Countering cyber proliferation: Zeroing in on Access-as-a-Service Report by Winnona DeSombre, James Shires, JD Work, Robert Morgus, Patrick Howell O’Neill, Luca Allodi, and Trey Herr Executive summary The proliferation of offensive cyber capabilities (OCC)—the combination of tools; vulnerabilities; and skills, including technical, organizational, and individual capacities used to conduct offensive cyber operations—presents an expanding set of risks to states and challenges commitments to protect openness, security, and stability in cyberspace. As these capabilities become more prolific, their regulation through formal international norms and export controls is increasingly ineffective. Countering the spread of dangerous capabilities is not a new policy challenge, but its specific application to the cyber domain remains uncertain both in theory and in practice. Left unchecked, the continued proliferation of offensive capabilities could significantly damage the global economy, international security, and the values that the United States and its allies hold dear. Thus, it is imperative that governments reevaluate their approach to countering the proliferation of OCC. This report profiles the “Access-as-a-Service” (AaaS) industry, a significant vector for the proliferation of OCC, as a means of both illustrating the character of this proliferation and investigating policies to counter it.