RA-3(3): Dynamic Threat Awareness

RA-3(3): Dynamic Threat Awareness requires you to determine your current cyber threat environment on an ongoing basis and use defined organizational inputs (your “ra-03.03_odp” parameters) to keep risk decisions current. Operationalize it by standing up a repeatable threat-intel intake, triage, and dissemination process that directly feeds risk assessments, control tuning, and executive risk acceptance. ¹

Key takeaways:

• Define “what sources” and “how often” in your RA-3(3) parameters, then run the process continuously. ¹
• Make threat awareness actionable: it must change assessments, priorities, and control settings, not just produce reports. ²
• Keep evidence of operation: inputs received, decisions made, actions taken, and who approved them.

The ra-3(3): dynamic threat awareness requirement is one of those controls that fails quietly: teams may subscribe to threat feeds, hold a monthly “threat briefing,” and still miss the core expectation—your organization must determine the current cyber threat environment on an ongoing basis, using defined inputs, and make that determination operational. ¹

For a CCO, GRC lead, or compliance officer, the fastest path is to treat RA-3(3) as a governance-and-operations requirement, not a tooling project. You need (1) a defined set of threat-awareness inputs (internal and external), (2) a cadence and triggers for re-evaluating the environment, (3) clear decision rights to translate threat changes into risk actions, and (4) durable evidence that the process runs as designed.

This page gives requirement-level implementation guidance you can put into a control procedure immediately: roles, steps, artifacts, audit-ready questions, and a practical execution plan. References are to NIST SP 800-53 Rev. 5 and the OSCAL catalog entry for RA-3(3). ³

Regulatory text

Requirement (excerpt): “Determine the current cyber threat environment on an ongoing basis using {{ insert: param, ra-03.03_odp }}.” ¹

Operator interpretation:

• “Determine” means you must produce an explicit organizational view of the current threat environment (for your sector, tech stack, and active adversary activity), not merely collect intel.
• “On an ongoing basis” means this is a standing operation with recurring review plus event-driven updates when conditions change.
• “Using … ra-03.03_odp” means you must define and follow organization-specific parameters (inputs, sources, methods, and/or frequency) and be able to show auditors what those parameters are and how you adhere to them. ¹

Plain-English requirement interpretation

You need a repeatable process that answers: “What threats matter to us right now?” and proves that the answer is refreshed continuously and used to adjust risk assessments and security priorities.

A good RA-3(3) implementation has three properties:

1. Current: It reflects recent intelligence, telemetry, and business changes (new systems, acquisitions, major releases, critical third parties).
2. Scoped: It is tailored to your crown jewels, attack surface, and dependencies, including third parties that support critical services.
3. Actionable: It produces decisions: patch acceleration, control tuning, additional monitoring, temporary compensating controls, supplier escalation, or executive risk acceptance.

Who it applies to (entity and operational context)

RA-3(3) is most directly applicable to:

• Federal information systems and the programs that operate them. ²
• Contractor systems handling federal data, where NIST SP 800-53 is required by contract, authorization boundary, or inherited control structure. ²

Operationally, it applies wherever your risk decisions can become stale:

• SOC operations (alerting priorities, detection engineering, threat hunting)
• Vulnerability management (prioritization and exceptions)
• Change management (risk sign-off for high-impact changes)
• Incident response readiness (playbook tuning and tabletop scope)
• Third-party risk management (supplier threat exposure and incident notifications)

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

Use the steps below as your RA-3(3) control procedure. Treat “ra-03.03_odp parameters” as a short configuration section at the top of the procedure.

1) Define your RA-3(3) parameters (“ra-03.03_odp”)

Document, approve, and version-control the parameters that govern how you determine the current threat environment. Keep them short and testable:

• Inputs (sources): internal telemetry (SIEM/EDR trends), vulnerability findings, incident reports, helpdesk security tickets; external sources (government advisories, ISAC/ISAO where relevant, key vendors’ security advisories, critical third-party notifications).
• Cadence and triggers: recurring review cadence plus event triggers (e.g., high-severity vendor advisory affecting in-scope assets; confirmed exploitation of a technology you run; material change to critical third party posture).
• Scope: business units, systems, authorization boundary, critical services, and priority third parties.
• Decision outputs: what artifacts you will produce (threat environment summary, risk memo, prioritized actions) and where they flow (risk register, vulnerability backlog, SOC detection backlog). ¹

Control owner: assign one accountable owner (often Security/GRC) with defined contributing roles (SOC, IR, VM, IT Ops, application security, third-party risk).

2) Stand up an “intake → triage → determination” workflow

Build a lightweight operational pipeline:

• Intake: central channel for threat items (ticket queue, case management system, or GRC workflow). Require minimum fields: source, date, affected technologies, suspected relevance, and confidence.
• Triage: daily/regular triage by SOC/VM/AppSec to label items as relevant/not relevant and map to assets.
• Determination: a short, explicit determination statement produced on the defined cadence and after defined triggers, such as:
  • “Active exploitation observed for X; our exposure includes Y; current threat level is elevated for Z services; actions required: A/B/C.” This “determination” is the exam-friendly centerpiece: it shows you are determining the environment, not just collecting intel. ¹

3) Convert determinations into risk actions with owners and due dates

For each “relevant” threat determination, force an action decision:

• Mitigate: patch/mitigation plan, compensating controls, increased monitoring, segmentation changes.
• Monitor: threat hunt, new detection rule, increased logging, supplier attestation request.
• Accept: documented risk acceptance with duration/conditions and an approving authority.

Tie actions to the systems and third parties in scope. Make the linkage explicit: threat item → affected asset/service/third party → action ticket → closure evidence.

4) Feed the outputs into your formal risk assessment and governance

RA-3(3) should update or trigger:

• Risk register entries (new risks, changed likelihood/impact, changed treatment plan)
• Vulnerability prioritization (what moves to the top and why)
• Control effectiveness review (what controls need tuning)
• Executive reporting (material changes, accepted risks, residual risk trends)

A common audit hangup is threat intel sitting in a SOC folder while the risk register remains unchanged. Prevent that by requiring a cross-reference in your risk tooling or GRC record.

5) Prove “ongoing” with recurring operations and QA

Add two operational QA checks:

• Completeness check: confirm required sources were reviewed/ingested for the period.
• Actionability check: confirm relevant determinations resulted in tickets, risk updates, or documented acceptance.

If you use Daydream, configure RA-3(3) as a mapped requirement with a named owner, a standard operating procedure, and recurring evidence tasks (for example: monthly determination memo plus event-triggered determinations), so you can show consistent operation without rebuilding evidence each audit cycle.

Required evidence and artifacts to retain

Auditors typically want to see both the design and proof of operation. Maintain:

• RA-3(3) procedure including “ra-03.03_odp” parameters (sources, cadence, triggers, scope, outputs). ¹
• Threat intake log (tickets/cases) with triage disposition and asset mapping.
• Threat environment determinations (periodic memo/record) with date, author, approver, and summary of current environment.
• Action records linked to determinations: patch/mitigation tickets, SOC detection changes, risk register updates, third-party follow-ups.
• Meeting notes/briefings where determinations were reviewed (security governance, change advisory, risk committee).
• Exception/risk acceptance records when you decide not to act immediately.

Practical tip: retain a “traceability bundle” for a handful of high-signal events (a major advisory, a third-party incident notification, a new exploitation campaign) that shows end-to-end handling.

Common exam/audit questions and hangups

Expect these questions and pre-answer them in your artifacts:

1. “What are your defined inputs for RA-3(3)?” Show the ra-03.03_odp parameters and evidence that sources are actually monitored. ¹
2. “How do you decide what is relevant to your environment?” Provide triage criteria and asset mapping logic.
3. “Show that this is ongoing.” Provide a series of periodic determinations and event-triggered determinations across time.
4. “What changed because of threat awareness?” Demonstrate actions taken: reprioritized vulnerabilities, new detections, compensating controls, supplier escalations.
5. “Who has authority to accept risk?” Show approval routing and decision rights.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails RA-3(3)	Fix
Subscribing to feeds but no written determination	Collection ≠ determining the environment	Produce a dated determination record that states threat conditions and relevance. 1
No defined parameters (sources/cadence)	“ra-03.03_odp” is undefined in practice	Document parameters in the procedure and get governance approval. 1
SOC-only activity	Threat awareness doesn’t reach risk governance	Require risk register updates or a “no change” statement tied to each determination.
No linkage to third parties	You miss supplier-driven threat shifts	Add critical third-party notifications and key vendor advisories as required inputs.
Actions taken but not evidenced	Auditors grade what you can prove	Store tickets, change records, and approvals linked to the determination.

Risk implications (why operators get burned)

Dynamic threat awareness is a control that connects intelligence to governance. If you cannot show this connection, your program can look performative: “we had the information” but did not translate it into changed priorities or mitigations. The most common failure mode is evidence: teams do real work during high-profile events, but the record of decision-making is scattered across email, chat, and incident bridges. RA-3(3) expects an auditable operational loop. ²

Practical 30/60/90-day execution plan

First 30 days (stand up the control)

• Assign control owner and RACI (SOC, VM, IR, AppSec, third-party risk, IT Ops).
• Draft ra-03.03_odp parameters: required sources, cadence, triggers, scope, outputs. ¹
• Implement the intake mechanism (ticket queue/case type) and minimum required fields.
• Produce your first threat environment determination and route it for approval.

Days 31–60 (make it operational and auditable)

• Run the recurring determination cycle and capture artifacts.
• Build the traceability chain: determination → actions → closures.
• Add a governance touchpoint (risk committee readout or security steering committee agenda item).
• Pilot with one high-value scope (critical service + its key third parties) and expand.

Days 61–90 (prove maturity and reduce audit friction)

• Add QA checks (source completeness; actionability).
• Tune triage criteria based on false positives/irrelevant items.
• Formalize reporting: a stable template for determinations, plus a dashboard view for leadership.
• In Daydream, map RA-3(3) to the owner, procedure, and recurring evidence tasks so evidence collection becomes routine rather than a scramble.

Frequently Asked Questions

What counts as “ongoing” for RA-3(3)?

“Ongoing” means you have a defined recurring process plus event-driven updates when threat conditions change. Prove it with a series of dated determinations and trigger-based determinations tied to specific events. ¹

Do we need a dedicated threat intelligence team to satisfy RA-3(3)?

No. You need defined inputs, triage, a determination record, and downstream actions. Many organizations run RA-3(3) with a small virtual team across SOC, vulnerability management, and GRC.

How do we document the “ra-03.03_odp” part without overengineering it?

Put it at the top of your RA-3(3) procedure as a short “parameters” section: required sources, cadence, triggers, scope, and required outputs. Then keep evidence that you followed those parameters. ¹

What evidence is strongest for auditors?

A time-ordered set of determination records plus tickets showing mitigations, detection changes, and risk register updates linked back to those determinations. The linkage is usually more persuasive than long narrative reports.

How does RA-3(3) connect to third-party risk management?

Your current threat environment changes when critical third parties report incidents, publish urgent advisories, or become newly exposed. Make those inputs explicit, and create action paths like supplier escalation, compensating controls, or contractual notification follow-ups.

We already do vulnerability management. Is that enough?

Vulnerability management is an input and an action channel, but RA-3(3) requires an explicit determination of the current threat environment using defined parameters. VM data alone rarely shows you performed that determination step. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5

3. NIST SP 800-53 Rev. 5; NIST SP 800-53 Rev. 5 OSCAL JSON