The Trump administration’s haphazard and opaque interventions into artificial intelligence security matters could catapult Chinese alternatives into broader acceptance, posing new security risks altogether, a group of Democratic senators wrote to top administration officials Monday.

The five senators said that the administration’s handling has alternated between too passive, such as when OpenAI models escaped testing in the Hugging Face hack last month, and overstepping, such as when the Commerce Department suspended access for any foreign national to Anthropic’s Fable 5 and Mythos 5 in June.

“The Administration’s ad hoc and unpredictable approach undermines U.S. competitiveness, heightening market incentives to adopt open weight models from vendors based in the People’s Republic of China (PRC),” wrote Sens. Kristen Gillibrand of New York, Adam Schiff of California, Mark Warner of Virginia, Chris Coons of Delaware and Mark Kelly of Arizona.

In the Hugging Face hack, the senators wrote that “the Federal Government cannot be passive as these capabilities emerge.”

In the case of the Fable 5 and Mythos 5 suspensions, the senators said that the administration “utilized an infrequently used authority to direct Anthropic to suspend all access to its Fable 5 and Mythos 5 models for foreign nationals (including foreign national employees inside the United States) citing an undisclosed national security concern later described as a narrow jailbreak finding.”

Because Anthropic couldn’t immediately assess users’ nationality, the firm had to disable both models for everyone. The administration and Anthropic negotiated for 18 days behind closed doors before reaching an agreement, the lawmakers complained.

“While the Administration may have been responding to real security concerns to protect the United States, even justifiable interventions can create broader harm if the standards and decision-making processes are opaque, ad hoc, or unpredictable,” they said in their letter to leaders in the White House, Office of the National Cyber Director and departments of State, Treasury and Commerce. “Moreover, when the Executive Branch exercises authority delegated from Congress, such as in the conduct of export control administration, it is essential that it keep Congress fully apprised of its actions and procedures.”

During the time Anthropic was under export controls, the stock price of “an entity-listed Chinese lab” nearly doubled, the senators said. And while Hugging Face was breached, the company “had to” rely on a Chinese open-weight model due to guardrails on U.S. frontier models.

“If American models are perceived as subject to sudden access disruptions based on a black-box U.S. Government process, or as unreliable because U.S. AI labs are overcorrecting in the face of this black-box process, companies and governments in the United States and abroad may hedge by adopting Chinese or other foreign models instead,” the senators contended. “That outcome would undermine U.S. technological leadership while increasing exposure to systems that may carry risks of PRC or otherwise directed censorship, espionage, IP theft, and other supply chain security risks.”

Their letter asked for answers to questions about the standards the administration uses to determine the national security risks a frontier model presents, what legal authorities it will use to invoke restrictions, which agencies are responsible for which decisions and more.

None of the offices or departments the letter was addressed to immediately responded to a request for comment.

The letter follows inquiries at the state level, where 15 attorneys general asked OpenAI for more information regarding the security incident at Hugging Face.

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Seven out of 10 federal cyber regulations requiring written reports to federal agencies are duplicated elsewhere, a report from a government watchdog found in a report to Congress Wednesday.

And so far, efforts to de-conflict haven’t had much success, the report from the Government Accountability Office concluded.

At the request of two top lawmakers, the GAO examined federal cyber regulations at 37 agencies. It counted 80 out of 117 rules that “either contain the same kind of reporting requirement applicable to a sector or the same reporting requirement as at least one other regulation.”

The desire to harmonize those conflicting rules gathered steam under the Biden administration, as it undertook a more aggressive push to regulate cybersecurity than prior administrations. It has continued into the second Trump administration.

The GAO scrutinized regulations that required the private sector to report cybersecurity incidents, plans and reviews to federal agencies, as part of a study sought by House Homeland Security Chairman Andrew Garbarino, R-N.Y., and the top Democrat on the Senate counterpart to Garbarino’s panel, Gary Peters, D-Mich.

In some cases, a single critical infrastructure sector could have duplication with several agencies. For example, the Cybersecurity and Infrastructure Security Agency has been working on a regulation stemming from the 2022 Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA), which would require critical infrastructure owners and operators to report when they are the victims of major attacks or make ransomware payments.

Elements of the financial services sector might fall under one of 15 preexisting cybersecurity reporting rules, depending on the agency that has oversight, but they may also be subject to the pending CIRCIA rules, GAO noted.

A 2024 national security memorandum tasked the Office of the National Cyber Director and the Department of Homeland Security to harmonize conflicting regulations, and both agencies made some progress on those goals.

But the executive branch paused some of those efforts after Trump issued an executive order in March of last year while the administration conducted a study of the 2024 memo, a study that was still underway as of last month, according to the GAO.

As such, on harmonization, “many past federal efforts have experienced delays and made limited progress,” the GAO concluded in its report Wednesday, its latest on the topic. 

Congress has also looked at ways to streamline cybersecurity regulations.

GAO’s study was focused only on federal rules. BreachRx, a cyber incident response firm, published its own report Wednesday looking at major cyber incidents and how overlapping regulatory reporting obligations came into play, folding in regulations from states and other sources.

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After a year and a half spent downplaying calls for AI safety regulations, the Trump administration has sharply reversed course, embracing a level of government scrutiny of frontier AI systems before public release–a far stricter stance than the Biden administration took.

An executive order designed to be friendly to the AI industry was meant to let the federal government briefly review some new models on a voluntary basis.

When the Trump administration, suddenly and without much warning, slapped export controls on Anthropic’s Fable 5 and Mythos 5 in response to private sector threat intelligence reporting, the U.S. AI industry officially entered its regulatory era.

But key questions and gaps remain. It’s not clear why the administration drew the line where it did, or whether they will move it again in the future.

While newer models like Mythos and OpenAI’s Daybreak do have stronger cybersecurity capabilities, the private sector reports the administration relied on describe capabilities already available in older commercial, open-source and Chinese models that nearly anyone can access.

CyberScoop spoke with current users of the latest frontier models, including OpenAI’s ChatGPT 5.5 and Fable 5, to learn more about what these models are currently capable of in offensive and defensive cybersecurity.

Cybersecurity experts and former government officials say the administration may be playing catch up on threats that have been building for years as it has more fully realized the national security implications of the technology.

Are the models breaking new ground or just breaking things? 

Users of Chat GPT 5.5, introduced this past April, and Fable 5 tell CyberScoop those models have been largely helpful to their work, even as they complained about high token usage and safety guardrails that hinder,  but don’t meaningfully prevent, defensive cyber tasks.

Eyal Webber Zvik, chief strategy officer at Cato Networks, a cloud and cybersecurity network provider in OpenAI’s Trusted Access in Cyber program, said they use GPT 5.5 and later OpenAI models to scan and triage internal codebases for vulnerabilities, test new safeguards and provide “highly autonomized service” to their customers.

Zvik wouldn’t disclose how many bugs 5.5 has found but said the company’s view is that it helps both find bugs that humans missed and rank which ones to patch based on factors like each bug’s exploitability.

“It is now a native part of our development environment and cycles, and we use those models to scale our entire codebase and make sure what we release into the service that our customers use to run their networks and network security has the least likelihood of having any vulnerabilities that can be exploited,” said Zvik.

John Hopper, vice president of engineering at SpecterOps, an identity security company, said newer models like GPT 5.5 are sharper and more persistent in pursuing their tasks.

“That can be a good or bad thing,” he noted.

One metric that SpecterOps tracks is how long it can keep a particular agent working before it moves off task or fails. That metric “matters a lot” because the longer an agent works without human help , the more agents a single operator can run at once.

Hopper said this provides defenders with immense value, and pushed back on the idea that the offensive capabilities the models offer are automatically more beneficial to malicious hackers. There is “a modicum of grounding that the industry needs when we talk about these models.”

“Yes, AI frontier tools will lower the barrier of entry, but these problems have always existed,” he said. “I don’t actually believe that AI is going to remove the needle in the haystack problem, but by howdy, using my two hands to find that damn needle, compared to using a backhoe, I can tell you which one I’d rather be driving.”

Eran Kinsbruner, vice president of product marketing at software security firm Checkmarx, told CyberScoop that later models like OpenAI’s Codex Security and GPT 5.5 are noticeably easier to set up and run with local systems, even for less technical users. That alone gives them an edge over many cybersecurity tools where interoperability is a constant concern.

However, GPT 5.5 burns through tokens at a much faster rate. He recalled one instance of using it to scan a medium-sized repository in three different programming languages.

“After 26 minutes I almost ran out of tokens, and it didn’t provide anything, just created a threat model for me and told me you want to buy more tokens?” he said.

In other instances, some of the scan results he received were not comprehensive.

Further, he expressed frustration with some of the guardrails designed to prevent risk – like only allowing users to scan local files but not code repositories like GitHub – “makes not too much sense” given how often developers must work with remote code.

Those kinds of guardrails – which can prevent models or developers from injecting malicious code or prompting into their models – sit at the heart of the debate in Washington D.C. and around the world. Some users feel differently about their utility.

Kinsbruner said that doesn’t make sense for organizations like his, which work with thousands of different enterprise organizations with  thousands of different code repositories spread across the internet.

“I cannot imagine how large-scale developers could just jump into this solution and make it an enterprise-grade, enterprise-level, de facto cybersecurity solution” out of it, said Kinsbruner.

OpenAI did not respond to a request from CyberScoop for an interview on GPT 5.5. The company has since released another model, GPT 5.6, that they said is more efficient at token use.

The White House’s crash course in AI cyber risk 

 The White House keeps changing its line on whether and how the U.S. government should limit the release of commercial frontier models. The shift comes from lessons learned since coming into office in Jan. 2025. Trump threw out Biden-era regulations meant to steer the industry toward safer models. Top officials like Vice President JD Vance argued against restricting industry progress.

Less than two years later, administration officials worry about the impact of speed and scale – two things AI excels at – in cyberspace.

According to Will Loucks, senior director of intelligence at the Office of the National Cyber Director, over the past two years the number of exposed and known vulnerabilities has shot up. Threat actors exploit those flaws faster before defenders can fix them. Once inside, the time from initial access to full network control shrinks.

“So in other words, every stage of the cyber operations lifecycle that a threat actor has to move through to get to a victim network and achieve an outcome, they’re just moving through more quickly faster,” said Loucks at a July 16 event in Washington D.C.

Speaking about AI in particular, Loucks said one of the defining characteristics of the technology is its ability to lower barriers for threat actors.

“Sometimes speed and volume have a threatening aspect alone, even if sophistication isn’t quite increasing in the same way, and the reason for that is because it places pressure on defenders…to triage alerts more quickly,” he said.

Jordan Rae Kelly, former director for cyber and incident response on the White House’s National Security Council during Trump’s first term, told CyberScoop that the changes over the past two years reflect the lessons the White House has learned on the issue since returning to office.

In the early days of this administration, Kelly said, “there is a sense and a spirit that the Biden administration was limiting AI and there was a kind of a rip-it-all-off [attitude], everybody go and do whatever, we will be the biggest and boldest and brightest.”

“I love that talking point, but I think what you’ve seen is probably an education over the last 19 months, where people [in the White House] have said that’s a challenging premise to put into place, knowing about the potential downsides and capabilities,” she added.

Michael Daniel, former White House cyber coordinator under President Barack Obama, thinks the horse may already be out of the barn.

Daniel, now head of the Cyber Threat Alliance, a membership nonprofit group focused on cyber threat information sharing between industry and government, said his members report that AI is being used to do things “faster and at a slightly bigger scale” but aren’t yet seeing the flood of exploitation that analysts have warned about. Not yet.

“I think what we’re seeing right now [and] talking about is ‘okay, where are the step changes [in the cyber threat landscape] actually going to occur?” said Daniel. “Are we and when will we see the explosion in vulnerability reporting from these Mythos-like capabilities? That’s what’s really got their attention right now.”

But Mythos and OpenAI’s Daybreak models are restricted to select organizations, and neither has publicly released its most powerful cybersecurity models to the public. That dynamic won’t last.

The UK’s AI Security Institute estimates that open source and foreign LLM models are between 4-7 months behind frontier U.S. models. In that setting, it’s hard to stop the development of AI models worldwide through export controls or other limits.

“It’s not like we’re buying ourselves five to ten years on this,” he said. “We’re not, and so I’m not sure the impact on the defenders who are trying to obey the law is worth whatever small hiccup we cause for our adversaries.”

Kelly said there’s merit to the administration’s current position, even if it took time to get there. Many federal cybersecurity procedures that operated even a decade ago – such as a Vulnerabilities Equities Process that could take days or weeks to consider the pros and cons of keeping an exploit – are no longer practical.

“All of that work to some degree, is out the window, because you can’t meet with the regularity you would need to meet to adjudicate vulnerabilities that are being found in seconds and exploited in minutes,” said Kelly.

But Kelly and others say that’s also because AI capabilities in cybersecurity are developing faster than policymakers can react, even in the best of times.

Key questions remain and the administration’s balance between national security and backing domestic industry will likely shift  in response to new events.  The administration wants a framework that can predict and manage the risks of AI models today and tomorrow. That may be harder than it sounds.

“Do I think they’ve been clear? No,” said Kelly. “But I think it’s a place where clarity is really hard to achieve.”

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An epidemic of cyberattacks on open-source software has mounted in recent months, making clear how uniquely difficult it is to protect the publicly available code, from both a policy and a technical perspective, that serves as the foundation for so much of the digital world.

While open-source software security got a boost in attention under President Joe Biden — whose administration grappled with the fallout from the potentially catastrophic Log4j flaw that emerged in 2021 — a number of open-source experts say that government protection efforts have suffered setbacks under President Donald Trump. Many also say companies that heavily rely on open-source software, which is basically all of them, haven’t shouldered enough of the responsibility for safeguarding it.

“What we’re seeing is years of lack of investment sustainment in open-source software that is finally starting to catch up to us, where it seems like every week there’s a new supply chain compromise,” said Jack Cable, who held a role at the Cybersecurity and Infrastructure Security Agency where he worked on open-source security before departing under Trump.

The advancements of frontier artificial intelligence models stand to exacerbate the risk further, while simultaneously illustrating what makes defending open source difficult: Project Glasswing said shortly after its announcement that it had uncovered 6,202 high- or critical-severity vulnerabilities in a scan of more than 1,000 open-source projects, but that it had disclosed only 502 of them to open-source project maintainers and only 75 had been patched as of May 22 (albeit some due to typical patching lagtimes).

At the same time, there are questions about how much the government can help, even as overseas governments seek to focus on open-source security.

The evolution of open-source risk 

There are a series of factors contributing to the current threat to open-source software, experts say.

One is simply that attackers go to the area where they can get the highest return on their work. Compromising open-source software gives them the chance to get into the supply chain and exploit additional targets.

“Twenty years ago, open source was still fairly niche,” said Æva Black, who also worked on open-source security at CISA but left when Trump came back into power. “The potential blast radius if you managed to compromise open source was relatively small, because back then the world didn’t run on open source. Now almost everything runs on open source,” she said, from modern cars to satellites.

Another part is the nature of open-source software itself.

“It’s a symptom [of having] lots of open source [that] is a little bit under-maintained or not cared for enough, so that we spend too little effort and money and infrastructure on them,” said Daniel Stenberg, who is the creator and maintainer of cURL, a popular open-source project. “Lots of open source is being maintained by small teams, lots of volunteers, and I think that that’s a tough situation.”

That doesn’t mean the maintainers are to blame, Stenberg said. The companies that rely on open-source need to be diligent about using it, Black said.

“What we’re seeing in that realm right now is not new; it is more advanced and far more widespread,” she said. “The problem remains that companies who use open source — because open source is by far the most efficient way to collaborate on non-product value features — most companies are not implementing a responsible and safe utilization pathway.”

Open-source projects lack a systematic way to handle coordinated vulnerability disclosures, unlike companies or industry groups with formal processes, said Dan Lorenc, CEO and co-founder of Chainguard. Project maintainers sometimes aren’t reachable, and those who are available are flooded with reports, many of them unverified findings from AI tools that waste their time without adding value..

Of course, some of those vulnerability reports turn out to be legitimate. “Mythos and AI models have contributed to an uptick in the number of vulnerabilities and things that we’re able to find” in open-source software, said Alex Zenla, chief technology officer for the cybersecurity company Edera.

All of that leaves more room for companies, non-profits and world governments to improve open-source security.

A moment of momentum

While open-source software security isn’t a new issue, the 2021 discovery of the Log4j flaw sounded alarms within the cybersecurity community. Jen Easterly, then the director of CISA, called it “one of the most serious I’ve seen in my entire career, if not the most serious,” with the potential to affect hundreds of millions of devices given the ubiquitous nature of the popular open-source logging library.

A year later, the Cyber Safety Review Board released its report on the incident, concluding that swift action from industry and government averted a disaster. But the incident “called attention to security risks unique to the thinly-resourced, volunteer-based open source community,” it wrote. “This community is not adequately resourced to ensure that code is developed pursuant to industry-recognized secure coding practices and audited by experts.”

The U.S. government actions after included some steps focused specifically on open-source software such as creation of the Open-Source Software Security Initiative and hires of well-regarded open-source security experts at CISA such as Black, but also some steps that could be applied more generally and still help with open-source security, such as greater promotion of secure-by-design, memory-safe languages and software bills of materials (SBOMs).

Some of the Biden administration work on open-source security started before Log4j, such as provisions from an executive order he issued in 2021 that directed CISA along with the Office of Management and Budget and General Services Administration to issue guidance to agencies. 

The administration’s 2023 cybersecurity strategy also stepped into the long, thorny discussions over software liability, with a mention of open-source security: “Responsibility must be placed on the stakeholders most capable of taking action to prevent bad outcomes, not on the end-users that often bear the consequences of insecure software nor on the open-source developer of a component that is integrated into a commercial product.“ The Biden administration always indicated that addressing software liability would take a prolonged battle ahead.

Under Trump, many of the Biden administration’s efforts have languished. CISA’s splashy hires on open-source are gone, including Black, Tim Pepper and Anjana Rajan. Also departed are leading figures on secure-by-design and SBOMs, with CISA personnel cutbacks slicing deep. 

No one has seen any sign that the national cyber director-led Open-Source Software Security Initiative is active, with few participants remaining in government today. The Trump administration cyber strategy doesn’t mention open-source.

“The loss of open-source experts at CISA “is unfortunate, and it will be hard for the government to try to rebuild capacity, but I do think now more than ever CISA has a core role to play to secure open source software,” Cable said.

The pressure is mounting

It’s not that the issue is getting zero attention from those in a position to make a difference. Nick Andersen, the acting director of CISA, said last month that open-source security was an area of particular concern for him.

Andersen responded to concerns about CISA staffing levels on open-source security and spoke more broadly on the topic in a statement to CyberScoop.

“As artificial intelligence and other technologies have the power to transform how vulnerabilities are discovered and exploited, CISA recognizes that the open source software (OSS) that underpins much of the nation’s critical infrastructure will need to be hardened,” he said. “CISA actively collaborates with our partners on shared priorities, including OSS security, to ensure time and resources are spent where they matter the most.  We have an immensely talented team, but are also accelerating our hiring in critical areas, to strengthen the nation’s defenses against cyber threats.”

The Office of the National Cyber Director did not respond to requests for comment.

There’s been some activity on Capitol Hill, too. The Securing Open Source Software Act, which Cable worked on during a stint as a Senate staffer, would direct CISA and other agencies to take actions to mitigate open-source software security risks, but the legislation has stalled since its introduction in 2022. A portion of the bill, however, was included in the Department of Homeland Security funding law Trump signed in April, directing CISA to brief Congress on the value of establishing something like an open source program office, which some companies use to manage open source within a given firm.

Senate Intelligence Committee Chairman Tom Cotton, R-Ark., has pushed the executive branch to improve its awareness of foreign adversaries playing roles in open-source software used by national security-focused agencies.

The annual defense policy bill in the House calls on the Defense Department’s chief information officer to report to Congress on a plan to secure open-source software supply chains, saying lawmakers are “concerned that the Department lacks sufficient visibility into the origins, maintenance, and security of OSS applications and software dependencies.”

That defense authorization bill language is “really beneficial, and I think it signals acknowledgement of this changing of culture” around open-source security risks, said Hayden Smith, founder of HuntedLabs, whose company won a contract with the Space Development Agency on supply chain security — agency work that the defense bill singled out.

“The report language is the first time the Hill is trying to get a true handle on foreign influence in open source code where they have oversight,” he said, saying it was a “piece of the puzzle” along with Cotton’s letter and a memo from Secretary of Defense Pete Hegseth last year about foreign influence in the Pentagon supply chain. “It’s good and would trickle down into everyone who provides software to the department.”

Zenla, though, believes trying to isolate China from open-source systems isn’t in and of itself a good idea. 

“I don’t think that that makes a lot of sense, because they’re actually pretty good things that people contribute to open source,” she said. “Not everyone is malicious, and what are we going to do, spy on every single open source maintainer?” It’s more about doing things like making sure that highly-classified systems are set up in a separate way, she said.

Europe is also taking action to secure open-source software that the United States doesn’t seem ready or willing to do right now. Germany, for instance, devotes grants to the security of open-source projects, although Stenberg pointed out that sometimes money doesn’t equate to maintainers being able to fix flaws more quickly, depending on the project’s size.

The Cyber Resilience Act (CRA) adopted by the Council of the European Union in 2024 could offer another road on open-source security. The CRA requires those who use open-source software products as part of any commercial activity to take certain security measures. 

Black said that when she was at CISA, there were discussions between the agency and European counterparts about finding compatible ideas on open-source security, but that momentum died with the Trump administration.

But “Europe kept rolling, and now has in place a new legal framework that is set to really reshape open-source security for potentially the whole world, but certainly for anyone who wants to work with Europe on open source,” she said.

Lorenc recently wrote that “open source isn’t governable.” He said an organization like a neutral nonprofit, possibly using some government funding, should take responsibility for things like coordinating vulnerability disclosure into one pipeline. He also said there needs to be one authority in charge of “forking” — that is, taking a project and assigning stewardship elsewhere — when a maintainer isn’t responsive to vulnerabilities. 

There are differing opinions on how much past government warnings, advisories and guidance have helped. Smith gave some credit to government agencies that “have all responded to open source attacks using the means they have.”

Stenberg said that “I don’t think they make any big dent at all in the big scheme of things.” They might get some attention initially, “then two years later we all forgot about them, and they actually didn’t change much.”

Ideally, everyone could get on the same page, Zenla said. “The best way to do this is if people actually collaborated on a global scale on some sort of regulation around this, but that seems nearly impossible at the current moment,” she said. (The United Nations’ Open Source Week runs all this week.)

But if there’s an upside to the spate of attacks on open-source software, it’s the energy it gives to how better to secure it, Lorenc said, invoking the political saying to never let a good crisis go to waste.

“Everyone knows the industry has to change,” he said. “This is a really good crisis, and the right things are happening in the right places, and organizations are rethinking their culture around software development, and they know what they have to do. It’s just something that’s never been top of the priority list for the last 10 years. Now it is, and they’re doing it, and it’s, ‘Can we do it fast enough?’”

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The White House has updated rules for federal agencies to keep logs of significant cyber activities in their networks, touting it as a measure to cut back on red tape and focus on how cybersecurity risks have evolved.

The Office of Management and Budget memorandum, released Friday, replaces a 2021 memo signed by then-President Joe Biden. It continues revisions that President Donald Trump has made to federal cybersecurity guidance under his predecessor.

The new memo, M-26-14, nods at the intentions of the earlier memo, M-21-31, saying that “Implementation of that memorandum improved foundational capabilities across agencies” to establish standards for logging and improve agencies’ record-keeping for the purposes of detecting and responding to cyberattacks.

“However, some requirements, such as the retention of vast quantities of logging data without clear utility, proved neither operationally feasible nor cost-effective for most agencies,” last week’s updated memo states. “To address these inefficiencies and the evolving cyber threat environment, this memorandum directs agencies to employ a risk-based, prioritized logging approach.”

There have been calls for the idea of updating the 2021 memo, and one observer praised the new version to CyberScoop. Another analyst, however, questioned how much harm the Trump administration might do by rescinding the earlier memo before having all of the new memo’s directives in place.

One directive is for the Cybersecurity and Infrastructure Security Agency to develop a “logging reference architecture” within 90 days that prioritizes the objectives of conducting continuous event monitoring and enabling investigations of forensic analysis after a known or suspected compromise.

Agencies would have another 90 days to submit a logging plan that adheres to those principles. The memo also establishes a new model for measuring agency progress in implementation. Multiple government watchdogs have concluded that agencies weren’t meeting the prior memo’s benchmarks.

The new memo “sharpens focus on real-time threat detection and the ability to investigate and recover after a cyber attack,” John Harmon, regional vice president of cyber solutions at Elastic, told CyberScoop. “It gives agencies the flexibility to build logging architectures that fit their specific mission.”

Harmon also praised the memo’s recognition of artificial intelligence risks to cybersecurity, and the revised maturity model.

But Nick Leiserson, senior vice president for policy at the Institute for Security and Technology think tank, said the timing of the replacement memo and the rescinding of the previous memo will give agencies a reason not to budget and prioritize logging for a period of time that adds up to six months or more.

“Moving from that to nothing is not ideal, and that’s essentially what this is doing,” Leiserson, who served in the Biden administration’s Office of the National Cyber Director, told CyberScoop. “This is saying ‘We’re rescinding 21-31 right now’ You won’t have any new guidance for at least 90 days, when CISA publishes this logging reference architecture, and it’s not clear to me why you would disaggregate that and not have the two of those things come out at the same time.”

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