Together with Nate Kim (former student) and Trey Herr (Atlantic Council Cyber Statecraft Initiative), I have written a paper on IoT supply chain security. The basic problem we try to solve is: how to you enforce IoT security regulations when most of the stuff is made in other countries? And our solution is: enforce the regulations on the domestic company that’s selling the stuff to consumers. There’s a lot of detail between here and there, though, and it’s all in the paper.
We also wrote a Lawfare post:
…we propose to leverage these supply chains as part of the solution. Selling to U.S. consumers generally requires that IoT manufacturers sell through a U.S. subsidiary or, more commonly, a domestic distributor like Best Buy or Amazon. The Federal Trade Commission can apply regulatory pressure to this distributor to sell only products that meet the requirements of a security framework developed by U.S. cybersecurity agencies. That would put pressure on manufacturers to make sure their products are compliant with the standards set out in this security framework, including pressuring their component vendors and original device manufacturers to make sure they supply parts that meet the recognized security framework.