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Coast Guard MTSA Regulation Compliance Preparation

Cybersecurity Assessment & Gap Analysis

 (Aligned with §§ 101.650, 101.655) 


Regulatory Gap Assessment


  • Evaluate current cybersecurity posture against Subpart F requirements
  • Map existing controls to USCG regulatory expectations
  • Identify compliance gaps and risk areas
     

Cyber Risk Assessment


  • Identify critical operational technology (OT) and IT systems
  • Conduct threat modeling specific to maritime environments
  • Evaluate vulnerabilities affecting:

                            Navigation systems

                            Cargo handling systems

                            Industrial control systems (ICS/SCADA)

                            Communications systems

  • Document risk findings in a format suitable for USCG review

Cybersecurity Plan Development

 (Aligned with § 101.650 )


Develop or Update the Cybersecurity Plan (CSP)


  • Draft a compliant Cybersecurity Plan for submission to USCG
  • Define:
           Cybersecurity Officer roles and responsibilities
           System inventory and critical cyber systems

                            Security controls and safeguards
                           Incident response procedures
                           Ensure integration with the Facility Security Plan (FSP) or Vessel Security Plan (VSP)
 

Documentation & Recordkeeping Framework


  • Create required documentation templates
  • Establish procedures for maintaining compliance records
  • Prepare documentation for inspections and audits

Designation & Support of Cybersecurity Officer (CySO)

 (Aligned with § 101.655) 


  • Help define the Cybersecurity Officer role
  • Develop CySO responsibilities matrix
  • Provide virtual/outsourced Cybersecurity Officer services
  • Train internal personnel to fulfill CySO responsibilities

Technical Safeguards & Security Control Implementation

 (Aligned with § 101.660 )


Access Controls


  • Role-based access control (RBAC)
  • Multi-factor authentication (MFA)
  • Privileged access management (PAM)
     

Network Security


  • IT/OT network segmentation
  • Firewalls and maritime-grade network architecture
  • Secure remote access controls
  • Wireless network hardening
     

System Hardening


  • Secure configuration baselines
  • Patch management programs
  • Endpoint protection deployment 
  • USB and removable media controls
     

Monitoring & Logging


  • Security Information and Event Management (SIEM)
  • Log aggregation and retention
  • Intrusion detection systems (IDS/IPS)
  • OT monitoring solutions

Incident Response & Reporting

(Aligned with § 101.665)


Incident Response Plan Development


  • Create maritime-specific cyber incident response procedures
  • Define escalation paths and communication protocols
  • Integrate with physical security and safety procedures
     

Regulatory Reporting Readiness


  • Prepare procedures for reporting cyber incidents to:

                            National Response Center (NRC)

                            U.S. Coast Guard

  • Develop reporting templates
  • Conduct tabletop exercises simulating reportable events
     

Digital Forensics & Recovery


  • Incident investigation support
  • Evidence preservation procedures
  • Recovery and business continuity planning

Training & Drills

 (Aligned with § 101.670)


Workforce Cybersecurity Training


  • Role-based training (crew, operators, executives)
  • Phishing awareness programs
  • OT-specific cybersecurity training
     

Drills & Exercises


  • Cybersecurity tabletop exercises
  • Red team / blue team simulations
  • Incident response drills
  • USCG inspection preparedness exercises

Supply Chain & Third-Party Risk Management

  • Assess vendor cybersecurity posture
  • Implement third-party risk management programs
  • Secure remote vendor access
  • Review contracts for cybersecurity requirements
  • Conduct risk reviews for maritime technology vendors

Continuous Monitoring & Compliance Maintenance

  • Managed Detection & Response (MDR)
  • Continuous vulnerability scanning
  • Compliance monitoring dashboards
  • Periodic internal audits
  • Preparation for Coast Guard inspections

Governance & Policy Development

  • Cybersecurity governance frameworks
  • Board-level cybersecurity reporting
  • Risk management frameworks aligned to:

                           NIST Cybersecurity Framework

                           NIST SP 800-82 (ICS security)

  • Policy harmonization across multiple regulated facilities

OT / Maritime-Specific Security Architecture

  • Secure bridge systems
  • Cargo control system protection
  • Port automation security
  • SCADA hardening
  • Secure satellite communications
  • Resilient backup navigation systems

Audit & Inspection Readiness

  • Conduct mock USCG inspections
  • Prepare inspection response packages
  • Review documentation completeness
  • Provide corrective action plans
  • Support interactions with Coast Guard inspectors

Program Maturity Roadmap

  • Develop a multi-year cybersecurity improvement roadmap
  • Align compliance with operational resilience
  • Integrate cyber risk into enterprise risk management
  • Support cyber insurance underwriting readiness

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  • 33 CFR Part 101 Subpart F
  • NIST
  • HIPAA
  • SOC
  • PCI
  • CMMC

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