FedRAMP Penetration Test Guidance

Version 1.0.1
July 6, 2015

FedRAMP Penetration Test Guidance V1.0.1

07/06/2015

Revision History
Date

Version

Page(s)

Description

Author

06/30/2015

1.0

All

First Release

FedRAMP
PMO

07/06/2015

1.0.1

All

Minor corrections and edits

FedRAMP
PMO

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Table of Contents
About This Document .................................................................................................................... iv
Who Should Use This Document .............................................................................................. iv
How This Document Is Organized ............................................................................................ iv
How To Contact Us ................................................................................................................... iv
1. Scope ........................................................................................................................................... 1
2. Definitions & Threats ................................................................................................................. 2
2.1. Definitions ........................................................................................................................... 2
2.2. Threat Models ...................................................................................................................... 3
2.3. Threat Modeling .................................................................................................................. 3
3. Attack Vectors ............................................................................................................................ 4
3.1. External to Corporate External Untrusted to Internal Untrusted ...................................... 6
3.2. External to Target System External Untrusted to External Trusted ................................. 7
3.3. Target System to CSP Management System External Trusted to Internal Trusted .......... 8
3.4. Tenant to Tenant External Trusted to External Trusted ................................................... 9
3.5. Corporate to CSP Management System Internal Untrusted to Internal Trusted............... 9
3.6. Mobile Application External Untrusted to External Trusted .......................................... 10
4. Scoping the Penetration Test .................................................................................................... 10
5. Penetration Test Methodology and Requirements .................................................................... 11
5.1. Information Gathering & Discovery .................................................................................. 12
5.2. Web Application/API Testing Information Gathering/Discovery ..................................... 13
5.3. Mobile Application Information Gathering/Discovery ..................................................... 13
5.4. Network Information Gathering/Discovery ....................................................................... 14
5.5. Social Engineering Information Gathering/Discovery ...................................................... 15
5.6. Simulated Internal Attack Information Gathering/Discovery ........................................... 15
5.7. Exploitation ........................................................................................................................ 16
5.7.1. Web Application/API Exploitation ................................................................................. 16
5.7.2. Mobile Application Exploitation .................................................................................... 16
5.7.3. Network Exploitation ...................................................................................................... 17
5.7.4. Social Engineering Exploitation ..................................................................................... 18
5.7.5. Simulated Internal Attack Exploitation .......................................................................... 18
5.8. Post-Exploitation ............................................................................................................... 19
5.8.1. Web Application/API Post-Exploitation ........................................................................ 19
5.8.2. Mobile Application Post-Exploitation ............................................................................ 20
5.8.3. Network Post-Exploitation ............................................................................................. 20
5.8.4. Social Engineering Post-Exploitation ............................................................................. 20
5.8.5. Simulated Internal Attack Post-Exploitation .................................................................. 21
6. Reporting................................................................................................................................... 21
6.1. Scope of Target System ..................................................................................................... 21
6.2. Attack Vectors Addressed During the Penetration Test .................................................... 21
6.3. Timeline for Assessment Activity ..................................................................................... 21
6.4. Actual Tests Performed and Results .................................................................................. 21

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6.5. Findings and Evidence ....................................................................................................... 21

6.6. Access Paths ...................................................................................................................... 21
7. Testing Schedule Requirements ................................................................................................ 22
8. Third Party Assessment Organization (3PAO) Staffing Requirements .................................... 22
Appendix A: Acronyms ................................................................................................................ 23
Appendix B: References ............................................................................................................... 24
Appendix C: ROE/Test Plan Template ......................................................................................... 25

List of Tables
Table 1.
Table 2.
Table 3.
Table 4.
Table 5.
Table 6.
Table 7.
Table 8.
Table 9.
Table 10.
Table 11.
Table 12.
Table 13.
Table 14.
Table 15.
Table 16.
Table 17.

Cloud Service Classification ........................................................................................ 1

Types of Attacks ........................................................................................................... 4
Attack Vector Summary ............................................................................................... 4
Discovery Activities ................................................................................................... 13
Mobile Application Information Gathering/Discovery .............................................. 14
Network Information Gathering/Discovery................................................................ 14
Network Information Gathering/Discovery................................................................ 15
Simulated Internal Attack Gathering/Discovery ........................................................ 15
Web Application/API Exploitation ............................................................................ 16
Mobile Application Exploitation ............................................................................ 17
Network Exploitation .............................................................................................. 17
Social Engineering Exploitation ............................................................................. 18
Simulated Internal Attack Exploitation .................................................................. 18
Post-Exploitation..................................................................................................... 19
Web Application/API Post-Exploitation................................................................. 19
Network Post-Exploitation...................................................................................... 20
3PAO Staffing Requirements ................................................................................. 22

List of Figures
Figure 1.
Figure 2.
Figure 3.
Figure 4.
Figure 5.
Figure 6.
Figure 7.

Sample Target System .................................................................................................. 6

External to Corporate Attack Vector ............................................................................ 7
External to Target System Attack Vector ..................................................................... 8
Target System to CSP Management System ................................................................ 8
Tenant to Tenant Attack Vector ................................................................................... 9
Corporate to CSP Management System Attack Vector .............................................. 10
Elements of a Penetration Test ................................................................................... 12

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ABOUT THIS DOCUMENT

The purpose of this document is to provide guidelines for organizations regarding planning and
conducting Penetration Testing and analyzing and reporting on the findings.
A Penetration Test is a proactive and authorized exercise to break through the security of an IT
system. The main objective of a Penetration Test is to identify exploitable security weaknesses in an
information system. These vulnerabilities may include service and application flaws, improper
configurations, and risky end-user behavior. A Penetration Test also may evaluate an organizations
security policy compliance, its employees security awareness, and the organization's ability to
identify and respond to security incidents.

WHO SHOULD USE THIS DOCUMENT

The following individuals should read this document:

Cloud Service Providers (CSP) should use this document when preparing to perform a
Penetration Test on their cloud system

Third Party Assessor Organizations (3PAO) should use this document when planning,
executing, and reporting on Penetration Testing activities

Authorizing Officials (AO) should use this document when developing and evaluating
Penetration Test plans.

HOW THIS DOCUMENT IS ORGANIZED

This document is divided into the following primary sections and appendices:
Section
Section 1
Section 2
Section 3
Section 4
Section 5
Section 6
Section 7
Section 8
Appendix A
Appendix B
Appendix C

Contents
Document Scope
Definitions and Assumptions
Attack Vectors
Scoping The Penetration Test
Penetration Test Methodology and Requirements
Reporting
Test Schedule Requirements
3PAO Staffing Requirements
Table of acronyms used in this document
References
Rules of Engagement/Test Plan

HOW TO CONTACT US
Questions about FedRAMP or this document may be directed to [email protected].
For more information about FedRAMP, visit the website at http://www.fedramp.gov.

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1. SCOPE
The Federal Risk and Authorization Management Program (FedRAMP) requires that Penetration
Testing be conducted in compliance with the following guidance:

Guide to Understanding FedRAMP, June 2014

NIST SP 800-115 Technical Guide to Information Security Testing and Assessment,
September 2008
NIST SP 800-145 The NIST Definition of Cloud Computing, September 2011
NIST SP 800-53 Security and Privacy Controls for Federal Information Systems and
Organizations, Revision 4, April 2013, with updates as of January 2015
NIST SP 800-53A Assessing Security and Privacy Controls in Federal Information
Systems and Organizations: Building Effective Assessment Plans, Revision 4, December
2014

FedRAMP also requires that CSP products and solutions (cloud service) undergoing a FedRAMP
assessment and Penetration Test must be classified as a SaaS, PaaS, or IaaS. In some scenarios, it
may be appropriate to apply multiple designations to a cloud service. Table 1 below shows the
definitions of these three service types.
Table 1.

Cloud Service
Model

Cloud Service Classification

NIST Description

Software as a
Service (SaaS)

The capability provided to the consumer is to use the providers applications

running on a cloud infrastructure. The applications are accessible from various
client devices through either a thin-client interface, such as a web browser (e.g.,
web-based email), or a program interface. The consumer does not manage or
control the underlying cloud infrastructure including network, servers, operating
systems, storage, or even individual application capabilities, with the possible
exception of limited user-specific application configuration settings.

Platform as a
Service (PaaS)

The capability provided to the consumer is to deploy onto the cloud

infrastructure consumer-created or acquired applications created using
programming languages, libraries, services, and tools supported by the provider.
The consumer does not manage or control the underlying cloud infrastructure
including network, servers, operating systems, or storage, but has control over
the deployed applications and possibly configuration settings for the applicationhosting environment.

Infrastructure as
a Service (IaaS)

The capability provided to the consumer is to provision processing, storage,

networks, and other fundamental computing resources where the consumer is
able to deploy and run arbitrary software, which can include operating systems
and applications. The consumer does not manage or control the underlying cloud
infrastructure, but has control over operating systems, storage, and deployed
applications; and possibly limited control of select networking components (e.g.,
host firewalls).

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All components, associated services, and access paths (internal/external) within the defined test
boundary of the CSP system must be scoped and assessed. The Rules of Engagement (ROE)
must identify and define the appropriate testing method(s) and techniques associated with
exploitation of the relevant devices and/or services.
Penetration Testing may require:

Negotiation and agreement with third parties such as Internet Service Providers (ISP),
Managed Security Service Providers (MSSP), facility leaseholders, hosting services,
and/or other organizations involved in, or affected by, the test. In such scenarios, the CSP
is responsible for coordination and obtaining approvals from third parties prior to the
commencement of testing.

To limit impact on business operations, the complete or partial testing may be conducted
in a non-production environment as long as it is identical to the production environment
and has been validated by the 3PAO. For instance, if a CSP has two identical locations, a
Penetration Test on one location may suffice. In this case, the environments must be
exactly the same, not almost, nearly, or virtually.

When the cloud system has multiple tenants, the CSP must build a temporary tenant
environment if another tenant environment suitable for testing does not exist.

The Penetration Test plan must include actual testing of all the attack vectors described in
Section 3 below or explain why a particular vector was not applicable. The Independent
Assessors (IA) may include additional attack vectors they believe are appropriate. See Appendix
C: ROE/Test Plan Template for more information regarding test plans.

2. DEFINITIONS & THREATS

To establish a baseline and context for FedRAMP Penetration Testing, the following terms are
used to describe proposed cloud services.

2.1. DEFINITIONS
The following is a list of definitions for this document.

Corporate Internal CSP network access outside the authorization boundary.

Insider Threat A threat that is posed by an employee or a third party acting on behalf
of the CSP.
Management System A backend application or infrastructure setup that facilitates
administrative access to the cloud service. The Management System is accessible only by
CSP personnel.
Roles Access levels and privileges of a user.
System The cloud service that is offered to government customers.
Target The application or cloud service that will be evaluated during the Penetration
Test.
Tenant A customer instance of the cloud service.
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2.2. THREAT MODELS

For FedRAMP threat models with multiple tenants, the CSP must build a temporary tenant
environment if another tenant environment suitable for testing does not exist.
The Penetration Test plan must include:

A description of the approach, constraints, and methodologies for each planned attack
A detailed Test Schedule that specifies the Start and End Date/Times and content of each
test period and the overall Penetration Test beginning and end dates
Technical Points of Contact (POC) with a backup for each subsystem and/or application
that may be included in the Penetration Test

The Penetration Test Rules of Engagement (ROE) describes the target systems, scope,
constraints, and proper notifications and disclosures of the Penetration Test. The IA develops the
ROE based on the parameters provided by the CSP. The ROE must be developed in accordance
with National Institute of Standards and Technology (NIST) Special Publication (SP) 800-115,
Appendix B, and be approved by the authorizing officials of the CSP prior to testing. See Section
6, Rules of Engagement, of the FedRAMP Security Assessment Plan Template for more
information on the ROE. The IA must include a copy of the ROE in the FedRAMP Security
Assessment Plan submitted to FedRAMP.
The ROE should also include:

Local Computer Incident Response Team or capability and their requirements for
exercising the Penetration Test
Physical Penetration Constraints
Acceptable Social Engineering Pretext(s)
A summary and reference to any Third Party agreements, including Points of Contact
(POC) for Third Parties that may be affected by the Penetration Test

2.3. THREAT MODELING

The IA must ensure the Penetration Test is appropriate for the size and complexity of the cloud
system and takes into account the most critical security risks. The IA must perform the
Penetration Test in accordance with industry best practices and standards. Typical goals for
Penetration Testing include:

Gaining access to sensitive information

Circumventing access controls and privilege escalation
Exploiting vulnerabilities to gain access to systems or information
Confirming that remediated items are no longer a risk

The IA should test all or a sufficient sample of access points and locations (for physical
Penetration Testing). When the IA tests a sample, the IA must describe how and why the sample
was selected, and why it is sufficient.
The IA should attempt to exploit vulnerabilities and weaknesses throughout the cloud system
environment, including physical Penetration Testing. At a minimum, the IA should verify

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security doors are locked, security alarms work, and security guards are present and alert as
required by the CSP organizations security policies and procedures. These situations must be
identified during scoping sessions and accounted for accordingly in the Rules of
Engagement/Test Plan (ROE/TP).
The types of attacks must be repeatable and present a consistent representation of threats, threat
capabilities, and organization-specific threat qualifications. In addition, the types of attacks must
address the goals of the Penetration Test and include both internal and external attacks.

Internal Employees or users who are employed by the CSP, including both privileged
and non-privileged users, in the context of the target system.
External Users and non-users of the system who are not employed by the CSP. This
includes government users of the application, as well as third parties who do not have
access rights to the target system.
Trusted Users with approved access rights to the target system. Trusted users include
both internal CSP employees with management access to the system, as well as external
users with credentialed access to the tenant environment.
Untrusted Non-users of the target system. Untrusted users include both internal CSP
employees who lack credentialed access to the target system, as well as any individual
attempting to access the target system from the Internet.

See Table 2 below for the relationships between Trusted/Untrusted and Internal/External attacks.
Table 2.

Types of Attacks

Internal

External

Trusted

CSP employee responsible for setup,

maintenance, or administrative access
to the CSP target system.

Any user of the target system,

regardless of assigned roles or access
rights.

Untrusted

An employee of the CSP without direct Any individual, without authorized

access to the target system.
credentials, attempting to access the
target system from the Internet.

3. ATTACK VECTORS
Attack vectors can be defined as potential avenues of compromise which may lead to a
degradation of system integrity, confidentiality, or availability. FedRAMP has identified and
developed several risk scenarios for the 3PAO organization to review and address during
Penetration Testing. Table 3 below lists the identified attack vectors, which are detailed in the
sections below.
Table 3.

Attack Vector Summary

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Description

External to Corporate
External Untrusted to Internal
Untrusted

An internet-based attack attempting to gain useful information

about or access the target cloud system through an external
corporate network owned and operated by the CSP.

External to Target System

External Untrusted to External
Trusted

An internet-based attack as an un-credentialed third party

attempting to gain unauthorized access to the target system.

Target System to CSP

Management System
External Trusted to Internal
Trusted

An external attack as a credentialed system user attempting to

access the CSP management system or infrastructure.

Tenant to Tenant External

Trusted to External Trusted

An external attack as a credentialed system user, originating

from a tenant environment instance, attempting to access or
compromise a secondary tenant instance within the target
system.

Corporate to CSP Management

System Internal Untrusted to
Internal Trusted

An internal attack attempting to access the target management

system from a system with an identified or simulated security
weakness on the CSP corporate network that mimics a
malicious device.

Mobile Application External

Untrusted to External Trusted

An attack that emulates a mobile application user attempting to

access the CSP target system or the CSPs target systems
mobile application.

Figure 1 belowillustrates a sample target cloud system to give context to the attack vectors
illustrated in Figures 2 through 6 below. Each attack vector has been paired with its relevant
threat model as a general guide for designing test cases. Note that physical attack vectors are not
included in the attack vector descriptions below and a specific cloud service may differ from the
represented system. The 3PAO must demonstrate how the Penetration Test will address these
attack vectors.

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External Un-trusted

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External Trusted

External Network Boundary

Application Layer

Platform Layer

Management

Infrastructure Layer

Internal Network Boundary

Internal Un-Trusted

Internal Trusted

Granted External
Access
Granted Internal
Access
Attempted Access

Figure 1. Sample Target System

3.1. EXTERNAL TO CORPORATE EXTERNAL UNTRUSTED TO

INTERNAL UNTRUSTED
Figure 2 illustrates an internet-based attack attempting to gain useful information about or access
to the target cloud system through an external corporate network owned and operated by the
CSP. Only employees who are directly responsible for the target system will need to be included
in this attack vector. See Section 5.5 Social Engineering, for information about this attack vector.

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Attacker
External Network Boundary

Application Layer

Platform Layer

Management

Internet

Infrastructure Layer

Internal Network Boundary

Corporate Network

Figure 2. External to Corporate Attack Vector

3.2. EXTERNAL TO TARGET SYSTEM EXTERNAL UNTRUSTED

TO EXTERNAL TRUSTED
Figure 3 below illustrates an internet-based attack as an un-credentialed third party attempting to
gain unauthorized access to the target system.

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Attacker
External Network Boundary

Application Layer

Platform Layer

Management

Infrastructure Layer

Internal Network Boundary

Figure 3. External to Target System Attack Vector

3.3. TARGET SYSTEM TO CSP MANAGEMENT SYSTEM

EXTERNAL TRUSTED TO INTERNAL TRUSTED
Figure 4 below illustrates an external attack as a credentialed system user attempting to access
the CSP management system or infrastructure.

Attacker
External Boundary

Tenant

Application Layer

Platform Layer

Management

Infrastructure Layer

Internal Boundary

Figure 4. Target System to CSP Management System

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3.4. TENANT TO TENANT EXTERNAL TRUSTED TO EXTERNAL

TRUSTED
Figure 5 below illustrates an external attack as a credentialed system user, originating from a
tenant environment instance, attempting to access or compromise a secondary tenant instance
within the target system.

Attacker
External Boundary

Tenant 1

Tenant 2

Application Layer

Application Layer

Platform Layer

Platform Layer

Infrastructure Layer

Infrastructure Layer

Internal Boundary

Figure 5. Tenant to Tenant Attack Vector

3.5. CORPORATE TO CSP MANAGEMENT SYSTEM INTERNAL

UNTRUSTED TO INTERNAL TRUSTED
Figure 6 below illustrates an internal attack attempting to access the target management system
from a system with an identified or simulated security weakness on the CSP corporate network
that mimics a malicious device (as if the organization has been infiltrated) or remotely
compromised host on the corporate network.

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External Network Boundary

Application Layer

Platform Layer

Management

Infrastructure Layer

Internal Network Boundary

Attacker

Figure 6. Corporate to CSP Management System Attack Vector

3.6. MOBILE APPLICATION EXTERNAL UNTRUSTED TO

EXTERNAL TRUSTED
This attack vector consists of emulating a mobile application user attempting to access the CSP
target system or the CSPs target systems mobile application. This attack vector is tested on a
representative mobile device and does not directly impact the CSP target system or
infrastructure. Information derived from this activity can be used to inform testing of other attack
vectors.

4. SCOPING THE PENETRATION TEST

The authorization boundaries of the proposed cloud service will be initially determined based on
the System Security Plan (SSP) and attachments provided to the FedRAMP PMO. Section 9 of
the SSP should clearly define authorization boundaries of the cloud system in a diagram and
words. During the Penetration Test scoping discussions, individual system components will be
reviewed and deemed as in-scope or out-of-scope for the Penetration Test. The aggregate of
the agreed upon and authorized in-scope components will comprise the system boundary for the
Penetration Test.
When scoping the system boundaries for the assessment, it is important to consider the legal
ramifications of performing Penetration Testing activities on third-party environments. All
testing activities must be limited to the in-scope test boundary for the system to ensure adherence
to all agreements and limitation of legal liability. Penetration Testing should not be performed
on assets for which permission has not been explicitly documented. Obtaining permission for any
third-party assets that are required to be in-scope is the responsibility of the CSP.

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Service models intending to use FedRAMP-compliant services lower in the cloud stack can
leverage the FedRAMP compliance and security features of those services. As a result, attack
vectors already addressed by other FedRAMP- compliant services lower in the cloud stack are
not required to be re-evaluated. For example: If a PaaS and SaaS leverage another layer that is
FedRAMP compliant, then Penetration Testing of the lower layer is not required. However, the
CSP must determine the authorization system boundaries and provide justification for any
controls they intend to claim as inherited from the supporting service. If the PaaS and/or SaaS
are including FedRAMP-compliant security features for the lower layers, then Penetration
Testing of the lower layers is required and the CSP needs to obtain all the authorizations required
for the 3PAO to perform Penetration Testing for the lower layers.
Please refer to the current version of the Guide to Understanding FedRAMP for additional
guidance regarding boundary determination, cloud service modeling, and inheritance.

5. PENETRATION TEST METHODOLOGY AND

REQUIREMENTS
The Penetration Test methodology and requirements are constructed to follow industry best
practices. Figure 7 below illustrates the key elements of a CSP Penetration Test FedRAMP
identified based on the technology used within the cloud service. The depth of testing and
technologies to be tested is dependent on the Penetration Test system boundary and system
scope. This guidance will cover the following:

Web Application/Application Program Interface (API) Testing

Mobile Application Testing
Network Testing
Social Engineering Testing
Simulated Internal Attack Vectors

The methodology has been organized according to common assessment steps followed by
industry-practiced frameworks. The required level of effort regarding the appropriate Penetration
Testing methodology will be determined by the 3PAO based on the technologies in the in-scope
test boundary, regardless of how the CSP has self-identified the cloud service (SaaS, PaaS, or
IaaS). For example: If operating system/host-level access is offered by a CSP in a cloud service
in which the CSP self-identifies as a SaaS or PaaS cloud service, network Penetration Testing
requirements will still apply.

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Start

Discovery

Scoping

Web
Application
& API

Social
Engineering

Simulated
Internal Attack

Network

Post Exploitation

Exploitation

Mobile
Application

Reporting

End

Figure 7. Elements of a Penetration Test

5.1. INFORMATION GATHERING & DISCOVERY

Information gathering and discovery activities occur prior to exploitation and are intended to
accurately and comprehensively map the attack surface of the target system. Several
requirements are outlined below.

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5.2. WEB APPLICATION/API TESTING INFORMATION

GATHERING/DISCOVERY
For API testing, sample workflows and test cases should be provided by the CSP to serve as a
basic interface for common use cases of the applications functionality. The following activities
in Table 4 below must be completed.
Table 4.
Activity
Perform internet searches to
identify any publicly
available information on the
target web application

Discovery Activities
Description

Identify any publicly available documentation that can be

leveraged to gain insight into potential attack vectors of the
target web application. Determine if any publicly available
vulnerability has been disclosed, which could potentially be
leveraged to attack the target web application.

Identify the target application Identify all layers of the application including application
architecture
servers, databases, middleware, and other technologies to
determine communication flow and patterns within the
application.
Identify account roles and
authorization bounds

Identify the roles associated with the cloud service and determine
access limitations.

Map all content and

functionality

Create a sitemap detailing all levels of functionality within the

web application. Please note: different account roles may have
different access levels to functionality within the target web
application.

Identify all user-controlled

input entry points

Map all areas of the application that take input from the user of
the application.

Perform web application

server configuration checks

Perform web vulnerability scanning activity to determine if

common web server configuration flaws are present that could
lead to an access path.

5.3. MOBILE APPLICATION INFORMATION

GATHERING/DISCOVERY
Conduct information gathering and discovery activities against a mobile application. Please note
that all platforms (iOS, Android, BlackBerry, etc.) for which the mobile application is offered
should be tested independently. The following activities in Table 5 below must be completed.

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Mobile Application Information Gathering/Discovery

Activity

Description

Perform internet searches to

identify any publicly
available information on the
target web application

Identify any publicly available documentation that can be

leveraged to gain insight into potential attack vectors of the target
mobile application. Determine if any publicly available
vulnerability has been disclosed, which could potentially be
leveraged to attack the target mobile application.

Map all content and

functionality

Navigate through the application to determine functionality and

workflow.

Identify all permission sets

requested by the application

Inventory the permissions that the mobile application requests

from the phone. Determine if there are any differences across
mobile platforms.

5.4. NETWORK INFORMATION GATHERING/DISCOVERY

Conduct information gathering and discovery activities against externally available network
ranges and endpoints. The following activities in Table 6 below must be completed.
Table 6.
Activity
Perform Open Source
Intelligence (OSINT)
Gathering Activities

Network Information Gathering/Discovery

Description

Conduct an analysis of the public profile of the target system

including information disseminated about public Internet Protocol (IP)
ranges, technologies implemented within the target network or
organization, and details around previous public attacks against the
target system.

Enumerate and
Conduct a scan to identify active network endpoints on the network
Inventory Live Network environment.
Endpoints
Enumerate and
Inventory Network
Service Availability

Conduct an inventory of network services to identify potential attack

vectors.

Fingerprint Operating
Systems and Network

Determine service types and versions numbers.

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Description

Services
Perform Vulnerability
Identification

Conduct network scanning activity to identify publicly available

vulnerabilities.

5.5. SOCIAL ENGINEERING INFORMATION

GATHERING/DISCOVERY
Conduct external information gathering and discovery activities against CSP employees and
system administrators for the system to be tested. The following activities in Table 7 below must
be completed.
Table 7.

Network Information Gathering/Discovery

Activity

Description

Perform internet searches to identify CSP

personnel of interest responsible for target
system management.

Inventory publicly available information that

details CSP personnel roles and responsibilities
for the target system.
Note: The CSP must approve a final list of
system administrators to target for a spear
phishing exercise.

5.6. SIMULATED INTERNAL ATTACK INFORMATION

GATHERING/DISCOVERY
Conduct internal information gathering and discovery activities against CSP employees and
system administrators for the system to be tested. A representative corporate
workstation/environment with general user access commensurate with a typical CSP corporate
user must be given to the 3PAO to conduct this analysis. The following activities in Table 8
below must be completed.
Table 8.

Simulated Internal Attack Gathering/Discovery

Activity
Perform a scoping exercise with the
CSP to determine potential attack
vectors.

Description
Identify valid attack chains assuming an internal CSP
user was compromised by a social engineering attack.

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Description

Perform Vulnerability Identification

Conduct credentialed network scanning activity to

identify publicly available vulnerabilities and privilege
escalation vectors.

5.7. EXPLOITATION
During exploitation, the 3PAO Penetration Testing team will attempt to leverage attack vectors
identified during information gathering and discovery to gain initial access into the target system,
based on the attack vector being tested. Several attack vectors are outlined below.

5.7.1. WEB APPLICATION/API EXPLOITATION

Conduct web application exploitation activities against target web applications/APIs. The
following activities in Table 9 below must be completed.
Table 9.
Activity

Web Application/API Exploitation

Description

Authentication and
Session Management

Assess the application to determine how the target application creates

and maintains a session state. Analyze account creation and
management process.

Authorization

Identify issues related to role privilege enforcement across common

customer roles in the cloud service. Attempt to bypass authorization
restrictions.

Application Logic

Attempt to circumvent controls to prevent bypass on intended logic

patterns and application flows.

Input Validation

Perform injection attacks against all data inputs to determine if

information or files can be inserted or extracted from the target
application. Attempt to alter the backend.

5.7.2. MOBILE APPLICATION EXPLOITATION

Conduct local mobile exploitation activities against application content installed onto end-user
mobile devices. Please note that all available platforms should be tested if the application is
developed for multiple mobile device operating systems. Also note that interaction between the
mobile application and the cloud service is not addressed under this section, as it is covered in

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Section 5.8.1: Web Application/API Exploitation. The following activities in Table 10 below
must be completed.
Table 10. Mobile Application Exploitation
Activity

Description

Authorization

Identify issues related to role privilege enforcement across common

customer roles in the cloud service. Attempt to bypass authorization
restrictions.

Data Storage

Identify and inventory data being stored on the device. Determine if

encryption is being utilized outside of platform level controls.

Information
Disclosure

Identify what information is being disclosed in log files and local cache
stores.

5.7.3. NETWORK EXPLOITATION

Conduct network-level exploitation activities to analyze the risk of identified vulnerabilities by
demonstrating attacks against hosts to determine the sensitivity of the information that can be
retrieved. Specific requirements are not given in this section, as the nature of the exploitation
will be highly differentiated by the identified service or endpoint vulnerabilities; instead, general
guidelines for performing exploitation attacks are provided. The following activities in Table 11
below must be completed.
Table 11. Network Exploitation
Activity

Description

Attack
Scenarios

Present identified attack scenarios to the CSP for approval of execution. Note
that if the CSP does not approve a potential exploitation path, this must be
documented in the Penetration Test report.

Exploitation

Perform exploitation activity with the intent of gaining access to the target
systems and elevating privileges, if possible. If unsuccessful, attempt to adapt the
exploitation approach to work against the target environment.

Record
Results

If exploitation attack scenarios were successful, document the results. If

exploitation attack scenarios were unsuccessful, document why the exploit failed
and what protections (if any) prevented the exploit from executing.

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5.7.4. SOCIAL ENGINEERING EXPLOITATION

A social engineering exercise will target CSP employees responsible for administering the CSP
management system. While this exercise will differ based on the agreements and scope of the
test plan, the assumption is that the system administrators are operating outside of the target
system test boundary and its security controls (relying on CSP corporate security controls). The
intent of this test is to assess the likelihood of an external untrusted threat achieving compromise
of an internal trusted user responsible for system administration or management. The following
activities in Table 12 must be completed.
Table 12. Social Engineering Exploitation
Activity
Spear
Phishing
Exercise

Description
Conduct an unannounced spear phishing exercise targeted at the CSP system
administrators. Record and report statistics on observed click-through rates
during the email campaign.

5.7.5. SIMULATED INTERNAL ATTACK EXPLOITATION

Attempt to identify and potentially exploit attack vectors that could allow access to systems
within the test system boundary from within the CSP corporate network environment. This attack
vector simulates a breach of a corporate asset with the intent of pivoting access to the target
system and will be simulated through analysis of a representative corporate image/workstation.
An assumption is made that if escalation and pivoting vectors are identified, the target system
would eventually be compromised. Although the corporate asset is outside the system boundary,
the results of the simulated internal attack will be documented in the Penetration Test report for
remediation by the CSP. Utilizing this methodology simulates an internal attack without
conducting Penetration Testing activities of the corporate CSP network environment. The
following activities in Table 13 below must be completed.
Table 13. Simulated Internal Attack Exploitation
Activity

Description

Escalate to
Administrative
Privileges

Attempt to gain administrative privileges on the CSP standard workstation

image. If the CSP provisions users as local system administrators by
default, testing should still be conducted to determine the likelihood of a
successful pivot to additional workstations or servers in the CSP
environment.

Recording Results

If exploitation attack scenarios were successful, document the results. If

exploitation attack scenarios were unsuccessful, document why the exploit
failed and what protections (if any) prevented the exploit from executing.

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5.8. POST-EXPLOITATION
During post-exploitation, the 3PAO Penetration Testing team will attempt to exercise
vulnerabilities discovered during exploitation. The 3APO Penetration Testing team will conduct
post-exploitation activities with the intent of demonstrating the impact of exploitation by
laterally moving to additional endpoints with the intent to compromise sensitive CSP data,
information, or control of the target system infrastructure. Post-exploitation activities will be
determined by the level of access gained by exploitation and the technologies utilized by the
system. They should broadly cover the activities listed below. The following activities in Table
14 must be completed.
Table 14. Post-Exploitation
Activity

Description

Escalation of
Privileges

Attempt to gain administrative control of the compromised host.

Lateral Movement

Perform further discovery and enumeration to identify hosts on the

network that may only respond to the compromised system. Leverage
compromised systems and credentials to pivot to additional hosts with
the intent of gaining unauthorized access to management systems or
other customer systems.

Identification and
Exfiltration of
Sensitive Systems or
Data

Identify sensitive or critical information that may be accessed or

compromised through a successful attack (criteria for sensitive data to
be determined during the scoping phase). Attempt to exfiltrate sensitive
information undetected.

5.8.1. WEB APPLICATION/API POST-EXPLOITATION

Conduct web application post-exploitation activities against target web applications/APIs. The
following activities in Table 15 must be completed.
Table 15. Web Application/API Post-Exploitation
Activity

Description

Unauthorized
Management Access

Use access to application to attempt to gain control of underlying

infrastructure or management systems.

Unauthorized Data
Access

Attempt to demonstrate the potential to access additional data from

sources outside the cloud services intended scope.

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5.8.2. MOBILE APPLICATION POST-EXPLOITATION

This attack vector is not applicable since the Penetration Test will be assessing only the local
application on the test platform. The device on which the mobile application resides is
considered out of scope for the Penetration Test.

5.8.3. NETWORK POST-EXPLOITATION

Conduct network post-exploitation activities against the target infrastructure to attempt to access
management networks, applications, and other customer instances. The following activities in
Table 16 below must be completed.
Table 16. Network Post-Exploitation
Activity

Description

Gain Situational
Awareness

Determine what level of access was gained following a successful

exploitation attempt.

Privilege Escalation

If applicable, attempt to escalate privileges to allow for additional

access on the exploited endpoint or other endpoints within the network
environment.

Lateral Movement

Perform further discovery and enumeration to identify hosts on the

network that may respond only to the compromised system. Leverage
compromised systems and credentials to pivot to additional hosts with
the intent of gaining unauthorized access to management systems or
other customer systems.

Identification and
Exfiltration of
Sensitive Systems or
Data

Identify sensitive or critical information that may be accessed or

compromised through a successful attack (criteria for sensitive data to
be determined during the scoping phase). Attempt to exfiltrate sensitive
information undetected.

5.8.4. SOCIAL ENGINEERING POST-EXPLOITATION

This attack vector is not applicable. Collecting statistics of an unannounced spear phishing
assessment against the target system administrators will be required to be reported in the
Penetration Test report.

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5.8.5. SIMULATED INTERNAL ATTACK POST-EXPLOITATION

This attack vector is not applicable. The CSP will assume corporate breach; eventually leading to
management access into the CSP target system given the 3PAO is able to identify privilege
escalation and pivoting avenues and attack chains.

6. REPORTING
Penetration Test assessment activities and results must be organized and compiled into a
comprehensive Penetration Test report to be included in the Security Assessment Report (SAR).
The report is required to address the following sections.

6.1. SCOPE OF TARGET SYSTEM

Outline the target system that was assessed and if any deviations were made from the ROE/TP
document.

6.2. ATTACK VECTORS ADDRESSED DURING THE PENETRATION

TEST
Described the attack vector(s) tested and the threat model(s) followed for executing the
Penetration Test.

6.3. TIMELINE FOR ASSESSMENT ACTIVITY

Document when Penetration Testing activity was performed.

6.4. ACTUAL TESTS PERFORMED AND RESULTS

Document the actual tests performed to address the Penetration Test requirements outlined in this
document, and document the results of each test.

6.5. FINDINGS AND EVIDENCE

Findings should include a description of the issue, the impact on the target system, a
recommendation to the CSP, a risk rating, and relevant evidence to provide context for each
finding.

6.6. ACCESS PATHS

Access paths are the chain of attack vectors, exploitations, and post-exploitations that lead to a
degradation of system integrity, confidentiality, or availability. The 3PAO must describe the
access path and the Penetration Test impact if multiple vulnerabilities could be coupled to form a
sophisticated attack against the CSP.
The Penetration Test report should include appropriate confidentiality and sensitivity markings
in compliance with the CSP organizational policy. The 3PAO should provide the report to the
CSP via a secure means in compliance with the CSP organizations policies. Any information

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included in the report that could contain sensitive data (screenshots, tables, figures) must be
sanitized or masked using techniques that render the sensitive data permanently unrecoverable by
recipients of the report. The 3PAO must not include passwords (including those in encrypted
form) in the final report, or must mask them to ensure recipients of the report cannot recreate or
guess the password.

7. TESTING SCHEDULE REQUIREMENTS

For each initial security authorization, a Penetration Test must be completed by a 3PAO as a part
of the assessment process described in the Security Assessment Plan (SAP). Thereafter,
FedRAMP requires a complete Penetration Test at least every 12 months, unless otherwise
approved by the authorizing body with documented rationale.

8. THIRD PARTY ASSESSMENT ORGANIZATION (3PAO)

STAFFING REQUIREMENTS
All Penetration Test activities must be performed by a 3PAO that has demonstrated Penetration
Testing proficiency and maintains a defined Penetration Test methodology. The Penetration Test
team lead on each Penetration Test must be approved by the Assessment Organization and either
have an industry-recognized credential for Penetration Testing or equivalent education and
experience. Industry-recognized credentials are identified in Table 17 below.
Table 17. 3PAO Staffing Requirements
Certification Body

Certification

Global Information Assurance

Certification (GIAC)

GWAPT - GIAC Web Application Penetration Tester

GPEN - GIAC Network Penetration Tester
GXPN - GIAC Exploit Researcher and Advanced Penetration
Tester

Offensive Security

OSCP - Offensive Security Certified Professional

OSCE - Offensive Security Certified Expert

International Council of
Electronic Commerce
Consultants (EC-Council)

CEH - Certified Ethical Hacker

LPT - Licensed Penetration Tester

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APPENDIX A: ACRONYMS
Acronym

Meaning

3PAO

Third-Party Assessment Organization

API

Application Program Interface

CSP

Cloud Service Provider

EC-Council

International Council of Electronic Commerce Consultants

FedRAMP

Federal Risk and Authorization Management Program

GIAC

Global Information Assurance Certification

IA

Independent Assessor

IaaS

Infrastructure as a Service

IP

Internet Protocol

ISP

Internet Service Provider

PaaS

Platform as a Service

MSSP

Managed Security Service Provider

NIST

National Institute of Standards and Technology

OSINT

Open Source Intelligence

POC

Point of Contact

PTR

Penetration Test Report

ROE

Rules of Engagement

SaaS

Software as a Service

SAP

Security Assessment Plan

TP

Test Plan

URL

Uniform Resource Identifier

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APPENDIX B: REFERENCES
The publications referenced in this document are available at the following URLs:

https://www.fedramp.gov/files/2015/03/Guide-to-Understanding-FedRAMP-v2.0-4.docx
http://csrc.nist.gov/publications/nistpubs/800-115/SP800-115.pdf
http://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-53r4.pdf
http://dx.doi.org/10.6028/NIST.SP.800-53Ar4
http://csrc.nist.gov/publications/nistpubs/800-145/SP800-145.pdf
https://www.owasp.org/images/5/52/OWASP_Testing_Guide_v4.pdf
https://www.owasp.org/index.php/OWASP_Mobile_Security_Project#tab=Mobile_Security_
Testing
http://www.vulnerabilityassessment.co.uk/Penetration%20Test.html
https://www.owasp.org/index.php/Category:OWASP_Top_Ten_Project
https://azure.microsoft.com/blog/2014/11/11/red-teaming-using-cutting-edge-threatsimulation-to-harden-the-microsoft-enterprise-cloud/

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APPENDIX C: ROE/TEST PLAN TEMPLATE

Rules of Engagement/Test Plan
The Penetration Test Rules of Engagement (ROE) and Test Plan (TP) documents describe the
target systems, scope, constraints, and proper notifications and disclosures of the Penetration
Test. The 3PAO is required to develop the ROE and TP based on the parameters and system
information provided by the CSP.
The ROE and Test Plan document must be developed in accordance with NIST SP 800-115,
Appendix B, and be approved by the Authorizing Official of the CSP prior to testing. The 3PAO
must include a copy of the ROE in the FedRAMP Security Assessment Plan submitted to
FedRAMP.
Penetration Test planning must include or account for the following considerations:

Penetration
o Network penetration
o Wireless network penetration
o Physical penetration
o Social engineering penetration
Affected IP ranges and domains
Acceptable social engineering pretexts
Targeted organizations capabilities and technologies
Investigative tools
Specific testing periods (start and end date/times)
CSP reporting requirements (format, content, media, encryption)

The Penetration Test Plan must describe:

Target locations
Categories of information such as open source intelligence, human intelligence
Type of information such as physical, relationship, logical, electronic, metadata
Gathering techniques such as active, passive, on- and off-location
Pervasiveness
Constraints that do not exploit business relationships (customer, supplier, joint venture, or
teaming partners)

The 3PAO must justify omitting any attack vectors described in Section 3 above in the ROE/Test
Plan and the Penetration Test Report.

System Scope
Provide a description of the boundaries and scope of the cloud service system, along with any
identified supporting services or systems. System scope should account for all IP addresses,
Uniform Resource Identifiers (URLs), devices, components, software, and hardware.

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Assumptions and Limitations

Provide a description of the assumptions, dependencies, and limitations identified that may have
an impact on Penetration Testing activities or results. Include references to local and federal
legal constraints that may be relevant to testing or results. Assumptions also include any assumed
agreement, or access to third party software, systems, or facilities.

Testing Schedule
Provide a schedule that describes testing phases, initiation/completion dates, and allows for
tracking of Penetration Test deliverables.

Testing Methodology
The methodology section will address relevant Penetration Testing activities as described in
Section 5 above.

Relevant Personnel
Provide a list of key personnel involved in the management and execution of the Penetration Test.
The list should include, at a minimum:

System Owner (CSP)

Trusted Agent (CSP)
Penetration Test Team Lead (3PAO)
Penetration Test Team Member(s) (3PAO)
Escalation Points of Contact (CSP and 3PAO)

Incident Response Procedures

Provide a description of the chain of communications and procedures to be followed should an
event requiring incident response intervention be initiated during Penetration Testing.

Evidence Handling Procedures

Provide a description of procedures for transmission and storage of Penetration Test evidence
collected during the course of the assessment.

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