PM-16: Threat Awareness Program

To meet the pm-16: threat awareness program requirement, you must run a formal threat awareness program that continuously collects, analyzes, and disseminates threat intelligence, including a cross-organization information-sharing capability. Operationalize it by assigning ownership, defining intake-to-action workflows, integrating intel into security operations, and retaining evidence of sharing, dissemination, and resulting actions. ¹

Key takeaways:

• PM-16 requires an active program, not an ad hoc “threat feed” subscription. ¹
• You need two motions: internal awareness distribution and cross-organization threat intel sharing. ¹
• Evidence must show intel flows into decisions: tickets, detections, blocking, patching, and executive reporting. ¹

PM-16 sits in the NIST SP 800-53 Program Management (PM) family, which means assessors expect structure: named owners, defined processes, and repeatable outputs that can be audited. The control text is short, but the operational scope is real. “Threat awareness” is not limited to employee training, and it is not satisfied by buying a threat intel tool alone. You need a program that turns threat intelligence into action across teams, plus a defined way to share relevant threat information across organizational boundaries. ¹

For a CCO, GRC lead, or security compliance owner, the fastest path is to treat PM-16 like a governance-backed service: inputs (intel sources), processing (triage and validation), outputs (alerts, advisories, detections, remediation tasks), and external exchange (sharing mechanisms and rules of engagement). Examiners will focus on whether the capability exists, whether it is used, and whether it measurably drives operational decisions in security operations and risk management. ²

Regulatory text

Requirement (PM-16): “Implement a threat awareness program that includes a cross-organization information-sharing capability for threat intelligence.” ¹

What the operator must do:

1. Implement a threat awareness program: establish a defined, repeatable program that gathers and communicates threat intelligence to relevant internal stakeholders. ¹
2. Include cross-organization information sharing: build a capability to share threat intelligence with external organizations (as appropriate for your environment) and to receive and operationalize information from those sources. ¹

Plain-English interpretation

PM-16 requires you to run an organized “threat intel to action” loop. You must (a) stay aware of relevant threats, (b) distribute that awareness internally so teams can act, and (c) participate in structured sharing beyond your organization so you are not operating in isolation. The control is satisfied when you can show consistent intel intake, internal dissemination, and external sharing, plus evidence that intel changed what you did (detections, blocks, patches, access changes, third-party actions). ¹

Who it applies to

PM-16 is commonly expected in environments aligning to NIST SP 800-53, including:

• Federal information systems operated by agencies or on their behalf.
• Contractor systems handling federal data, including cloud and SaaS environments supporting federal workloads. ¹

Operationally, PM-16 matters most where you have:

• A SOC or security operations function (internal or outsourced)
• Centralized IT operations or vulnerability management
• A third-party ecosystem where threat intel triggers vendor notifications, blocking, or additional monitoring

What you actually need to do (step-by-step)

1) Assign ownership and define the program boundary

• Name a control owner (often the SOC manager, Threat Intel lead, or CISO delegate) and a GRC accountability owner who ensures evidence is collected.
• Define which parts of the organization the program covers: corporate IT, production, cloud, endpoints, identity, and critical third parties.
• Document a RACI: who ingests intel, who approves dissemination, who opens tickets, who updates detections, who communicates externally.

Deliverable: Threat Awareness Program Charter (1–3 pages) mapped to PM-16. ¹

2) Stand up intel intake sources (internal and external)

Create an “approved sources” register with:

• Internal sources: incident learnings, SIEM signals, EDR alerts, phishing reports, vulnerability scans.
• External sources: government/industry advisories, commercial intel providers, ISAC/ISAO-style communities if applicable, key third-party security notifications, and peer sharing channels.

You do not need a perfect list on day one. You need a controlled, reviewable set that the program actually checks.

Deliverables: Threat Intel Source Register; access records to subscriptions/portals.

3) Define the triage-to-action workflow

Write a procedure that answers:

• Who triages new intel and how often
• How you validate relevance (affected technologies, business exposure, confidence)
• What “actionable” means in your environment (e.g., new detection rule, blocklist update, patch request, vendor outreach)
• How you track work (ticketing system, case management, change control)

A simple workflow that runs consistently beats an elaborate playbook no one follows.

Deliverables: SOP/work instruction; ticket templates; severity and routing criteria.

4) Build internal threat awareness distribution

Define at least three distribution paths:

• Real-time/near-real-time operational alerts to SOC/IT (e.g., critical IOCs, active exploitation notes)
• Periodic threat brief to security/IT leadership (what changed, what was done, open risks)
• Targeted advisories to business units (e.g., fraud, exec protection, high-risk travel, phishing themes)

Make dissemination measurable: store the advisory, the recipients group, and the downstream tasks created.

Deliverables: Internal advisory examples; mailing list or collaboration channel membership; leadership brief.

5) Implement cross-organization sharing capability (the part teams miss)

PM-16 explicitly requires cross-organization sharing capability for threat intelligence. ¹

Operationalize with:

• Sharing mechanisms: defined channels (secure email lists, portal postings, community platform, structured intel platform if you have it).
• Rules of engagement: what can be shared, who approves, how to sanitize sensitive data, and retention.
• Outbound sharing triggers: when you share (e.g., confirmed malicious infrastructure impacting peers, supply chain indicator relevant to customers/partners, coordinated vulnerability exploitation patterns).

If your legal/privacy constraints limit sharing, document the constraints and show the sharing you can do (sanitized indicators, aggregate trends, de-identified TTPs).

Deliverables: External sharing SOP; approval workflow; examples of outbound shares; participation evidence.

6) Connect intel to operational controls (prove it changes behavior)

Assessors will ask, “So what?” Your evidence should show intel drove action such as:

• New SIEM detections or correlation rules
• EDR blocklists or quarantine actions
• Patch/vulnerability remediation prioritization
• Identity hardening (conditional access changes, MFA enforcement for targeted groups)
• Third-party notifications and required mitigations

Deliverables: Change tickets; detection rule commits; firewall/proxy changes; vuln exceptions tied to intel; third-party communications.

7) Map PM-16 to evidence artifacts and a recurring cadence

Turn PM-16 into an assessable control by mapping:

• Owner
• Procedure
• Systems in scope
• Evidence produced per cycle (advisories, tickets, sharing logs)

Daydream fits naturally here as a control-to-evidence system of record: you map PM-16 to the owner, implementation procedure, and recurring evidence artifacts, then track collection so you are ready for assessment without scrambling. ¹

Required evidence and artifacts to retain

Use this as your audit evidence checklist:

Evidence type	What it should show	Examples
Program governance	Ownership and defined process	Charter, RACI, SOP mapped to PM-16
Intel source inventory	Repeatable intake capability	Source register, subscription access, portal membership
Triage records	Intake to decision trail	Triage logs, case notes, “not relevant” rationale
Internal dissemination	Threat awareness distribution	Advisories, distribution lists, leadership brief decks
Cross-organization sharing	Capability and actual use	Sharing SOP, approval records, outbound sharing examples
Operational actions	Intel drove changes	Tickets, detections, change control records
Review/lessons learned	Program improvement loop	After-action notes, backlog grooming notes

Common exam/audit questions and hangups

• “Show me how threat intelligence enters your organization and who reviews it.”
• “What is your cross-organization information sharing mechanism? Show use, not just policy.” ¹
• “Give examples where threat intel resulted in a control change.”
• “How do you prevent oversharing sensitive data externally?”
• “Is the program consistent across business units, cloud, and third parties in scope?”

Typical hangup: teams can show inbound subscriptions but cannot show outbound sharing, approvals, or any record that intel changed security posture.

Frequent implementation mistakes and how to avoid them

1. Mistake: Treating PM-16 as security awareness training.
   Fix: keep “threat awareness” focused on threat intelligence dissemination and operational action; training can be a consumer of intel, but it is not the control.

2. Mistake: No cross-organization sharing evidence.
   Fix: document at least one approved channel and produce real outbound shares (sanitized if needed). ¹

3. Mistake: Intel exists in email, not in systems of record.
   Fix: force intel actions through tickets or case management with clear linkage to the intel item.

4. Mistake: Overcollection, no prioritization.
   Fix: define relevance criteria tied to your tech stack and crown-jewel services; record “ignored” items with a short rationale.

5. Mistake: The program lives only in SOC tooling.
   Fix: build a governance wrapper (charter, cadence, evidence map) so GRC can attest to operation during audits.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for PM-16, so this page does not cite specific enforcement outcomes. Practically, PM-16 gaps increase the chance you miss timely warnings about active exploitation, supply chain activity, or sector-specific targeting, and they make it harder to defend security “reasonable practices” during incident reviews because you cannot show a disciplined intake-to-action loop. ²

A practical 30/60/90-day execution plan

First 30 days (Immediate)

• Assign PM-16 owners (security + GRC) and approve the program charter.
• Create the intel source register and confirm access paths.
• Publish the triage SOP and a ticket template.
• Stand up one internal distribution channel (SOC/IT ops) and one leadership brief format.
• Define your external sharing channel and approval rules. ¹

By 60 days (Near-term)

• Run the workflow consistently and generate repeatable evidence: triage records, advisories, and action tickets.
• Produce at least one outbound sharing example (sanitized if needed) plus the approval record. ¹
• Tie intel to detections and vulnerability remediation with traceable tickets.

By 90 days (Stabilize and prepare for assessment)

• Add metrics that help operations (backlog, time-to-triage, action completion status). Keep them simple and defensible.
• Formalize a periodic review meeting and document improvements.
• Store evidence in a single place and map artifacts to PM-16 (Daydream or your GRC system), so audit response is exportable and consistent. ¹

Frequently Asked Questions

Does buying a threat intelligence feed satisfy the pm-16: threat awareness program requirement?

No. PM-16 expects a program with defined processes and evidence of internal dissemination and cross-organization sharing capability. A feed can be one input, but you still need triage, distribution, and action records. ¹

What counts as “cross-organization information sharing”?

A documented capability to exchange threat intelligence outside your organization through approved channels, with rules for what you share and proof that sharing occurs. Keep samples of outbound shares and approvals. ¹

We cannot share much externally due to confidentiality. How do we comply?

Document the constraint, implement sanitization and approval steps, and share what you can (e.g., de-identified indicators or generalized TTPs). Auditors want to see an established capability and governed execution. ¹

Who should own PM-16: SOC, CISO, or GRC?

Make security operations the operational owner because they can execute intake-to-action. Make GRC the accountability partner to ensure procedures exist and evidence is retained for assessment.

What evidence is most persuasive in an audit?

A clear trail from intel item → triage decision → internal advisory → ticket/change/detection update, plus a record of cross-organization sharing. Policies alone rarely satisfy assessors. ¹

How do we operationalize PM-16 across third parties?

Treat third-party security notifications and advisories as intel sources, then build triggers for outreach and required mitigations. Retain communications and track resulting actions in your ticketing system.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5