distributions, was compromised through a patient social engineering campaign targeting project maintainers. The threat was so severe that the government issued an alert.
By late 2024 and into 2025, malicious OSS packages continued to evolve. Attackers increasingly leveraged automation and AI-assisted tooling to generate convincing code, evade detection, and move faster than traditional scanning tools.
The Core Problem: OSS Is Critical Infrastructure Without Infrastructure-Grade Governance
Most organizations cannot reliably answer basic questions about their open-source exposure:
- Which open-source libraries are in use across production systems?
- Who maintains them?
- How quickly can vulnerabilities be located and addressed?
- What happens when a maintainer disappears, or the project dies off?
The purported strength of OSS is its transparency and open availability. The manner in which it is created, however, is different. Opaque communities of pseudo-anonymous contributors create a massive hole in what is (predictably) the most profitable attack surface for hackers–the human component.
Frameworks such as FedRAMP and CMMC face a challenge with OSS: they require stricter controls over software management, whereas open-source ecosystems are dynamic, decentralized, and often undocumented.
Why FedRAMP- and CMMC-Compliant Organizations Should Be Aware
Agencies such as CISA and NIST continue to refine guidance around secure software development frameworks and third-party risk management.
More recently, the White House’s Office of the National Cyber Director has been positioned as a coordinating body to align OSS risk mitigation across civilian agencies, the defense sector, and the critical infrastructure sector. The goal is to bring OSS under a governance model that reflects its real-world impact.
For contractors and vendors, this means expectations will continue to rise, whether explicitly through regulation or implicitly through procurement requirements.
- FedRAMP requires cloud service providers to demonstrate continuous monitoring, configuration management, vulnerability management, and supply-chain risk awareness. OSS components sit squarely within that scope, even when they are deeply embedded in platform services or inherited through managed services.
- CMMC, particularly at Levels 2 and 3, introduces explicit expectations around system integrity, risk management, and protection against advanced persistent threats. NIST SP 800-171 and 800-172 do not mention open source by name, but their requirements clearly apply to any software that can affect confidentiality, integrity, or availability.
What Proactive Organizations Should Be Doing Now
For businesses in the U.S. digital supply chain, the path forward is not to abandon open source. It is to operationalize it responsibly.
- Organizations need comprehensive visibility. That means maintaining accurate inventories of OSS components across environments, including transitive dependencies. SBOMs should not be treated as paperwork artifacts but as living risk-management tools.
- OSS risk must be integrated into formal governance processes. Vulnerability management, configuration control, and change management should explicitly account for open-source components and manage when and how they are updated.
- Businesses should evaluate maintenance and provenance, especially for critical components. Understanding who maintains a library, how changes are reviewed, and how releases are controlled is increasingly essential, particularly for software that supports authentication, encryption, logging, or remote access.
- Continuous monitoring must extend beyond CVE scanning. Behavioral analysis, anomaly detection, and dependency risk scoring are becoming essential as attackers shift from exploiting known vulnerabilities to embedding malicious functionality upstream.
- Organizations should align OSS governance with compliance narratives.
FedRAMP SSPs and CMMC artifacts should clearly document how open-source risk is identified, assessed, mitigated, and monitored. Doing so not only strengthens security posture but also reduces friction during assessments.
Manage OSS and Proprietary Software Risk with Lazarus Alliance
Open-source software is not going away. In fact, its role will only grow as cloud-native architectures, AI systems, and modular platforms expand. For organizations operating in regulated, federally connected environments, the choice is no longer whether to address OSS risk, but whether to do so proactively or under pressure.
The organizations that embrace automation and AI-driven defense will be prepared. Those that rely on legacy, reactive models will struggle to keep up with threats moving at machine speed.
To learn more about how Lazarus Alliance can help, contact us.
- FedRAMP
- GovRAMP
- NIST 800-53
- DFARS NIST 800-171
- CMMC
- SOC 1 & SOC 2
- ENS
- C5
- HIPAA, HITECH, & Meaningful Use
- PCI DSS RoC & SAQ
- IRS 1075 & 4812
- CJIS
- LA DMF
- ISO 27001, ISO 27002, ISO 27005, ISO 27017, ISO 27018, ISO 27701, ISO 22301, ISO 17020, ISO 17021, ISO 17025, ISO 17065, ISO 9001, & ISO 90003
- NIAP Common Criteria – Lazarus Alliance Laboratories
- And dozens more!
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