Level 3 Assessment Guide: Difference between revisions

From CMMC Toolkit Wiki
Jump to navigation Jump to search
Importing content from PDF File: https://dodcio.defense.gov/Portals/0/Documents/CMMC/AssessmentGuideL3v2.pdf
 
 
(25 intermediate revisions by 2 users not shown)
Line 1: Line 1:
'''Source of Reference: The official [https://dodcio.defense.gov/CMMC/Resources-Documentation/ CMMC Level 3 Assessment Guide Version 2.13, September 2024] from the Department of Defense Chief Information Officer (DoD CIO).'''


For inquiries and reporting errors on this wiki, please [mailto:support@cmmctoolkit.org contact us]. Thank you.


 
== NOTICES ==
 
The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing CMMC requirements under the law or departmental policies.
 
'''CMMC Assessment Guide '''
 
'''Level 3 '''
 
Version 2.13 | September 2024
 
DoD-CIO-00004 (ZRIN 0790-ZA20)
 
24-T-2767
 
 
 
 
 
 
 
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
ii
 
NOTICES <br />
The contents of this document do not have the force and effect of law and are not meant to  
 
bind the public in any way. This document is intended only to provide clarity to the public  
 
regarding existing CMMC requirements under the law or departmental policies.  


DISTRIBUTION STATEMENT A. Approved for public release. Distribution is unlimited.
DISTRIBUTION STATEMENT A. Approved for public release. Distribution is unlimited.


== Introduction ==
This document provides guidance in the preparation for and conduct of a Level 3 certification assessment under the Cybersecurity Maturity Model Certification (CMMC) Program as set forth in section 170.18 of title 32, Code of Federal Regulations (CFR). Certification at each CMMC level occurs independently. Guidance for conducting a Level 1 self-assessment can be found in ''CMMC Assessment Guide – Level 1''. Guidance for conducting both a Level 2 self-assessment and Level 2 certification assessment, can be found in ''CMMC Assessment Guide – Level 2''. More details on the model can be found in the ''CMMC Model Overview'' document.


An ''Assessment'' as defined in 32 CFR § 170.4 means the testing or evaluation of security controls to determine the extent to which the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for an information system, or organization as defined in 32 CFR § 170.15 to 32 CFR § 170.18''. A ''Level 3 certification assessment'' as defined in 32 CFR § 170.4 is ''the activity performed by the Department of Defense (DoD) to evaluate the CMMC level of an Organization Seeking Certification (OSC)''. For Level 3, assessments are conducted exclusively by the DCMA DIBCAC.


An OSC seeking a Level 3 certification assessment must have first achieved a CMMC Status of Final Level 2 (C3PAO), as set forth in 32 CFR § 170.18(a), for all applicable information systems within the CMMC Assessment Scope, and the OSC must implement the Level 3 requirements specified in 32 CFR § 170.14(c)(4). This is followed by the Level 3 certification assessment conducted by the DCMA DIBCAC.


OSCs may also use this guide to perform Level 3 self-assessments (for example, in preparation for an annual affirmation); however, they are not eligible to submit results from a self-assessment in support of a Level 3 certification assessment. Only the results from an assessment by DCMA DIBCAC are considered for award of the CMMC Statuses Conditional Level 3 (DIBCAC) or Final Level 3 (DIBCAC). Level 3 reporting and affirmation requirements can be found in 32 CFR § 170.18 and 32 CFR § 170.22.


=== Level 3 Description ===
Level 3 consists of selected security requirements derived from National Institute of Standards and Technology (NIST) Special Publication (SP) 800-172, ''Enhanced Security Requirements for Protecting Controlled Unclassified Information: A Supplement to NIST Special Publication 800-171'', with DoD-approved parameters where applicable. Level 3 only applies to systems that have already achieved a Final Level 2 (C3PAO) CMMC Status. Level 2 consists of the security requirements specified in NIST SP 800-171, ''Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations''.


Like Level 2, Level 3 addresses the protection of Controlled Unclassified Information (CUI), as defined in 32 CFR § 2002.4(h):


: ''Information the Government creates or possesses, or that an entity creates or possesses for or on behalf of the Government, that a law, regulation, or Government-wide policy requires or permits an agency to handle using safeguarding or dissemination controls. However, CUI does not include classified information (see paragraph (e) of this section) or information a non-executive branch entity possesses and maintains in its own systems that did not come from, or was not created or possessed by or for, an executive branch agency or an entity acting for an agency. Law, regulation, or Government-wide policy may require or permit safeguarding or dissemination controls in three ways: Requiring or permitting agencies to control or protect the information but providing no specific controls, which makes the information CUI Basic; requiring or permitting agencies to control or protect the information and providing specific controls for doing so, which makes the information CUI Specified; or requiring or permitting agencies to control the information and specifying only some of those controls, which makes the information CUI Specified, but with CUI Basic controls where the authority does not specify.''


Level 3 provides additional protections against advanced persistent threats (APTs), and increased assurance to the DoD that an OSC can adequately protect CUI at a level commensurate with the adversarial risk, to include protecting information flow with the government and with subcontractors in a multitier supply chain.
 
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
iii
 
 
TABLE OF CONTENTS
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#5|'''Introduction ............................................................................................................................................. 1 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#5|CMMC Level 3 Description ................................................................................................................................ 1 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#6|Purpose and Audience ........................................................................................................................................ 2 <br />
Document Organization ..................................................................................................................................... 2 ]]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#8|'''Assessment and Certification ............................................................................................................ 4 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#8|Assessment Scope................................................................................................................................................. 4 ]]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#9|'''CMMC-Custom Terms ............................................................................................................................ 5 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#12|'''Assessment Criteria and Methodology ........................................................................................... 8 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#13|Criteria ....................................................................................................................................................................... 9 <br />
Methodology ........................................................................................................................................................... 9 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#14|Who Is Interviewed ........................................................................................................................................... 10 <br />
What Is Examined ............................................................................................................................................... 10 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#15|What Is Tested ..................................................................................................................................................... 11 <br />
Assessment Findings ......................................................................................................................................... 11 ]]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#17|'''Requirement Descriptions ............................................................................................................... 13 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#19|'''Access Control (AC) ............................................................................................................................ 15 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#19|AC.L3-3.1.2e – Organizationally Controlled Assets ............................................................................................. 15 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#21|AC.L3-3.1.3e – Secured Information Transfer ....................................................................................................... 17 ]]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#24|'''Awareness and Training (AT) ......................................................................................................... 20 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#24|AT.L3-3.2.1e – Advanced Threat Awareness ......................................................................................................... 20 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#26|AT.L3-3.2.2e – Practical Training Exercises ........................................................................................................... 22 ]]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#29|'''Configuration Management (CM) .................................................................................................. 25 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#29|CM.L3-3.4.1e – Authoritative Repository ................................................................................................................ 25 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#32|CM.L3-3.4.2e – Automated Detection &amp; Remediation ........................................................................................ 28 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#35|CM.L3-3.4.3e – Automated Inventory ....................................................................................................................... 31 ]]
 
 
 
 
 
 
 
 
 
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
iv
 
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#38|'''Identification and Authentication (IA) ........................................................................................ 34 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#38|IA.L3-3.5.1e – Bidirectional Authentication ........................................................................................................... 34 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#41|IA.L3-3.5.3e – Block Untrusted Assets ...................................................................................................................... 37 ]]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#44|'''Incident Response (IR) ...................................................................................................................... 40 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#44|IR.L3-3.6.1e – Security Operations Center .............................................................................................................. 40 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#47|IR.L3-3.6.2e – Cyber Incident Response Team ...................................................................................................... 43 ]]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#50|'''Personnel Security (PS) .................................................................................................................... 46 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#50|PS.L3-3.9.2e – Adverse Information .......................................................................................................................... 46 ]]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#52|'''Risk Assessment (RA) ........................................................................................................................ 48 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#52|RA.L3-3.11.1e – Threat-Informed Risk Assessment ........................................................................................... 48 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#55|RA.L3-3.11.2e – Threat Hunting .................................................................................................................................. 51 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#58|RA.L3-3.11.3e – Advanced Risk Identification ...................................................................................................... 54 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#61|RA.L3-3.11.4e – Security Solution Rationale .......................................................................................................... 57 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#64|RA.L3-3.11.5e – Security Solution Effectiveness .................................................................................................. 60 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#67|RA.L3-3.11.6e – Supply Chain Risk Response ........................................................................................................ 63 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#69|RA.L3-3.11.7e – Supply Chain Risk Plan .................................................................................................................. 65 ]]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#71|'''Security Assessment (CA) ................................................................................................................. 67 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#71|CA.L3-3.12.1e – Penetration Testing ......................................................................................................................... 67 ]]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#74|'''System and Communications Protection (SC) ........................................................................... 70 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#74|SC.L3-3.13.4e – isolation ................................................................................................................................................. 70 ]]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#77|'''System and Information Integrity (SI) ......................................................................................... 73 ''']]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#77|SI.L3-3.14.1e – Integrity Verification ........................................................................................................................ 73 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#81|SI.L3-3.14.3e – Specialized Asset Security .............................................................................................................. 77 <br />
]][[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#84|SI.L3-3.14.6e – Threat-Guided Intrusion Detection ............................................................................................ 80 ]]
 
[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#87|'''Appendix A – Acronyms and Abbreviations .............................................................................. 83 ''']]
 
 
 
 
 
 
 
 
 
 
 
Introduction
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
1
 
''' '''
 
Introduction <br />
This document provides guidance in the preparation for and conduct of a Level 3 certification
 
assessment under the Cybersecurity Maturity Model Certification (CMMC) Program as set
 
forth in section 170.18 of title 32, Code of Federal Regulations (CFR). Certification at each
 
CMMC level occurs independently. Guidance for conducting a Level 1 self-assessment can be
 
found in ''CMMC Assessment Guide  –  Level 1''. Guidance for conducting both  a  Level 2 self-
 
assessment and Level 2 certification assessment, can be found in ''CMMC Assessment Guide – ''
 
''Level 2''. More details on the model can be found in the ''CMMC Model Overview'' document. <br />
An ''Assessment'' as defined in 32 CFR § 170.4 means t''he testing or evaluation of security controls ''
 
''to determine the extent to which the controls are implemented correctly, operating as intended, ''
 
''and producing the desired outcome with respect to meeting the security requirements for an ''
 
''information system, or organization as defined in 32 CFR § 170.15 to 32 CFR § 170.18''. A ''Level ''
 
''3  certification  assessment''  as defined in  32  CFR  § 170.4  is t''he activity performed by the ''
 
''Department of Defense (DoD)  to evaluate the CMMC level of an Organization Seeking ''
 
''Certification (OSC)''. For Level 3, assessments are conducted exclusively by the DCMA DIBCAC. <br />
An OSC seeking a Level 3 certification assessment must have first achieved a CMMC Status of
 
Final  Level 2 (C3PAO), as set forth  in  32  CFR  § 170.18(a),  for all applicable information
 
systems  within the CMMC Assessment  Scope,  and  the OSC must implement the Level 3
 
requirements specified in 32 CFR § 170.14(c)(4). This is followed by the Level 3 certification
 
assessment conducted by the DCMA DIBCAC. <br />
OSCs  may also use this guide to perform Level  3  self-assessments  (for example, in
 
preparation for an annual affirmation); however, they are not eligible to submit results from
 
a self-assessment in support of a Level 3 certification assessment. Only the results from an
 
assessment by DCMA DIBCAC are considered for award of the CMMC Statuses Conditional
 
Level 3 (DIBCAC) or Final Level 3 (DIBCAC). Level 3 reporting and affirmation requirements
 
can be found in 32 CFR § 170.18 and 32 CFR § 170.22.
 
Level 3 Description
 
Level  3  consists of selected  security requirements derived from  National Institute of
 
Standards and Technology (NIST) Special Publication (SP) 800-172,  ''Enhanced Security ''
 
''Requirements for Protecting Controlled Unclassified Information: A Supplement to NIST ''
 
''Special Publication 800-171'', with DoD-approved parameters where applicable. Level 3 only
 
applies to systems that have already achieved a Final Level 2 (C3PAO) CMMC Status. Level 2
 
consists of the security requirements specified in NIST SP 800-171, ''Protecting Controlled ''
 
''Unclassified Information in Nonfederal Systems and Organizations''.
 
 
 
 
 
 
 
 
 
Introduction
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
2
 
''' '''
 
Like Level 2, Level 3 addresses the protection of Controlled Unclassified Information (CUI), as
 
defined in 32 CFR § 2002.4(h):
 
''Information the Government creates or possesses, or that an entity creates or ''
 
''possesses for or on behalf of the Government, that a law, regulation, or ''
 
''Government-wide policy requires or permits an agency to handle using ''
 
''safeguarding or dissemination controls. However, CUI does not include classified ''
 
''information (see paragraph (e) of this section) or information a non-executive ''
 
''branch entity possesses and maintains in its own systems that did not come from, ''
 
''or was not created or possessed by or for, an executive branch agency or an entity ''
 
''acting for an agency. Law, regulation, or Government-wide policy may require ''
 
''or permit safeguarding or dissemination controls in three ways: Requiring or ''
 
''permitting agencies to control or protect the information but providing no ''
 
''specific controls, which makes the information CUI Basic; requiring or ''
 
''permitting agencies to control or protect the information and providing specific ''
 
''controls for doing so, which makes the information CUI Specified; or requiring or ''
 
''permitting agencies to control the information and specifying only some of those ''
 
''controls, which makes the information CUI Specified, but with CUI Basic controls ''
 
''where the authority does not specify. ''
 
Level  3  provides  additional protections against advanced persistent threats (APTs), and  
 
increased assurance to the DoD that an OSC can adequately protect CUI at a level  
 
commensurate with the adversarial risk, to include protecting information flow with the  
 
government and with subcontractors in a multitier supply chain.  
 
Purpose and Audience
 
This guide is intended for assessors, OSCs, cybersecurity professionals, and individuals and
 
companies that support CMMC efforts. This document can be used as part of preparation for
 
and conducting a Level 3 certification assessment.
 
Document Organization
 
This document is organized into the following sections: <br />
 
  '''Assessment and Certification:''  '''''provides an overview of the Level 3  assessment
 
processes  set forth in 32 CFR § 170.18.  It provides guidance regarding  the scope
 
requirements set forth in 32 CFR § 170.19(d).
 
 
  '''CMMC-Custom Terms:'''  incorporates definitions from 32 CFR  §  170.4, definitions
 
included by reference from 32 CFR § 170.2, and provides clarification of the intent and
 
scope of specific terms as used in the context of CMMC.
 
 
  '''Assessment Criteria and Methodology:  '''provides guidance on the criteria and
 
methodology (i.e., ''interview'',  ''examine'', and ''test'')  to be employed  during a Level 3
 
assessment, as well as on assessment findings.
 
 
 
 
 
 
 
 
 
Introduction
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
3
 
''' '''
 
 
  '''Requirement Descriptions: '''Provides  guidance  specific to  each  Level  3  security
 
requirement.
 
 
 
 
 
 
 
 
 
Assessment and Certification
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
4
 
''' '''
 
Assessment and Certification <br />
The DCMA DIBCAC will use the assessment methods defined in NIST SP 800-172A[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#8|1, ]]''Assessing ''
 
''Enhanced Security Requirements for Controlled Unclassified Information'',  along with the
 
supplemental information in this guide to conduct Level 3  certification  assessments.
 
Assessors  will review information and evidence to  verify that an  OSC  meets  the stated
 
assessment objectives for all of the requirements. <br />
An OSC can obtain a Level 3 certification assessment for an entire enterprise network or for
 
specific enclave(s), depending on how the CMMC Assessment Scope is defined in accordance
 
with 32 CFR § 170.19(d).
 
Assessment Scope
 
Prior to conducting a CMMC Level 3 certification assessment, the Level 3 CMMC Assessment
 
Scope must be defined as addressed in 32 CFR § 170.19(d) and the ''CMMC Scoping Guide – ''
 
''Level  3  ''document[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#8|2]]. The CMMC Assessment Scope informs which assets within the OSC’s
 
environment will be assessed and the details of the assessment. The OSC must have achieved
 
a CMMC Status of Final Level 2 (C3PAO) of all systems included within the Level 3 CMMC
 
Assessment Scope prior to requesting the Level 3 assessment, as set forth in 32 CFR § 170.18.
 
The Level 3 assessment scoping is based on the requirements defined in 32 CFR § 170.19(d)
 
and supported by the ''CMMC Scoping Guide – Level 3 ''document. The ''CMMC Scoping Guide – ''
 
''Level  3  ''document is available on the official CMMC documentation site at
 
https://dodcio.defense.gov/CMMC/Documentation/.  If a Final  Level 2  (C3PAO) CMMC
 
Status has not already been achieved for the desired CMMC Assessment Scope, the OSC may
 
not proceed with the Level 3 assessment.
 
 
1
 
NIST SP800-172A, March 2022
 
2
 
Note that an OSC ought to be mindful of their full Level 3 scoping in their request for a Level 2 assessment.
 
 
 
 
 
 
 
 
 
CMMC-Custom Terms
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
5
 
''' '''
 
CMMC-Custom Terms <br />
The CMMC Program has custom terms that align with program requirements. Although some
 
terms may have other definitions in open forums, it is important to understand these terms
 
as they apply to the CMMC Program. <br />
The custom terms associated with Level 3 are: <br />
 
  '''Assessment:  '''As defined 32  CFR'''  '''§ 170.4  means  the testing or evaluation of security
 
controls to determine the extent to which the controls are implemented correctly,
 
operating as intended, and producing the desired outcome with respect to meeting the
 
security requirements for an information system or organization defined in 32 CFR §
 
170.15 to 32 CFR § 170.18.''' <br />
'''o  Level 3 certification assessment is the term for the activity performed by the DCMA
 
DIBCAC to evaluate the information system of an OSC when seeking a CMMC Status of
 
Level 3 (DIBCAC).
 
o  POA&amp;M closeout certification assessment is the term for the activity performed by a
 
C3PAO or DCMA DIBCAC to evaluate only the NOT MET requirements that were
 
identified with POA&amp;M during the initial assessment, when seeking a CMMC Status of
 
Final Level 2 (C3PAO) or Final Level 3 (DIBCAC) respectively.
 
 
  '''Assessment Objective:''' Means a set of determination statements that, taken together,
 
expresses the desired outcome for the assessment of a security requirement. Successful
 
implementation of the corresponding CMMC security requirement requires meeting all
 
applicable assessment objectives defined in NIST SP 800–171A or NIST SP 800-172A.
 
 
  '''Asset:''' Means an item of value to stakeholders. An asset may be tangible (e.g., a physical
 
item such as hardware, firmware, computing platform, network device, or other
 
technology component) or intangible (e.g., humans, data, information, software,
 
capability, function, service, trademark, copyright, patent, intellectual property, image,
 
or reputation). The value of an asset is determined by stakeholders in consideration of
 
loss concerns across the entire system life cycle. Such concerns include but are not
 
limited to business or mission concerns. Understanding ''assets'' is critical to identifying the
 
''CMMC Assessment Scope''; for more information see ''CMMC Scoping Guide – Level 3''.''' '''
 
 
  '''CMMC Assessment Scope: '''As defined in 32 CFR''' '''§ 170.4 means the set of all ''assets'' in the
 
OSC’s environment that will be assessed against CMMC security requirements.
 
 
  '''CMMC Status:''' The result of meeting or exceeding the minimum required score for the
 
corresponding assessment. The CMMC Status of an OSA information system is officially
 
stored in SPRS and additionally presented on a Certificate of CMMC Status, if the
 
assessment was conducted by a C3PAO or DCMA DIBCAC. <br />
o  '''Conditional Level 3 (DIBCAC):''''' ''Defined in 32 CFR § 170.18(a)(1)(ii). The OSC will
 
achieve  CMMC Status of  Conditional Level 3 (DIBCAC)  if a  POA&amp;M exists upon
 
completion of the assessment and the POA&amp;M meets all Level 3 POA&amp;M requirements
 
listed in 32 CFR § 170.21(a)(3).
 
 
 
 
 
 
 
 
 
CMMC-Custom Terms
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
6
 
''' '''
 
 
  '''Final Level 3 (DIBCAC): '''Defined in''' '''32''' '''CFR § 170.18(a)(1)(iii).'' ''The OSC will achieve
 
Final Level 3 (DIBCAC) CMMC Status for the information systems within the CMMC
 
Assessment Scope upon implementation of all security requirements and, if
 
applicable a POA&amp;M closeout assessment within 180 days. Additional guidance can
 
be found in 32 CFR §170.21.
 
 
  '''Enduring Exception:''' As defined 32 CFR § 170.4 means a special circumstance or
 
system where remediation and full compliance with CMMC ''s''ecurity ''r''equirements is not
 
feasible. Examples include systems required to replicate the configuration of ‘fielded’
 
systems, medical devices, test equipment, OT, and IoT. No operational plan of action is
 
required but the circumstance must be documented within a system security plan.
 
Specialized Assets and Government Furnished Equipment (GFE) may be Enduring
 
Exceptions.
 
 
  '''Event: '''Any observable occurrence in a system[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#10|3]]. As described in NIST SP 800-171A[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#10|4]], the
 
terms “information system” and “system” can be used interchangeably. ''Events'' sometimes
 
provide indication that an ''incident'' is occurring.''' '''
 
 
  '''Incident:  '''An  occurrence that actually or potentially jeopardizes the confidentiality,
 
integrity, or availability of a system or the information the system processes, stores, or
 
transmits or that constitutes a violation or imminent threat of violation of security
 
policies, security procedures, or acceptable use policies.[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#10|5 ]]
 
 
  '''Monitoring:  '''The act of continually checking, supervising, critically observing, or
 
determining the status in order to identify change from the performance level required
 
or expected at an ''organization-defined'' frequency and rate.[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#10|6''' ''']]
 
 
  '''Operational plan of action: '''As used in security requirement CA.L2-3.12.2, means the
 
formal artifact which identifies temporary vulnerabilities and temporary deficiencies in
 
implementation of requirements and documents how and when they will be mitigated,
 
corrected, or eliminated.  The OSA defines the format (e.g., document, spreadsheet,
 
database) and specific content of its operational plan of action. An operational plan of
 
action is not the same as a POA&amp;M associated with an assessment.''' '''
 
 
  '''Organization-defined: '''As determined by the OSC being assessed except as defined in
 
the case of Organization-Defined Parameter (ODP). This can be applied to a frequency or
 
rate at which something occurs within a given time period, or it could be associated with
 
describing the configuration of a OSC’s solution.
 
 
  '''Organization-Defined Parameters (ODPs): '''Selected enhanced security requirements
 
contain selection and assignment operations to give organizations[[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#10|7 ]]flexibility in defining
 
variable parts of those requirements, as defined in NIST SP 800-172A. ODPs are used in
 
NIST SP 800-172 and NIST SP 800-172A to allow Federal agencies, in this case the DoD,
 
to customize security requirements. Once specified, the values for the assignment and
 
selection operations become part of the requirement and objectives, where applicable.
 
 
3
 
NIST SP 800-53 Rev. 5, p. 402
 
4
 
NIST SP 800-171A, June 2018, p. v
 
5
 
NIST SP 800-171 Rev. 2, Appendix B, p. 54 (adapted)
 
6
 
NIST SP 800-160 Vol. 1 R1, Engineering Trustworthy Secure Systems, 2022, Appendix B., p. 55
 
7
 
The organization defining the parameters is the DoD.
 
 
 
 
 
 
 
 
 
CMMC-Custom Terms
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
7
 
''' '''
 
The assignments and selections chosen for Level 3 are underlined in the requirement
 
statement and objectives. In some cases, further specificity of the assignment or selection
 
will need to be made by the OSC. In those cases, the term and abbreviation ODPs is used
 
in the assessment objectives to denote where additional definition is required.
 
 
  '''Periodically: '''Means occurring at a regular interval as determined by the OSA that may
 
not exceed one year. As used in many requirements within CMMC, the interval length is
 
''organization-defined'' to provide OSC flexibility, with an interval length of no more than
 
one year.''' '''
 
 
  '''Security Protection Data: '''As defined 32 CFR § 170.4''' '''means data stored or processed by
 
Security Protection Assets (SPA) that are used to protect an OSC's assessed environment.
 
Security Protection Data is security relevant information and includes, but is not limited
 
to: configuration data required to operate an SPA, log files generated by or ingested by
 
an SPA, data related to the configuration or vulnerability status of in-scope assets, and
 
passwords that grant access to the in-scope environment.
 
 
  '''System Security Plan (SSP):''' Means the formal document that provides an overview of
 
the security requirements for an information system or an information security program
 
and describes the security controls in place or planned for meeting those requirements.
 
The system security plan describes the system components that are included within the
 
system, the environment in which the system operates, how the security requirements
 
are implemented, and the relationships with or connections to other systems.
 
 
  '''Temporary deficiency: '''As defined 32 CFR''' '''§ 170.4 means a condition where
 
remediation of a discovered deficiency is feasible and a known fix is available or is in
 
process. The deficiency must be documented in an operational plan of action. A
 
temporary deficiency is not based on an ‘in progress’ initial implementation of a CMMC
 
security requirement but arises after implementation. A temporary deficiency may
 
apply during the initial implementation of a security requirement if, during roll-out,
 
specific issues with a very limited subset of equipment is discovered that must be
 
separately addressed. There is no standard duration for which a temporary deficiency
 
may be active. For example, FIPS-validated cryptography that requires a patch and the
 
patched version is no longer the validated version may be a temporary deficiency.
 
 
 
 
 
 
 
 
 
 
Assessment Criteria and Methodology
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
8
 
''' '''
 
Assessment Criteria and Methodology <br />
The  ''CMMC Assessment Guide  –  Level  3''  leverages the assessment procedure described in
 
NIST SP 800-172A Section 2.1:
 
''An assessment procedure consists of an assessment objective and a set of ''
 
''potential assessment methods and objects that can be used to conduct the ''
 
''assessment. Each assessment objective includes a set of determination ''
 
''statements related to the CUI enhanced security requirement that is the subject ''
 
''of the assessment. Organization-defined parameters (ODP) that are part of ''
 
''selected enhanced security requirements are included in the initial ''
 
''determination statements for the assessment procedure. ODPs are included since ''
 
''the specified parameter values are used in subsequent determination ''
 
''statements. ODPs are numbered sequentially and noted in bold italics. <br />
Determination statements reflect the content of the enhanced security ''
 
''requirements to ensure traceability of the assessment results to the ''
 
''requirements. The application of an assessment procedure to an enhanced ''
 
''security requirement produces assessment findings. The findings are used to ''
 
''determine if the enhanced security requirement has been satisfied. <br />
Assessment objects are associated with the specific items being assessed. These ''
 
''objects can include specifications, mechanisms, activities, and individuals. <br />
''•
 
  ''Specifications are the document-based artifacts (e.g., policies, procedures, ''
 
''security plans, security requirements, functional specifications, architectural ''
 
''designs) associated with a system. ''
 
 
  ''Mechanisms are the specific hardware, software, or firmware safeguards ''
 
''employed within a system. ''
 
 
  ''Activities are the protection-related actions supporting a system that involve ''
 
''people (e.g., conducting system backup operations, exercising a contingency ''
 
''plan, and monitoring network traffic). ''
 
 
  ''Individuals, or groups of individuals, are people applying the specifications, ''
 
''mechanisms, or activities described above. ''
 
''Assessment methods define the nature and the extent of the assessor’s actions. ''
 
''The methods include examine, interview, and test. <br />
''•
 
  ''The  examine  method is the process of reviewing, inspecting, observing, ''
 
''studying, or analyzing assessment objects (i.e., specifications, mechanisms, ''
 
''activities). ''
 
 
  ''The interview method is the process of holding discussions with individuals ''
 
''or groups of individuals to facilitate understanding, achieve clarification, or ''
 
''obtain evidence. ''
 
 
 
 
 
 
 
 
 
Assessment Criteria and Methodology
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
9
 
''' '''
 
 
  ''The test method is the process of exercising assessment objects (i.e., activities, ''
 
''mechanisms) under specified conditions to compare actual with expected ''
 
''behavior. ''
 
''The purpose of the assessment methods is to facilitate understanding, achieve ''
 
''clarification, and obtain evidence. The results obtained from applying the ''
 
''methods are used for making the specific determinations called for in the ''
 
''determination statements and thereby achieving the objectives for the ''
 
''assessment procedure. ''
 
Criteria
 
Assessment objectives are provided for each requirement and are based on existing criteria
 
from NIST SP 800-172A. The criteria are authoritative and provide a basis for the assessor
 
to conduct an assessment of a requirement.
 
Methodology
 
During the CMMC certification assessment, the assessor will verify and validate that the OSC
 
has met the requirements. Because an OSC can meet the assessment objectives in different
 
ways (e.g., through documentation, computer configuration, network configuration, or
 
training), the assessor may use a variety of techniques, including one or more of the three
 
assessment methods described above from NIST SP 800-172A, to determine if the OSC meets
 
the intent of the requirements. <br />
The assessor  will follow the guidance in NIST  SP  800-172A when determining which
 
assessment methods to use:
 
''Organizations [DoD] are not expected to use all of the assessment methods and ''
 
''objects contained within the assessment procedures identified in this ''
 
''publication. Rather, organizations have the flexibility to establish the level of ''
 
''effort needed and the assurance required for an assessment (e.g., which ''
 
''assessment methods and objects are deemed to be the most useful in obtaining ''
 
''the desired results). The decision on level of effort is made based on how the ''
 
''organization can accomplish the assessment objectives in the most cost-effective ''
 
''and efficient manner and with sufficient confidence to support the determination ''
 
''that the CUI enhanced security requirements have been satisfied. ''
 
The primary deliverable of an assessment is a compliance score and accompanying report
 
that contains the findings associated with each requirement. For more detailed information
 
on assessment methods, see Appendix C of NIST SP 800-172A. <br />
Figure 1 illustrates an example of an assessment procedure for requirement AC.L3-3.1.3e.
 
 
 
 
 
 
 
 
 
Assessment Criteria and Methodology
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
10
 
''' '''
 
 
Who Is Interviewed
 
The assessor  has discussions with OSC  staff to understand if a requirement has been
 
addressed. Interviews with  applicable staff (possibly at different organizational levels)
 
determine if CMMC security  requirements are implemented and  if adequate resourcing,
 
training, and planning have occurred for individuals to perform the requirements.
 
What Is Examined
 
Examination includes reviewing, inspecting, observing, studying, or analyzing assessment
 
objects. The objects can be documents, mechanisms, or activities. The primary focus will be
 
to examine through demonstrations during interviews. <br />
For some requirements, the assessor reviews documentation to determine if assessment
 
objectives are met. Interviews with OSC staff may identify the documents uses. Documents
 
need to be in their final forms; working papers (e.g., drafts) of documentation are not eligible
 
to be submitted as evidence because they are not yet official and are still subject to change.
 
Common types of documents that can be used as evidence include: <br />
 
  policy, process, and procedure documents;
 
 
  training materials;
 
 
  plans and planning documents; and
 
 
  system-level, network, and data flow diagrams.
 
 
 
 
 
 
 
 
 
Assessment Criteria and Methodology
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
11
 
''' '''
 
This list of documents is not exhaustive or prescriptive. An OSC may not have these specific
 
documents, and other documents may be used to provide evidence of compliance. <br />
In other cases, the requirement is best assessed by observing that safeguards are in place by
 
viewing  hardware or associated configuration information or observe  staff  exercising  a
 
process.
 
What Is Tested
 
Testing is an important part of the assessment process. Interviews tell the assessor what the
 
OSC staff believe to be true, documentation provides evidence of intent, and testing
 
demonstrates what has or has not been done and is the preferred assessment method when
 
possible. For example, staff may talk about how users are identified and documentation may
 
provide details on how users are identified, but seeing a demonstration of user identification
 
provides evidence that the requirement is met. The assessor will determine which
 
requirements or objectives within a requirement need demonstration or testing. Most
 
objectives will require testing.
 
Assessment Findings
 
The assessment of a CMMC security requirement results in one of three possible findings:
 
MET, NOT MET, or NOT APPLICABLE as defined in 32 CFR § 170.24. To achieve CMMC Status
 
of Final Level 3 (DIBCAC) as described in 32 CFR § 170.18, the OSC will need a finding of MET
 
or NOT APPLICABLE on all Level 3 security requirements.  <br />
 
  '''MET:'''  All applicable  assessment  objectives  for the security requirement are  satisfied
 
based on evidence. All evidence must be in final form and a not draft. Unacceptable forms
 
of evidence include working papers, drafts, and unofficial or unapproved policies. For
 
each security requirement marked MET, it is best practice to record statements that
 
indicate the response conforms to all objectives and document the appropriate evidence
 
to support the response.
 
 
  Enduring Exceptions when described, along with any mitigations, in the system
 
security plan shall be assessed as MET.
 
 
  Temporary deficiencies that are appropriately addressed in operational plans of
 
action (i.e., include deficiency reviews, milestones, and show progress towards
 
the implementation of corrections to reduce or eliminate identified
 
vulnerabilities) shall be assessed as MET.
 
 
  '''NOT MET: '''One or more objectives for the security requirement is not satisfied. During a
 
Level 3 certification assessment, for each requirement objective marked NOT MET, the
 
assessor will document why the evidence provided by the OSC does not conform.
 
 
  '''NOT APPLICABLE (N/A): '''A security requirement and/or objective does not apply at the
 
time of the assessment. For example, SI.L3-3.14.3e might be N/A if there are no Internet of
 
Things (IoT),  Industrial Internet of Things (IIoT),  Operational Technology (OT),
 
 
 
 
 
 
 
 
 
Assessment Criteria and Methodology
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
12
 
''' '''
 
Government Furnished Equipment (GFE), Restricted Information Systems, or  test
 
equipment included in the Level 3 CMMC Assessment Scope. <br />
If an OSC previously received a favorable adjudication from the DoD CIO indicating that
 
a requirement is not applicable or that an alternative security measure is equally
 
effective, the DoD CIO  adjudication must be included in the system security plan to
 
receive consideration during an assessment. Implemented security measures
 
adjudicated by the DoD CIO as equally effective are assessed as MET if there have been
 
no changes in the environment. <br />
Each assessment  objective in NIST SP 800-171A  and NIST SP 800-172A  must yield a
 
finding of MET or NOT APPLICABLE in order for the overall security requirement to be
 
scored as MET. Assessors exercise judgment in determining when sufficient and
 
adequate evidence has been presented to make an assessment finding. <br />
CMMC  certification  assessments are conducted and results are captured at the
 
assessment objective level. One NOT MET assessment objective results in a failure of the
 
entire security requirement. <br />
A security requirement can be applicable even when assessment objectives included in
 
the security requirements are scored as N/A. The security requirement is NOT MET when
 
one or more applicable assessment objectives is NOT MET. <br />
Satisfaction of security requirements may be accomplished by other parts of the enterprise
 
or an External Service Provider (ESP), as defined in 32 CFR § 170.4. A security requirement
 
is considered MET if adequate evidence is provided that the enterprise or ESP, implements
 
the requirement objectives. An ESP may be external people, technology, or facilities that
 
the  OSC  uses, including cloud service providers, managed service providers, managed
 
security service providers, or cybersecurity-as-a-service providers.
 
 
 
 
 
 
 
 
 
Requirement Descriptions
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
13
 
''' '''
 
Requirement Descriptions <br />
This section provides detailed information and guidance for assessing each Level 3 security
 
requirement. The section is organized first  by domain and  then  by individual security
 
requirement. Each security  requirement description contains the following elements  as
 
described in 32 CFR § 170.14(c): <br />
 
  '''Requirement Number, Name, and Statement:''' Headed by the requirement identification
 
number in the format DD.L#-REQ (e.g., AC.L3-3.1.2e); followed by the requirement short
 
name identifier, meant to be used for quick reference only; and finally followed by the
 
complete CMMC security requirement statement. In the case where the original NIST SP
 
800-172 requirement requires  an assignment and/or selection statement, the Level 3
 
assignment (and any necessary selection)  text  is  emphasized  using  underlining.  See
 
Section 2.2 in NIST SP 800-172 for the discussion on assignments and selections.
 
 
  '''Assessment Objectives [NIST SP 800-172A]: '''Identifies the specific list of objectives
 
that must be met to receive MET for the requirement as defined in NIST SP 800-172A and
 
includes the Level 3 assignment/selection text (as appropriate). In cases where a Level 3
 
assignment  fully satisfies the definition(s)  required in an  organization-defined
 
parameter (ODP) in NIST SP 800-172A, the ODP statement is not included as an objective,
 
since that objective has been met by the assignment itself.  However, when the
 
assignment does not fully contain all required aspects of a NIST SP 800-172A ODP, the
 
ODP is included as its own objective, using the original NIST SP 800-172A ODP number
 
(e.g., “[ODP4]”). See the breakout box ''ORGANIZATION-DEFINED PARAMETERS'' in Section
 
2.1 of NIST  SP  800-172A for additional details on an  ODP.  In all cases where an
 
assignment is used within an objective, it also emphasized using underlining.
 
 
  '''Potential Assessment Methods and Objects [NIST SP 800-172A]: '''Defines the nature
 
and extent of the assessor’s actions. Potential assessment methods and objects are as
 
defined in NIST  SP  800-172A. The methods include ''examine'',  ''interview'', and ''test''.
 
Assessment objects identify the items being assessed and can include specifications,
 
mechanisms, activities, and individuals.
 
 
  '''Discussion [NIST SP 800-172]: '''Contains discussion from the associated NIST SP 800-172
 
security requirement.
 
 
  '''Further Discussion: '''
 
 
  Expands upon the NIST content to provide supplemental information on the
 
requirement intent.
 
 
  Contains examples illustrating how the OSC might apply the requirement. These
 
examples provide insight but are not intended to be prescriptive of how the
 
requirement must be implemented, nor comprehensive of all assessment
 
objectives necessary to achieve the requirement. The assessment objectives met
 
within the example are referenced by letter in brackets (e.g., [a,d] for objectives
 
“a” and “d”) within the text. Note that some of the examples contain company
 
names; all company names used in this document are fictitious.
 
 
 
 
 
 
 
 
 
Requirement Descriptions
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
14
 
''' '''
 
 
  Provides potential assessment considerations. These may include common
 
considerations for assessing the requirement and potential questions the assessor
 
may ask when assessing the objectives.
 
 
  '''Key References: '''Lists the security requirement from NIST SP 800-172.
 
 
 
 
 
 
 
 
 
AC.L3-3.1.2e – Organizationally Controlled Assets
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
15
 
''' '''
 
Access Control (AC) <br />
'''AC.L3-3.1.2E – ORGANIZATIONALLY CONTROLLED ASSETS '''
 
Restrict access to systems and system components to only those information resources that
 
are owned, provisioned, or issued by the organization.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Information resources that are owned, provisioned, or issued by the organization are
 
identified; and
 
[b] Access to systems and system components is restricted to only those information
 
resources that are owned, provisioned, or issued by the organization.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Access control policy; procedures addressing the use of external systems;
 
list of information resources owned, provisioned, or issued by the organization; security
 
plan; system design documentation; system configuration settings and associated
 
documentation; system connection or processing agreements; system audit records; account
 
management documents; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for restricting or prohibiting the use
 
of non-organizationally owned systems, system components, or devices; system and
 
network administrators; organizational personnel responsible for system security].
 
'''Test <br />
'''[SELECT FROM: Mechanisms implementing restrictions on the use of non-organizationally
 
owned systems, components, or devices].
 
'''DISCUSSION [NIST SP 800-172] '''
 
Information resources that are not owned, provisioned, or issued by the organization include
 
systems or system components owned by other organizations and personally owned
 
devices. Non-organizational information resources present significant risks to the
 
organization and complicate the ability to employ a “comply-to-connect” policy or
 
implement component or device attestation techniques to ensure the integrity of the
 
organizational system.
 
 
 
 
 
 
 
 
 
AC.L3-3.1.2e – Organizationally Controlled Assets
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
16
 
''' '''
 
'''FURTHER DISCUSSION '''
 
Implementing this requirement ensures that an organization has control over the systems
 
that can connect to organizational assets. This control will allow more effective and efficient
 
application of security policy. The terms “has control over” provides policy for systems that
 
are not owned outright by the organization.  Control includes policies, regulations or
 
standards that are enforced on the resource accessing contractor systems. Control may also
 
be exercised through contracts or agreements with the external party. Provisioned includes
 
setting configuration, whether through direct technical means or by policy or agreement. For
 
purposes of this requirement, GFE can be considered provisioned by the OSA.
 
'''Example 1 <br />
'''You are the chief network architect for your company.  Company policy states  that all
 
company-owned assets  must  be separated from all non-company-owned  (i.e.,  guest or
 
employee) assets. You decide the best way forward is to modify the corporate wired and
 
wireless networks to only allow company-owned devices to connect [b]. All other devices
 
are connected to a second (untrusted) network that non-corporate devices may use to access
 
the internet.  The two environments are physically separated and are not allowed to be
 
connected.  You also decide to limit the virtual private network (VPN)  services of the
 
company to devices owned by the corporation by installing certificate keys and have the VPN
 
validate the configuration of connecting devices before they are allowed in [b].
 
'''Example 2 <br />
'''You are a small company that uses an External Service Provider (ESP) to provide your audit
 
logging.  Access between the ESP and the organization is controlled by the agreement
 
between the organization and the ESP. That agreement will include the policies, standards,
 
and configuration for the required access. Technical controls should be documented and in
 
place which limit the ESP’s access to the minimum required to perform the logging service.
 
'''Potential Assessment Considerations <br />
'''•
 
  Can the organization demonstrate a non-company-owned device failing to access
 
information resources owned by the company [b]?
 
 
  How is this requirement met for organizational devices that are specialized assets (GFE,
 
restricted information systems) [a,b]?
 
 
  Does the company allow employees to charge personal cell phones on organizational
 
systems [b]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.1.2e
 
 
 
 
 
 
 
 
 
 
 
AC.L3-3.1.3e – Secured Information Transfer
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
17
 
''' '''
 
'''AC.L3-3.1.3E – SECURED INFORMATION TRANSFER '''
 
Employ secure information transfer solutions to control information flows between security
 
domains on connected systems.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[ODP1] Secure information transfer solutions are defined; <br />
[a] Information flows between security domains on connected systems are identified; and <br />
[b] Secure information transfer solutions  are employed to control information flows
 
between security domains on connected systems.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Access control policy; information flow control policies; procedures
 
addressing information flow enforcement; system design documentation; security plan;
 
system configuration settings and associated documentation; system audit records; system
 
baseline configuration; list of information flow authorizations; other relevant documents or
 
records].
 
'''Interview <br />
'''[SELECT FROM: System and network administrators; organizational personnel responsible
 
for information security; system developers].
 
'''Test <br />
'''[SELECT FROM: Mechanisms implementing information flow enforcement policy;
 
mechanisms implementing secure information transfer solutions].
 
'''DISCUSSION [NIST SP 800-172] '''
 
Organizations employ information flow control policies and enforcement mechanisms to
 
control the flow of information between designated sources and destinations within systems
 
and between connected systems. Flow control is based on the characteristics of the
 
information and/or the information path. Enforcement occurs, for example, in boundary
 
protection devices that employ rule sets or establish configuration settings that restrict
 
system services, provide a packet-filtering capability  based on header information, or
 
provide a message-filtering capability based on message content. Organizations also
 
consider the trustworthiness of filtering and inspection mechanisms (i.e., hardware,
 
firmware, and software components) that are critical to information flow enforcement. <br />
Transferring information between systems in different security domains with different
 
security policies introduces the risk that the transfers violate one or more domain security
 
 
 
 
 
 
 
 
 
AC.L3-3.1.3e – Secured Information Transfer
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
18
 
''' '''
 
policies. In such situations, information owners or information stewards provide guidance
 
at designated policy enforcement points between connected systems. Organizations
 
mandate specific architectural solutions when required to enforce logical or physical
 
separation between systems in different security domains. Enforcement includes prohibiting
 
information transfers between connected systems, employing hardware mechanisms to
 
enforce one-way information flows, verifying write permissions before accepting
 
information from another security domain or connected system, and implementing
 
trustworthy regrading mechanisms to reassign security attributes and labels. <br />
Secure information transfer solutions often include one or more of the following properties:
 
use of cross-domain solutions when traversing security domains, mutual authentication of
 
the sender and recipient (using hardware-based cryptography), encryption of data in transit
 
and at rest, isolation from other domains, and logging of information transfers (e.g., title of
 
file, file size, cryptographic hash of file, sender, recipient, transfer time and Internet Protocol
 
[IP] address, receipt time, and IP address).
 
'''FURTHER DISCUSSION '''
 
The organization implementing this requirement must decide on the secure information
 
transfer solutions they will use. The solutions must be configured to have strong protection
 
mechanisms for information flow between security domains. Secure information transfer
 
solutions control information flow between a Level 3 enclave and other CMMC or non-CMMC
 
enclaves. If CUI requiring Level 3 protection resides in one area of the environment or within
 
a given enclave outside of the normal working environment, protection to prevent
 
unauthorized personnel from accessing, disseminating,  and sharing the protected
 
information is required. Physical and virtual methods can be employed to implement secure
 
information transfer solutions.
 
'''Example <br />
'''You are the administrator for an enterprise that stores and processes CUI requiring Level 3
 
protection. The files containing CUI information are tagged by the company as CUI. To ensure
 
secure information transfer, you use an intermediary device to check the transfer of any CUI
 
files. The device sits at the boundary of the CUI enclave, is aware of all other CUI domains in
 
the enterprise, and has the ability to examine the metadata in the encrypted payload. The
 
tool checks all outbound communications paths. It first checks the metadata for all data being
 
transferred. If that data is identified as CUI, the device checks the destination to see if the
 
transfer is to another, sufficiently certified CUI domain. If the destination is not a sufficient
 
CUI domain, the tool blocks the communication path and does not allow the transfer to take
 
place. If the destination is a sufficient CUI domain, the transfer is allowed. The intermediary
 
device logs all blocks.
 
'''Potential Assessment Considerations <br />
'''•
 
  Has the organization defined the secure information transfer solutions it is using [b]?
 
 
  Has the organization defined domains, boundaries, and flows between those domains
 
that need to be controlled [a]?
 
 
 
 
 
 
 
 
 
AC.L3-3.1.3e – Secured Information Transfer
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
19
 
''' '''
 
 
  Has the organization defined attributes to be associated with the CUI, and both source
 
and destination objects [b]?
 
 
  Has the organization defined metadata or some other tagging mechanism to be used as a
 
means of enforcing CUI flow control [b]?
 
 
  Has the organization defined filters to be used as a basis for enforcing flow control
 
decisions [b]?
 
 
  Has the organization identified  CUI  flows for which flow control decisions are to be
 
applied and enforced [a,b]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.1.3e
 
 
 
 
 
 
 
 
 
 
AT.L3-3.2.1e – Advanced Threat Awareness
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
20
 
''' '''
 
Awareness and Training (AT) <br />
'''AT.L3-3.2.1E – ADVANCED THREAT AWARENESS '''
 
Provide awareness training upon initial hire, following a significant cyber event, and at least
 
annually, focused on recognizing and responding to threats from social engineering,
 
advanced persistent threat actors, breaches, and suspicious behaviors; update the training
 
at least annually or when there are significant changes to the threat.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Threats from social engineering, advanced persistent threat actors, breaches, and
 
suspicious behaviors are identified;
 
[b] Awareness training focused on recognizing and responding to threats from social
 
engineering, advanced persistent threat actors, breaches, and suspicious behaviors is
 
provided upon initial hire, following a significant cyber event, and at least annually;
 
[c] Significant changes to the threats from social engineering, advanced persistent threat
 
actors, breaches, and suspicious behaviors are identified; and
 
[d] Awareness training is updated at least annually or when there are significant changes to
 
the threat.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Awareness training policy; procedures addressing awareness training
 
implementation; appropriate codes of federal regulations; awareness training curriculum;
 
awareness training materials; security plan; training records; threat information on social
 
engineering, advanced persistent threat actors, suspicious behaviors, and breaches; other
 
relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for awareness training;
 
organizational personnel responsible for information security; organizational personnel
 
comprising the general system user community].
 
'''Test <br />
'''[SELECT FROM: Mechanisms managing awareness training; mechanisms managing threat
 
information].
 
 
 
 
 
 
 
 
 
AT.L3-3.2.1e – Advanced Threat Awareness
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
21
 
''' '''
 
'''DISCUSSION [NIST SP 800-172] '''
 
An effective method to detect APT activities and reduce the effectiveness of those activities
 
is to provide specific awareness training for individuals. A well-trained and security-aware
 
workforce provides another organizational safeguard that can be employed as part of a
 
defense-in-depth strategy to protect organizations against malicious code injections via
 
email or web applications. Threat awareness training includes educating individuals on the
 
various ways that APTs can infiltrate organizations, including through websites, emails,
 
advertisement pop-ups, articles, and social engineering. Training can include techniques for
 
recognizing suspicious emails, the use of removable systems in non-secure settings, and the
 
potential targeting of individuals by adversaries outside the workplace. Awareness training
 
is assessed and updated periodically to ensure that the training is relevant and effective,
 
particularly with respect to the threat since it is constantly, and often rapidly, evolving. <br />
[NIST SP 800-50] provides guidance on security awareness and training programs.
 
'''FURTHER DISCUSSION '''
 
All organizations, regardless of size,  should have a cyber training program that helps
 
employees understand threats they will face on a daily basis. This training must include
 
knowledge about APT actors, breaches, and suspicious behaviors.
 
'''Example <br />
'''You are the cyber training coordinator for a small business with eight employees. You do not
 
have your own in-house cyber training program. Instead, you use a third-party company to
 
provide cyber training.  New hires take the course when they start,  and all current staff
 
members receive refresher training at least once a year [b]. When significant changes to the
 
threat landscape take place, the company contacts you and informs you that an update to the
 
training has been completed [c,d] and everyone will need to receive training [b]. You keep a
 
log of all employees who have gone through the cyber training program and the dates of
 
training.
 
'''Potential Assessment Considerations <br />
'''•
 
  Does the organization have evidence that employees participate in cyber awareness
 
training at initial hire and at least annually thereafter or when there have been significant
 
changes to the threat [b]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.2.1e
 
 
''' '''
 
 
 
 
 
 
 
 
 
AT.L3-3.2.2e – Practical Training Exercises
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
22
 
''' '''
 
'''AT.L3-3.2.2E – PRACTICAL TRAINING EXERCISES '''
 
Include practical exercises in awareness training for all users, tailored by roles, to include
 
general users, users with specialized roles, and privileged users,  that are aligned with
 
current threat scenarios and provide feedback to individuals involved in the training and
 
their supervisors.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Practical exercises are identified; <br />
[b] Current threat scenarios are identified; <br />
[c] Individuals involved in training and their supervisors are identified; <br />
[d] Practical exercises that are aligned with current threat scenarios are included in
 
awareness training for all users, tailored by roles, to include general users, users with
 
specialized roles, and privileged users; and
 
[e] Feedback is provided to individuals involved in the training and their supervisors.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Awareness training policy; procedures addressing awareness training
 
implementation; appropriate codes of federal regulations; awareness training curriculum;
 
awareness training materials; security plan; training records; threat information on social
 
engineering, advanced persistent threat actors, suspicious behaviors, breaches, or other
 
relevant adversary tactics, techniques, or procedures; feedback on practical exercises and
 
awareness training; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for awareness training; organizational
 
personnel responsible for information security; organizational personnel with roles identified
 
for practical exercises; supervisors of personnel with roles identified for practical exercises]. 
 
'''Test <br />
'''[SELECT FROM: Mechanisms managing awareness training; mechanisms managing threat
 
information].
 
 
 
 
 
 
 
 
 
AT.L3-3.2.2e – Practical Training Exercises
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
23
 
''' '''
 
'''DISCUSSION [NIST SP 800-172] '''
 
Awareness training is most effective when it is complemented by practical exercises tailored
 
to the tactics, techniques, and procedures (TTP) of the threat. Examples of practical exercises
 
include unannounced social engineering attempts to gain unauthorized access, collect
 
information, or simulate the adverse impact of opening malicious email attachments or
 
invoking, via spear phishing attacks, malicious web links. Rapid feedback is essential to
 
reinforce desired user behavior. Training results, especially failures of personnel in critical
 
roles, can be indicative of a potentially serious problem. It is important that senior
 
management are made aware of such situations so that they can take appropriate
 
remediating actions.  <br />
[NIST SP 800-181] provides guidance on role-based security training, including a lexicon and
 
taxonomy that describes cybersecurity work via work roles.
 
'''FURTHER DISCUSSION '''
 
This  requirement  can be performed by the organization or by a  third-party company.
 
Training exercises (including unannounced exercises, such as phishing training) should be
 
performed at various times throughout the year to encourage employee readiness. After
 
each exercise session has been completed, the results should be recorded (date, time, what
 
and who the training tested, and the percent of successful and unsuccessful responses). The
 
purpose of training is to help employees in all roles act appropriately for any given training
 
situation, which should reflect real-life scenarios.  Collected results will help identify
 
shortcomings in the cyber training and/or whether additional instructional training may be
 
needed. <br />
General exercises can be included for all users, but exercises tailored for specific roles are
 
important, too. Training tailored for specific roles helps make sure individuals are ready for
 
actions and events specific to their positions in a company. Privileged users receive training
 
that emphasizes what permissions their privileged account has in a given environment and
 
what extra care is required when using their privileged account.
 
'''Example <br />
'''You are the cyber training coordinator for a medium-sized business. You and a coworker
 
have developed a  specialized awareness training to increase  cybersecurity awareness
 
around your organization. Your training includes social media campaigns, social engineering
 
phone calls, and phishing emails with  disguised  links to staff to train them beyond the
 
standard cybersecurity training [a,b]. <br />
To send simulated  phishing emails to staff, you subscribe to  a  third-party  service  that
 
specializes in this area [a]. The service sets up fictitious websites with disguised links to help
 
train general staff against this TTP used by APTs [d]. The third-party company tracks the
 
individuals who were sent phishing emails and whether they click on any of the of the links
 
within the emails. After the training action is completed, you receive a report from the third-
 
party company. The results show that 20% of the staff clicked on one or more phishing email
 
links, demonstrating a significant risk to your company. As the cyber training coordinator,
 
 
 
 
 
 
 
 
 
AT.L3-3.2.2e – Practical Training Exercises
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
24
 
''' '''
 
you notify the individuals, informing them they failed the training and identifying the area(s)
 
of concern  [e].  You send an email to the  supervisors informing them who in their
 
organization  has received training. You also send an email out to the entire company
 
explaining the training that just took place and the overall results [e].
 
'''Potential Assessment Considerations <br />
'''•
 
  Are the individuals being trained and the results recorded [e]?
 
 
  Are the training exercises performed [c]?
 
 
  Are the exercises set up for all users? Are there tailored exercises based on roles within
 
the organization (general users, users with specialized roles, and privileged users) [d]?
 
 
  Does the organization have documentation recording the training exercises, who
 
participated, and feedback provided to those who participated in a training session [c,e]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.2.2e
 
 
 
 
 
 
 
 
 
CM.L3-3.4.1e – Authoritative Repository
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
25
 
''' '''
 
Configuration Management (CM) <br />
'''CM.L3-3.4.1E – AUTHORITATIVE REPOSITORY '''
 
Establish and maintain an authoritative source and repository to provide a trusted source
 
and accountability for approved and implemented system components.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Approved system components are identified; <br />
[b] Implemented system components are identified; <br />
[c] An authoritative source and repository are established to provide a trusted source and
 
accountability for approved and implemented system components; and
 
[d] An authoritative source and repository are maintained to provide a trusted source and
 
accountability for approved and implemented system components.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Configuration management policy; procedures addressing the baseline
 
configuration of the system; configuration management plan; enterprise architecture
 
documentation; system design documentation; system architecture and configuration
 
documentation; system configuration settings and associated documentation; change
 
control records; system and system component inventory records; inventory reviews and
 
update records; security plan; system audit records; change control audit and review
 
reports; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for configuration management;
 
organizational personnel responsible for system component inventory; organizational
 
personnel responsible for configuration change control; organizational personnel
 
responsible for information security; system/network administrators; members of a change
 
control board or similar].
 
'''Test <br />
'''[SELECT FROM: Mechanisms that implement configuration change control; mechanisms
 
supporting configuration control of the baseline configuration; mechanisms supporting
 
and/or implementing the system component inventory].
 
 
 
 
 
 
 
 
 
CM.L3-3.4.1e – Authoritative Repository
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
26
 
''' '''
 
'''DISCUSSION [NIST SP 800-172] '''
 
The establishment and maintenance of an authoritative source and repository includes a
 
system component inventory of approved hardware, software, and firmware; approved
 
system baseline configurations and configuration changes; and verified system software and
 
firmware, as well as images and/or scripts. The authoritative source implements integrity
 
controls to log changes or attempts to change software, configurations, or data in the
 
repository. Additionally, changes to the repository are subject to change management
 
procedures and require authentication of the user requesting the change. In certain
 
situations, organizations may also require dual authorization for such changes. Software
 
changes are routinely checked for integrity and authenticity to ensure that the changes are
 
legitimate when updating the repository and when refreshing a system from the known,
 
trusted source. The information in the repository is used to demonstrate adherence to or
 
identify deviation from the established configuration baselines and to restore system
 
components from a trusted source. From an automated assessment perspective, the system
 
description provided by the authoritative source is referred to as the desired state. The
 
desired state is compared to the actual state to check for compliance or deviations. [NIST SP
 
800-128] provides guidance on security configuration management, including security
 
configuration settings and configuration change control. <br />
[NIST IR 8011-1] provides guidance on automation support to assess system and system
 
component configurations.
 
'''FURTHER DISCUSSION '''
 
Trusted software, whether securely developed in house or obtained from a trusted source,
 
should have baseline data integrity established when first created or obtained, such as by
 
using hash algorithms to obtain a hash value that would be used to validate the source prior
 
to use of the software in a given system. Hardware in the repository should be stored in boxes
 
or containers with tamper-evident seals. Hashes and seals should be checked on a regular
 
basis employing the principle of separation of duties.
 
'''Example <br />
'''You are the primary system build technician at a medium-sized company. You have been put
 
in charge of creating, documenting, and implementing a baseline configuration for all user
 
systems [c]. You have identified a minimum set of software that is needed by all employees
 
to complete their work (e.g., office automation software). You acquire trusted versions of the
 
software and build one or more baselines of all system software, firmware, and applications
 
required by the organization. The gold version of each baseline is stored in a secure
 
configuration management system repository and updated as required to maintain integrity
 
and security. Access to the build repository for updates and use is carefully controlled using
 
access control mechanisms that limit access to you and your staff. All interactions with the
 
repository are logged. Using an automated build tool, your team builds each organizational
 
system using the standard baseline
 
 
 
 
 
 
 
 
 
CM.L3-3.4.1e – Authoritative Repository
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
27
 
''' '''
 
'''Potential Assessment Considerations <br />
'''•
 
  Does an  authoritative  source  and repository exist  to provide a trusted source and
 
accountability for approved and implemented system components [c,d]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.4.1e
 
 
''' '''
 
 
 
 
 
 
 
 
 
CM.L3-3.4.2e – Automated Detection &amp; Remediation
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
28
 
''' '''
 
'''CM.L3-3.4.2E – AUTOMATED DETECTION &amp; REMEDIATION '''
 
Employ automated mechanisms to detect misconfigured or unauthorized system
 
components; after detection, remove the components or place the components in a
 
quarantine or remediation network  to facilitate patching, re-configuration, or other
 
mitigations.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Automated mechanisms to detect misconfigured or unauthorized system components
 
are identified;
 
[b] Automated mechanisms are employed to detect misconfigured or unauthorized system
 
components;
 
[c] Misconfigured or unauthorized system components are detected; and <br />
[d] After detection, system components are removed  or placed  in a quarantine or
 
remediation network to facilitate patching, re-configuration, or other mitigations.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Configuration management policy; procedures addressing the baseline
 
configuration of the system; configuration management plan; authoritative source or
 
repository; enterprise architecture documentation; system design documentation; system
 
architecture and configuration documentation; system procedures addressing system
 
configuration change control; configuration settings and associated documentation; change
 
control records; change control audit and review reports; agenda/minutes from
 
configuration change control oversight meetings; alerts/notifications of unauthorized
 
baseline configuration changes; security plan; system audit records; other relevant
 
documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for configuration management;
 
organizational personnel responsible for information security; organizational personnel
 
responsible for configuration change control; system developers; system/network
 
administrators; members of a change control board or similar roles].
 
'''Test <br />
'''[SELECT FROM: Automated mechanisms supporting configuration control of the baseline
 
configuration; automated mechanisms that implement security responses to changes to the
 
baseline configurations; automated mechanisms that implement configuration change
 
control; automated mechanisms that detect misconfigured or unauthorized system
 
components].
 
 
 
 
 
 
 
 
 
CM.L3-3.4.2e – Automated Detection &amp; Remediation
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
29
 
''' '''
 
'''DISCUSSION [NIST SP 800-172] '''
 
System components used to process, store, transmit, or protect CUI are monitored and
 
checked against the authoritative source (i.e., hardware and software inventory and
 
associated baseline configurations). From an automated assessment perspective, the system
 
description provided by the authoritative source is referred to as the desired state. Using
 
automated tools, the desired state is compared to the actual state to check for compliance or
 
deviations. Security responses to system components that are unknown or that deviate from
 
approved configurations can include removing the components; halting system functions or
 
processing; placing the system components in a quarantine or remediation network that
 
facilitates patching, re-configuration, or other mitigations; or issuing alerts and/or
 
notifications to personnel when there is an unauthorized modification of an organization-
 
defined configuration item. Responses can be automated, manual, or procedural.
 
Components that are removed from the system are rebuilt from the trusted configuration
 
baseline established by the authoritative source. <br />
[NIST  IR 8011-1] provides guidance on using automation support to assess system
 
configurations
 
'''FURTHER DISCUSSION '''
 
For this requirement, the organization is required to implement automated tools to help
 
identify misconfigured components. Once under an attacker’s control, the system may be
 
modified in some manner and the automated tool should detect this. Or, if a user performs a
 
manual configuration adjustment, the system will be viewed as misconfigured, and that
 
change should be detected. Another common example is if a component has been offline and
 
not updated, the tool should detect the incorrect configuration. If any of these scenarios
 
occurs, the automated configuration management system (ACMS) will notice a change and
 
can take the system offline, quarantine the system, or send an alert so the component(s) can
 
be manually removed. Quarantining a misconfigured component does not require it to be
 
removed from the network. Quarantining only requires that a temporary limitation be put
 
in place eliminating the component’s  ability to process, store, or transmit CUI until it is
 
properly configured. If a component has the potential of disrupting business operations then
 
the OSC should take extra care to ensure configuration updates are properly tested and that
 
components are properly configured and tested before being added to the network. Once
 
one of these actions is accomplished, a system technician may need to manually inspect the
 
system or rebuild it using the baseline configuration. Another option is for an ACMS to make
 
adjustments while the system is running rather than performing an entire rebuild. These
 
adjustments can include replacing configuration files, executable files, scripts, or library files
 
on the fly.
 
'''Example 1 <br />
'''As the system administrator,  you implement company policy stating that every system
 
connecting to the company network via VPN will be checked for specific configuration
 
settings and software versioning before it is allowed to connect to the network, after it passes
 
authentication  [a,b].  If any deviations from the authoritative baseline  are  identified, the
 
 
 
 
 
 
 
 
 
CM.L3-3.4.2e – Automated Detection &amp; Remediation
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
30
 
''' '''
 
system is placed in a VPN quarantine zone (remediation network) using a virtual local area
 
network (VLAN) [b,c,d]. This VLAN is set up for system analysis, configuration changes, and
 
rebuilding after forensic information is pulled from the system. Once the system updates are
 
complete, the system will be removed from the quarantine zone and placed on the network
 
through the VPN connection.
 
'''Example 2 <br />
'''As the system administrator, you have chosen to use a network access control (NAC) solution
 
to validate system configurations before they are allowed to connect to the corporate
 
network [a]. When a system plugs into or connects to a local network port or the VPN, the
 
NAC solution checks the hash of installed system software [b,c]. If the system does not pass
 
the configuration check, it is put in quarantine until an administrator can examine it or the
 
ACMS updates the system to pass the system checks [d].
 
'''Potential Assessment Considerations <br />
'''•
 
  Can the organization explain  the automated process  that  identifies, quarantines, and
 
remediates a system when a misconfiguration or unauthorized system component is
 
identified [a,b,c,d]?
 
 
  Does the organization have a patching and rebuild process for all assets that may be taken
 
offline [d]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.4.2e
 
 
''' '''
 
 
 
 
 
 
 
 
 
CM.L3-3.4.3e – Automated Inventory
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
31
 
''' '''
 
'''CM.L3-3.4.3E – AUTOMATED INVENTORY '''
 
Employ automated discovery and management tools to maintain an up-to-date, complete,
 
accurate, and readily available inventory of system components.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Automated discovery and management tools for the inventory of system components are
 
identified;
 
[b] An up-to-date, complete, accurate, and readily available inventory of system components
 
exists; and
 
[c] Automated discovery and management tools are employed to maintain an up-to-date,
 
complete, accurate, and readily available inventory of system components.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Configuration management policy; configuration management plan;
 
procedures addressing system component inventory; procedures addressing the baseline
 
configuration of the system; configuration management plan; system design documentation;
 
system architecture and configuration documentation; security plan; system configuration
 
settings and associated documentation; configuration change control records; system
 
inventory records; change control records; system maintenance records; system audit
 
records; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for information security;
 
organizational personnel responsible for configuration management; organizational
 
personnel responsible for managing the automated mechanisms implementing the system
 
component inventory; system developers; system/network administrators].
 
'''Test <br />
'''[SELECT FROM: Automated mechanisms implementing baseline configuration maintenance;
 
automated mechanisms implementing the system component inventory].
 
'''DISCUSSION [NIST SP 800-172] '''
 
The system component inventory includes system-specific information required for
 
component accountability and to provide support to identify, control, monitor, and verify
 
configuration items in accordance with the authoritative source. The information necessary
 
for effective accountability of system components includes the system name, hardware and
 
software component owners, hardware inventory specifications, software license
 
 
 
 
 
 
 
 
 
CM.L3-3.4.3e – Automated Inventory
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
32
 
''' '''
 
information, software version numbers, and—  for networked components—the machine
 
names and network addresses. Inventory specifications include the manufacturer, supplier
 
information, component type, date of receipt, cost, model, serial number, and physical
 
location. Organizations also use automated mechanisms to implement and maintain
 
authoritative (i.e., up-to-date, complete, accurate, and available) baseline configurations for
 
systems that include hardware and software inventory tools, configuration management
 
tools, and network management tools. Tools can be used to track version numbers on
 
operating systems, applications, types of software installed, and current patch levels.
 
'''FURTHER DISCUSSION '''
 
Organizations  use  an  automated  capability to discover components connected to the
 
network  and  system software  installed.  The  automated capability  must also be able to
 
identify attributes associated with those components. For systems that have already been
 
coupled to the environment, they should allow remote access for inspection of the system
 
software configuration and components. Another option is to place an agent on systems that
 
performs internal system checks to identify system software configuration and components.
 
Collection of switch and router data can also be used to identify systems on networks.
 
'''Example <br />
'''Within your organization, you are in charge of implementing an authoritative inventory of
 
system components. You first create a list of the automated technologies you will use and
 
what each technology will be responsible for identifying  [a].  This includes  gathering
 
information from switches, routers, access points, primary domain controllers, and all
 
connected systems or devices, whether wired or wireless (printers, IoT, IIoT, OT, IT, etc.) [b].
 
To keep the data up-to-date,  you set a very short search  frequency for identifying new
 
components. To maximize availability of this data, all information will be placed in a central
 
inventory/configuration management system, and automated reporting is performed every
 
day [c]. A user dashboard is set up that allows you and other administrators to run reports
 
at any time.
 
'''Potential Assessment Considerations <br />
'''•
 
  Can the organization explain the process by which current  inventory  information is
 
acquired [a]?
 
 
  Is the organization able to produce an inventory of components on the network [b,c]?
 
 
  Has the organization implemented  a valid  frequency  for  the component discovery
 
solution [b,c]?
 
 
  Can the organization demonstrate that the inventory is current and accurate [b]?
 
 
  Has the organization developed a defined list of identifiable attributes for each
 
component type, and is that list adequate to support component accountability [a]?
 
 
  Is the organization able to track, monitor, and verify configuration items in accordance
 
with the organization’s authoritative list of components [b,c]?
 
 
 
 
 
 
 
 
 
CM.L3-3.4.3e – Automated Inventory
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
33
 
''' '''
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.4.3e
 
''' '''
 
 
 
 
 
 
 
 
 
IA.L3-3.5.1e – Bidirectional Authentication
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
34
 
''' '''
 
Identification and Authentication (IA) <br />
'''IA.L3-3.5.1E – BIDIRECTIONAL AUTHENTICATION '''
 
Identify and authenticate systems and system components, where possible,  before
 
establishing a network connection using bidirectional authentication that is
 
cryptographically based and replay resistant.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[ODP1] Systems and system components to identify and authenticate are defined; <br />
[a] Bidirectional authentication that is cryptographically-based is implemented; <br />
[b] Bidirectional authentication that is replay-resistant is implemented; and <br />
[c] Systems and system components, where possible, are identified and authenticated before
 
establishing a network connection using bidirectional authentication that is
 
cryptographically-based and replay-resistant.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Identification and authentication policy; procedures addressing device
 
identification and authentication; network connection policy; security plan; system
 
configuration settings and associated documentation; system design documentation; list of
 
devices requiring unique identification and authentication; device connection reports;
 
system audit records; list of privileged system accounts; other relevant documents or
 
records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for system operations; organizational
 
personnel responsible for account management; organizational personnel responsible for
 
device identification and authentication; organizational personnel responsible for
 
information security; system/network administrators; system developers].
 
'''Test <br />
'''[SELECT FROM: Cryptographically-based bidirectional authentication mechanisms;
 
mechanisms supporting and/or implementing network connection policy; mechanisms
 
supporting and/or implementing replay-resistant authentication mechanisms; mechanisms
 
supporting and/or implementing an identification and authentication capability;
 
mechanisms supporting and/or implementing a device identification and authentication
 
capability].
 
 
 
 
 
 
 
 
 
IA.L3-3.5.1e – Bidirectional Authentication
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
35
 
''' '''
 
'''DISCUSSION [NIST SP 800-172] '''
 
Cryptographically-based and replay-resistant authentication between systems, components,
 
and devices addresses the risk of unauthorized access from spoofing (i.e., claiming a false
 
identity). The requirement applies to client-server authentication, server-server
 
authentication, and device authentication (including mobile devices). The cryptographic key
 
for authentication transactions is stored in suitably secure storage available to the
 
authenticator application (e.g., keychain storage, Trusted Platform Module [TPM], Trusted
 
Execution Environment [TEE], or secure element). Mandating authentication requirements
 
at every connection point may not be practical, and therefore, such requirements may only
 
be applied periodically or at the initial point of network connection. <br />
[NIST SP 800-63-3] provides guidance on identity and authenticator management.
 
'''FURTHER DISCUSSION '''
 
The intent of this practice is to prevent unauthorized devices from connecting to one
 
another. One example satisfying this requirement is a web server configured with transport
 
layer security (TLS) using mutual authentication. At a lower level in the OSI stack, IPsec
 
provides application-transparent mutual authentication. Another example would be
 
implementing 802.1X technology to enforce port-based NAC. This is done by enabling 802.1X
 
on switches, wireless access points, and VPN connections for a given network. 802.1X defines
 
authentication controls for devices trying to access a given network. NAC controls
 
authorization and policy management. For this to be implemented, bidirectional
 
authentication must be turned on via 802.1X. Once successfully authenticated, the device
 
may communicate on the network. A final example, at the application-server level, involves
 
the use of Kerberos to control 1) which files a client can access and 2) the transmission of
 
sensitive data from the client to the server.
 
'''Example 1 <br />
'''You are the network engineer in charge of implementing this requirement. You have been
 
instructed to  implement a technology that will provide mutual authentication for client
 
server connections. You implement Kerberos. <br />
On the server side, client authentication is implemented by having the client establish a local
 
security context. This is initially accomplished by having the client present credentials which
 
are confirmed by the Active Directory Domain Controller (DC). After that, the client may
 
establish context via a session of a logged-in user. The service does not accept connections
 
from any unauthenticated client. <br />
On the client side, server authentication requires registration, using administrator
 
privileges, of unique Service Provider Names (SPNs) for each service instance offered. The
 
names are registered in the Active Directory Domain Controller. When a client requests a
 
connection to a service, it composes an SPN for a service instance, using known data or data
 
provided by the user. For authentication, the client presents its SPN to the Key Distribution
 
Center (KDC), and the KDC searches for computers with the registered SPN before allowing
 
a connection via an encrypted message passed to the client for forwarding to the server.
 
 
 
 
 
 
 
 
 
IA.L3-3.5.1e – Bidirectional Authentication
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
36
 
''' '''
 
'''Example 2 <br />
'''You are the network engineer in charge of implementing this requirement. You have been
 
instructed to implement a technology that will provide authentication for each system prior
 
to connecting to the environment. You implement the company-approved scheme that uses
 
cryptographic keys installed on each system for it to authenticate to the environment, as well
 
as user-based cryptographic keys that are used in combination with a user’s password for
 
user-level authentication [a,c].  Your authentication implementation is finalized on each
 
system using an ACM solution. When a system connects to the network, the system uses the
 
system-level certificate to authenticate itself to the switch before the switch will allow it to
 
access the corporate network [a,c]. This is accomplished using 802.1x technology on the
 
switch and by authenticating with a RADIUS server that authenticates itself with the system
 
via cryptographic keys. If either system fails to authenticate to the other, the trust is broken,
 
and the system will not be able to connect to or communicate on the network. You also set
 
up a similar implementation in your wireless access point. 
 
'''Example 3 <br />
'''You are the network engineer in charge of implementing the VPN solution used by the
 
organization.  To meet this requirement,  you  use  a VPN gateway server and public key
 
infrastructure (PKI) certificates via a certification authority (CA) and a chain of trust. When
 
a client starts a VPN connection, the server presents its certificate to the client and if the
 
certificate is trusted, the client then presents its certificate to the server [a]. If the server
 
validates the client certificate,  an established communications channel is opened for the
 
client to finish the authentication process and gain access to the network via the VPN
 
gateway server [c]. If the client fails final authentication, fails the certification validation, or
 
the VPN gateway fails the certificate check by the client, the communication channel will be
 
denied.
 
'''Potential Assessment Considerations <br />
'''•
 
  Are cryptographic keys stored securely [a]?
 
 
  Has the requirement been implemented for any of the three use cases, where applicable:
 
client-server authentication, server-server authentication, and device authentication
 
[b,c]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.5.1e
 
 
 
 
 
 
 
 
 
IA.L3-3.5.3e – Block Untrusted Assets
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
37
 
''' '''
 
'''IA.L3-3.5.3E – BLOCK UNTRUSTED ASSETS '''
 
Employ automated or manual/procedural mechanisms to prohibit system components from
 
connecting to organizational systems unless the components are known, authenticated, in a
 
properly configured state, or in a trust profile.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] System components that are known, authenticated, in a properly configured state, or in
 
a trust profile are identified;
 
[b] Automated or manual/procedural mechanisms to prohibit system components from
 
connecting to organizational systems are identified; and
 
[c] Automated or manual/procedural mechanisms are employed to prohibit system
 
components from connecting to organizational systems unless the components are
 
known, authenticated, in a properly configured state, or in a trust profile.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Configuration management policy; identification and authentication policy;
 
system and information integrity policy; procedures addressing system component
 
inventory; procedures addressing device identification and authentication; procedures
 
addressing device configuration management; procedures addressing system monitoring
 
tools and techniques; configuration management plan; security plan; system design
 
documentation; system configuration settings and associated documentation; system
 
inventory records; configuration management records; system monitoring records;
 
alerts/notifications of unauthorized components within the system; change control records;
 
system audit records; system monitoring tools and techniques documentation; documented
 
authorization/approval of network services; notifications or alerts of unauthorized network
 
services; system monitoring logs or records; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for managing the mechanisms
 
implementing unauthorized system component detection; organizational personnel
 
responsible for device identification and authentication; organizational personnel
 
responsible for information security; organizational personnel responsible for installing,
 
configuring, and/or maintaining the system; system/network administrators;
 
organizational personnel responsible for monitoring the system; system developers].
 
 
 
 
 
 
 
 
 
IA.L3-3.5.3e – Block Untrusted Assets
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
38
 
''' '''
 
'''Test <br />
'''[SELECT FROM: Mechanisms implementing the detection of unauthorized system
 
components; mechanisms supporting and/or implementing a device identification and
 
authentication capability; mechanisms for providing alerts; mechanisms supporting and/or
 
implementing configuration management; cryptographic mechanisms supporting device
 
attestation; mechanisms supporting and/or implementing a system monitoring capability;
 
mechanisms for auditing network services].
 
'''DISCUSSION [NIST SP 800-172] '''
 
Identification and authentication of system components and component configurations can
 
be determined, for example, via a cryptographic hash of the component. This is also known
 
as device attestation and known operating state or trust profile. A trust profile based on
 
factors such as the user, authentication method, device type, and physical location is used to
 
make dynamic decisions on authorizations to data of varying types. If device attestation is
 
the means of identification and authentication, then it is important that patches and updates
 
to the device are handled via a configuration management process such that the patches and
 
updates are done securely and do not disrupt the identification and authentication of other
 
devices. <br />
[NIST  IR 8011-1] provides guidance on using automation support to assess system
 
configurations.
 
'''FURTHER DISCUSSION '''
 
This  requirement  can be achieved  in  several  ways, such as blocking based on posture
 
assessments, conditional access, or trust profiles. A posture assessment can be used to assess
 
a given system’s posture to validate that it meets the standards set by the organization before
 
allowing it to connect. Conditional access is the set of policies and configurations that control
 
devices receiving access to services and data sources. Conditional access helps an organization
 
build rules that manage security controls, perform blocking, and restrict components. A trust
 
profile is a set of factors that are checked to inform a device that a system can be trusted.
 
'''Example 1 <br />
'''In a Windows environment,  you authorize devices to connect to systems by defining
 
configuration rules in one or more Group Policy Objects (GPO) that can be automatically
 
applied to all relevant devices in a domain [a]. This provides you with a mechanism to apply
 
rules for which devices are authorized to connect to any given system and prevent devices
 
that are not within the defined list from connecting [b,c]. For instance, universal serial bus
 
(USB) device rules for authorization can be defined by using a USB device’s serial number,
 
model number, and manufacturer information. This information can be used to build a trust
 
profile for a device and authorize it for use by a given system. You use security policies to
 
prevent unauthorized components from connecting to systems [c].
 
 
 
 
 
 
 
 
 
IA.L3-3.5.3e – Block Untrusted Assets
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
39
 
''' '''
 
'''Example 2 <br />
'''You have been assigned to build trust profiles for all devices allowed to connect to your
 
organization’s systems. You want to test the capability starting with printers. You talk to your
 
purchasing department, and they tell you that policy states every printer must be from a
 
specific manufacturer; they only purchase four different models. They also collect all serial
 
numbers from purchased printers. You gather this information and build trust profiles for
 
each device [a,b]. Because your organization shares printers, you push the trust profiles out
 
to organizational systems. Now, the systems are not allowed to connect to a network printer
 
unless they are within the trust profiles you have provided [b,c].
 
'''Example 3 <br />
'''Your organization has implemented a network access control solution (NAC) to help ensure
 
that only properly configured computers are allowed to connect to the corporate network
 
[a,b]. The solution first checks for the presence of a certificate to indicate that the device is
 
company-owned. It next reviews the patch state of the computer and forces the installation
 
of any patches that are required by the organization. Finally, it reviews the computer’s
 
configuration to ensure that the firewall is active and that the appropriate security policies
 
have been applied. Once the computer has passed all of these requirements, it is allowed
 
access to network resources and defined as a trusted asset for the length of its session [a].
 
Devices that do not meet all of the requirements are automatically blocked from connecting
 
to the network [c].
 
'''Potential Assessment Considerations <br />
'''•
 
  If the organization is using a manual method, is the method outlined in detail so any user
 
will be able to follow it without making an error [b,c]?
 
 
  If the organization is using an automated method, can the organization explain how the
 
technology performs the task? Can they explain the steps needed to implement [a,b,c]?
 
 
  Can  the organization provide evidence showing they have trust profiles for specific
 
devices [a,b,c]?
 
 
  Can the organization explain how their system components authenticate to a system if
 
they are not using trust profiles [b,c]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.5.3e
 
 
 
 
 
 
 
 
 
IR.L3-3.6.1e – Security Operations Center
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
40
 
''' '''
 
Incident Response (IR) <br />
'''IR.L3-3.6.1E – SECURITY OPERATIONS CENTER '''
 
Establish and maintain a security operations center capability that operates 24/7, with
 
allowance for remote/on-call staff.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] A security operations center capability is established; <br />
[b] The security operations center capability operates 24/7, with allowance for remote/on-
 
call staff; and
 
[c] The security operations center capability is maintained.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Incident response policy; contingency planning policy; procedures
 
addressing incident handling; procedures addressing the security operations center
 
operations; mechanisms supporting dynamic response capabilities; incident response plan;
 
contingency plan; security plan; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for incident handling; organizational
 
personnel responsible for contingency planning; security operations center personnel;
 
organizational personnel responsible for information security].
 
'''Test <br />
'''[SELECT FROM: Mechanisms that support and/or implement the security operations center
 
capability; mechanisms that support and/or implement the incident handling process].
 
'''DISCUSSION [NIST SP 800-172] '''
 
A security operations center (SOC) is the focal point for security operations and computer
 
network defense for an organization. The purpose of the SOC is to defend and monitor an
 
organization’s systems and networks (i.e., cyber infrastructure) on an ongoing basis. The SOC
 
is also responsible for detecting, analyzing, and responding to cybersecurity incidents in a
 
timely manner. The SOC is staffed with skilled technical and operational personnel (e.g.,
 
security analysts, incident response personnel, systems security engineers);  in some
 
instances operates 24 hours per day, seven days per week; and implements technical,
 
management, and operational controls (e.g., monitoring, scanning, and forensics tools) to
 
 
 
 
 
 
 
 
 
IR.L3-3.6.1e – Security Operations Center
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
41
 
''' '''
 
monitor, fuse, correlate, analyze, and respond to security-relevant event data from multiple
 
sources. Sources of event data include perimeter defenses, network devices (e.g., gateways,
 
routers, and switches), and endpoint agent data feeds. The SOC provides a holistic situational
 
awareness capability to help organizations determine the security posture of the system and
 
organization. An SOC capability can be obtained in many ways. Larger organizations may
 
implement a dedicated SOC while smaller organizations may employ third-party
 
organizations to provide such a capability. <br />
[NIST SP 800-61] provides guidance on incident handling. [NIST SP 800-86] and [NIST SP
 
800-101] provide guidance on integrating forensic techniques into incident response. [NIST
 
SP  800-150] provides guidance on cyber threat information sharing. [NIST SP  800-184]
 
provides guidance on cybersecurity event recovery.
 
'''FURTHER DISCUSSION '''
 
Security operations  centers are created to monitor and respond to suspicious activities
 
across an organization’s IT applications and infrastructure. A SOC may be implemented in a
 
variety of physical, virtual, and geographic constructs. The organization may also opt to not
 
hire their own staff but to engage a third-party external service provider to serve as their
 
SOC. <br />
The SOC is typically comprised of multiple levels of cybersecurity analysts.  Each tier of
 
cybersecurity analysts works on increasingly complex aspects of Incident Response. The SOC
 
may also have dedicated cybersecurity engineers to support configuration and management
 
of defensive cyber tools. The SOC may work with staff in IT operations who provide support
 
to the SOC. <br />
SOC capabilities run 24/7, and while staff may not always be performing tasks for the SOC,
 
the capability alerts staff members and directs them to go to a facility or perform SOC actions
 
from a remote location. Staff members should be scheduled or on call to ensure they are
 
available when needed.
 
'''Example <br />
'''You are the Chief Information Security Officer (CISO) of a medium-sized organization. To
 
meet the goal of 24/7 SOC operation, you have decided to adjust the current SOC, which
 
operates five days a week for 12 hours a day, by minimizing active staff members and hiring
 
trusted expert consultants to have on call at all times (i.e., seven days a week, 24 hours a day)
 
[a,b].  You  design  your SOC to be remotely accessible so your experts can access your
 
environment when needed. You also decide to set up a very strong automated capability that
 
is good at identifying questionable activities and alerting the appropriate staff. You create a
 
policy stating that after an alert goes out, two members of the SOC team must  remotely
 
connect to the environment within 15 minutes to address the problem. All staff members
 
also have regular working hours during which they perform other SOC activities, such as
 
updating information to help the automated tool perform its functions [c].
 
 
 
 
 
 
 
 
 
IR.L3-3.6.1e – Security Operations Center
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
42
 
''' '''
 
'''Potential Assessment Considerations <br />
'''•
 
  How does the organization enable 24/7 SOC capabilities? Does the organization have
 
people in seats 24/7 or on-call members?  If on-call members are used, what are the
 
trigger and alerting mechanisms that allow for 24/7 coverage [a,b]?
 
 
  Does the organization have sufficient trained full-time equivalent staff to enable 24/7
 
SOC services [a,b]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.6.1e
 
 
 
 
 
 
 
 
 
 
 
IR.L3-3.6.2e – Cyber Incident Response Team
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
43
 
''' '''
 
'''IR.L3-3.6.2E – CYBER INCIDENT RESPONSE TEAM '''
 
Establish and maintain a cyber incident response team that can be deployed by the
 
organization within 24 hours.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] A cyber incident response team is established; <br />
[b] The cyber incident response team can be deployed by the organization within 24 hours;
 
and
 
[c] The cyber incident response team is maintained.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Incident response policy; procedures addressing incident response;
 
incident response plan; security plan; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for incident response; organizational
 
personnel from the incident response team; organizational personnel responsible for
 
information security].
 
'''Test <br />
'''[SELECT FROM: Mechanisms supporting and/or implementing incident response].
 
'''DISCUSSION [NIST SP 800-172] '''
 
A cyber incident response team (CIRT) is a team of experts that assesses, documents, and
 
responds to cyber incidents so that organizational systems can recover quickly and
 
implement the necessary controls to avoid future incidents. CIRT personnel include, for
 
example, forensic analysts, malicious code analysts, systems security engineers, and real-
 
time operations personnel. The incident handling capability includes performing rapid
 
forensic preservation of evidence and analysis of and response to intrusions. The team
 
members may or may not be full-time but need to be available to respond in the time period
 
required. The size and specialties of the team are based on known and anticipated threats.
 
The team is typically pre-equipped with the software and hardware (e.g., forensic tools)
 
necessary for rapid identification, quarantine, mitigation, and recovery and is familiar with
 
how to preserve evidence and maintain chain of custody for law enforcement or
 
counterintelligence uses. For some organizations, the CIRT can be implemented as a cross
 
organizational entity or as part of the Security Operations Center (SOC).
 
 
 
 
 
 
 
 
 
IR.L3-3.6.2e – Cyber Incident Response Team
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
44
 
''' '''
 
[NIST SP 800-61] provides guidance on incident handling. [NIST SP 800-86] and [NIST SP
 
800-101] provide guidance on integrating forensic techniques into incident response. [NIST
 
SP  800-150] provides guidance on cyber threat information sharing. [NIST SP  800-184]
 
provides guidance on cybersecurity event recovery.
 
'''FURTHER DISCUSSION '''
 
The CIRT’s primary function is to handle information security incident management and
 
response for the environments the SOC oversees. The primary goals of the CIRT are triage
 
and initial response to an incident. They also communicate with all the proper people to
 
ensure understanding of an incident and the response actions, including  collection of
 
forensic evidence, have been conveyed. <br />
If and when an incident is detected by the organization’s SOC, the IR team is responsible for
 
handling the incident and communicating  what has happened to the appropriate people
 
within the organization, as well to the authorities (as needed). <br />
The deployment of a team does not necessarily mean they are “physically deployed.”
 
Deployment may simply mean connecting to a remote system in a manner that is equivalent
 
to being on the system’s keyboard. Remote access can provide just as much capability as local
 
access in many cases. <br />
Some situations require physical access.  For instance, if the company has a physically
 
isolated environment located at a remote location, a team must be physically present at the
 
remote facility to perform the duties required.
 
'''Example <br />
'''You are the lead for an IR team within your organization. Your manager is the SOC lead, and
 
she reports to the chief information officer (CIO). As the SOC is alerted and/or identifies
 
incidents within the organization’s environments, you lead and deploy teams to resolve the
 
issues, including incidents involving cloud-based systems. You use a custom dashboard that
 
was created for your team members  to  view and manage  incidents, perform response
 
actions, and record actions and notes for each case. You also have your team create an after
 
action report for all incidents to which they respond; this information is used to determine
 
if a given incident requires additional action and reporting [a]. <br />
One  day,  you receive a message from the SOC that your website has become corrupted.
 
Within  minutes,  you have a team on the system inspecting logs, analyzing applications,
 
preserving key information, and looking for evidence of tampering/attack [b]. Your team
 
runs through a procedure  set for this specific incident type  based on a handbook the
 
organization has created  and maintains [c].  It is found that a cyberattack caused the
 
corruption, but the corruption caused a crash, which prevented the attack from continuing.
 
Your team takes note of all actions they perform, and at the end of the incident analysis, you
 
send a message to the website lead to inform them of the issue, case number, and notes
 
created by the team. The website lead has their team rebuild the system and validate that
 
the attack no longer works. At the end of the incident, the CISO and CIO are informed of the
 
issue.
 
 
 
 
 
 
 
 
 
IR.L3-3.6.2e – Cyber Incident Response Team
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
45
 
''' '''
 
'''Potential Assessment Considerations <br />
'''•
 
  Does the organization have a response capability that has remote  access to the
 
organization’s systems and system components within 24 hours in place of physical
 
access [a,b]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.6.2e
 
 
 
 
 
 
 
 
 
PS.L3-3.9.2e – Adverse Information
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
46
 
''' '''
 
Personnel Security (PS) <br />
'''PS.L3-3.9.2E – ADVERSE INFORMATION '''
 
Ensure that organizational systems are protected if adverse information develops or is
 
obtained about individuals with access to CUI.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Individuals with access to CUI are identified; <br />
[b] Adverse information about individuals with access to CUI is defined; <br />
[c] Organizational systems to which individuals have access are identified; and <br />
[d] Mechanisms are in place to protect organizational systems if adverse information
 
develops or is obtained about individuals with access to CUI.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Personnel security policy; system and services acquisition policy;
 
procedures addressing personnel screening; records of screened personnel; enterprise
 
architecture documentation; system design documentation; system architecture and
 
configuration documentation; security plan; list of individuals who have been identified as
 
posing an increased level of risk; list of appropriate access authorizations required for
 
system personnel; personnel screening criteria and associated documentation; other
 
relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for personnel security; organizational
 
personnel responsible for information security; organizational personnel responsible for
 
system and services acquisition; organizational personnel responsible for personnel
 
screening].
 
'''Test <br />
'''[SELECT FROM: Organizational processes for personnel screening; mechanisms supporting
 
personnel screening].
 
 
 
 
 
 
 
 
 
PS.L3-3.9.2e – Adverse Information
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
47
 
''' '''
 
'''DISCUSSION [NIST SP 800-172] '''
 
If adverse information develops or is obtained about an individual with access to CUI which
 
calls into question whether the individual should have continued access to systems
 
containing CUI, actions are taken (e.g., preclude or limit further access by the individual,
 
audit actions taken by the individual) to protect the CUI while the adverse information is
 
resolved.
 
'''FURTHER DISCUSSION '''
 
According to Defense Counterintelligence and Security Agency, or DCSA (Industrial Security
 
Letter ISL 2011-04, revised July 15, 2020), adverse information consists of any information
 
that negatively reflects the integrity or character of an  individual.  This pertains to an
 
individual’s ability to safeguard sensitive information, such as CUI. Adverse information may
 
simply be a report showing someone has sent sensitive information outside the organization
 
or used unapproved software, against company policy. An organization may receive adverse
 
information about an individual  through  police reports, reported  violations  of company
 
policies (including social media posts that directly violate company policies), and revocation
 
or suspension of DoD clearance. <br />
When adverse information is identified about a given individual, the organization should
 
take action to validate that information resources accessible by the individual have been
 
identified and appropriate protection mechanisms are in place to safeguard information and
 
system configurations. Based on organizational policy, an individual’s access to resources
 
may be more closely monitored or restricted until further review. Logs should be examined
 
to identify any attempt to perform unauthorized actions.
 
'''Example <br />
'''You learn that one of your employees has been convicted on shoplifting charges. Based on
 
organizational policy, you report this information to human resources (HR), which verifies
 
the information with a criminal background check [a,b,c].  Per policy, you increase the
 
monitoring of the employee’s access to ensure that the employee does not exhibit patterns
 
of behavior consistent with an insider threat [d]. You maintain contact with HR as they
 
investigate the adverse information so that you can take stronger actions if required, such as
 
removing access to organizational systems.
 
'''Potential Assessment Considerations <br />
'''•
 
  Does the organization define the protection mechanisms for organizational systems if
 
adverse information develops or is obtained about an individual with access to CUI [d]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.9.2e
 
 
 
 
 
 
 
 
 
RA.L3-3.11.1e – Threat-Informed Risk Assessment
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
48
 
''' '''
 
Risk Assessment (RA) <br />
'''RA.L3-3.11.1E – THREAT-INFORMED RISK ASSESSMENT '''
 
Employ threat intelligence, at a minimum from open or commercial sources, and any DoD-
 
provided sources,  as part of a risk assessment to guide and inform the development of
 
organizational systems, security architectures, selection of security solutions, monitoring,
 
threat hunting, and response and recovery activities.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[ODP1] Sources of threat intelligence are defined;'' <br />
''[a] A risk assessment methodology is identified; <br />
[b] Threat intelligence, at a minimum from open or commercial sources, and any
 
DoD-provided sources, are employed as part of a risk assessment to guide and inform the
 
development of organizational systems and security architectures;
 
[c] Threat intelligence, at a minimum from open or commercial sources, and any
 
DoD-provided sources, are employed as part of a risk assessment to guide and inform the
 
selection of security solutions;
 
[d] Threat intelligence, at a minimum from open or commercial sources, and any
 
DoD-provided sources, are employed as part of a risk assessment to guide and inform
 
system monitoring activities;
 
[e] Threat intelligence, at a minimum from open or commercial sources, and any
 
DoD-provided sources, are employed as part of a risk assessment to guide and inform
 
threat hunting activities; and
 
[f]  Threat intelligence, at a minimum from open or commercial sources, and any
 
DoD-provided sources, are employed as part of a risk assessment to guide and inform
 
response and recovery activities.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Information security program  plan; risk assessment policy; threat
 
awareness program documentation; procedures for the threat awareness program; security
 
planning policy and procedures; procedures addressing organizational assessments of risk;
 
threat hunting program documentation; procedures for the threat hunting program; risk
 
assessment results relevant to threat awareness; threat hunting results; list or other
 
documentation on the cross-organization, information-sharing capability; security plan; risk
 
assessment; risk assessment results; risk assessment reviews; risk assessment updates;
 
 
 
 
 
 
 
 
 
RA.L3-3.11.1e – Threat-Informed Risk Assessment
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
49
 
''' '''
 
contingency planning policy; contingency plan; incident response policy; incident response
 
plan; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for information security program
 
planning and plan implementation; organizational personnel responsible for the threat
 
awareness and threat hunting programs; organizational personnel responsible for risk
 
assessments; organizational personnel responsible for the cross-organization, information-
 
sharing capability; organizational personnel responsible for information security;
 
organizational personnel responsible for contingency planning; organizational personnel
 
responsible for incident response; personnel with whom threat awareness information is
 
shared by the organization].
 
'''Test <br />
'''[SELECT FROM: Mechanisms supporting and/or implementing the threat awareness
 
program; mechanisms supporting and/or implementing the cross-organization,
 
information-sharing capability; mechanisms supporting and/or implementing the threat
 
hunting program; mechanisms for conducting, documenting, reviewing, disseminating, and
 
updating risk assessments; mechanisms supporting and/or implementing contingency
 
plans; mechanisms supporting and/or implementing incident response plans].
 
'''DISCUSSION [NIST SP 800-172] '''
 
The constant evolution and increased sophistication of adversaries, especially the APT,
 
makes it more likely that adversaries can successfully compromise or breach organizational
 
systems. Accordingly, threat intelligence can be integrated into each step of the risk
 
management process throughout the system development life cycle. This risk management
 
process includes defining system security requirements, developing system and security
 
architectures, selecting security solutions, monitoring (including threat hunting), and
 
remediation efforts. <br />
[NIST SP  800-30] provides guidance on risk assessments. [NIST SP  800-39] provides
 
guidance on the risk management process. [NIST SP  800-160-1] provides guidance on
 
security architectures and systems security engineering. [NIST SP  800-150] provides
 
guidance on cyber threat information sharing.
 
'''FURTHER DISCUSSION '''
 
An organization consumes threat intelligence and improves their security posture based on
 
the intelligence relevant to that  organization and/or a  system(s).  The organization can
 
obtain threat intelligence from open or commercial sources  but must also use  any
 
DoD-provided sources. Threat information can be received in high volumes from various
 
providers and must be processed and analyzed by the organization. It is the responsibility of
 
the organization to process the threat information in a manner that is useful and actionable
 
to their needs. Processing, analyzing, and extracting the intelligence from the threat feeds
 
 
 
 
 
 
 
 
 
RA.L3-3.11.1e – Threat-Informed Risk Assessment
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
50
 
''' '''
 
and applying it to all organizational security engineering needs is the primary benefit of this
 
requirement. Note that more than one source is required to meet assessment objectives.
 
'''Example <br />
'''Your organization receives a commercial threat  intelligence feed from  FIRST and
 
government threat intelligence feeds from both USCERT and DoD/DC3 to help learn about
 
recent threats and any additional information the threat feeds provide  [b,c,d,e,f].  Your
 
organization uses the threat intelligence for multiple purposes: <br />
 
  To perform up-to-date risk assessments for the organization [a];
 
 
  To add rules to the automated system put in place to identify threats (indicators of
 
compromise, or IOCs) on the organization’s network [e];
 
 
  To guide the organization in making informed selections of security solutions [c];
 
 
  To shape the way the organization performs system monitoring activities [d];
 
 
  To manage the escalation process for identified incidents, handling specific events, and
 
performing recovery actions [f];
 
 
  To provide additional information to the hunt team to identify threat activities [e];
 
 
  To inform  the development and design decisions for organizational systems and the
 
overall security architecture, as well as the network architecture [b,c];
 
 
  To assist in decision-making regarding systems that are part of the primary network and
 
systems that are placed in special enclaves for additional protections [b]; and
 
 
  To determine additional security measures based on current threat activities taking place
 
in similar industry networks [c,d,e,f].
 
'''Potential Assessment Considerations <br />
'''•
 
  Does the organization detail how threat feed information is to be ingested, analyzed, and
 
used [a]?
 
 
  Can the organization’s SOC or hunt teams discuss how they use the threat feed
 
information after it is processed [e,f]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.11.1e
 
 
 
 
 
 
 
 
 
 
 
RA.L3-3.11.2e – Threat Hunting
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
51
 
''' '''
 
'''RA.L3-3.11.2E – THREAT HUNTING '''
 
Conduct cyber threat hunting activities on an on-going aperiodic basis or when indications
 
warrant, to search for indicators of compromise in organizational systems and detect, track,
 
and disrupt threats that evade existing controls.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[ODP4] Organizational systems to search for indicators of compromise are defined;'' <br />
''[a] Indicators of compromise are identified; <br />
[b] Cyber threat hunting activities are conducted on an on-going aperiodic basis or when
 
indications warrant, to search for indicators of compromise in organizational systems;
 
and
 
[c] Cyber threat hunting activities are conducted on an on-going aperiodic basis or when
 
indications warrant, to detect, track, and disrupt threats that evade existing controls.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: System and information integrity policy; policy and procedures addressing
 
system monitoring; threat hunting program documentation; procedures for the threat
 
hunting program; threat hunting results; system design documentation; security plan;
 
system monitoring tools and techniques documentation; security planning policy and
 
procedures; system configuration settings and associated documentation; system
 
monitoring logs or records; system audit records; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for threat hunting program;
 
system/network administrators; organizational personnel responsible for information
 
security; system developers; organizational personnel installing, configuring, and/or
 
maintaining the system; organizational personnel responsible for monitoring the system
 
and/or network].
 
'''Test <br />
'''[SELECT FROM: Mechanisms supporting and/or implementing a threat hunting program;
 
mechanisms supporting and/or implementing a system monitoring capability; mechanisms
 
supporting and/or supporting and/or implementing incident response plans].
 
'''DISCUSSION [NIST SP 800-172] '''
 
Threat hunting is an active means of defense that contrasts with traditional protection
 
measures, such as firewalls, intrusion detection and prevention systems, quarantining
 
 
 
 
 
 
 
 
 
RA.L3-3.11.2e – Threat Hunting
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
52
 
''' '''
 
malicious code in sandboxes, and Security Information and Event Management (SIEM)
 
technologies and systems. Cyber threat hunting involves proactively searching
 
organizational systems, networks, and infrastructure for advanced threats. The objective is
 
to track and disrupt cyber adversaries as early as possible in the attack sequence and to
 
measurably improve the speed and accuracy of organizational responses. Indicators of
 
compromise are forensic artifacts from intrusions that are identified on organizational
 
systems at the host or network level and can include unusual network traffic, unusual file
 
changes, and the presence of malicious code. <br />
Threat hunting teams use existing threat intelligence and may create new threat information,
 
which may be shared with peer organizations, Information Sharing and Analysis
 
Organizations (ISAO), Information Sharing and Analysis Centers (ISAC), and relevant
 
government departments  and agencies. Threat indicators, signatures, tactics, techniques,
 
procedures, and other indicators of compromise may be available via government and non-
 
government cooperatives, including Forum of Incident Response and Security Teams, United
 
States Computer Emergency Response Team, Defense Industrial Base Cybersecurity
 
Information Sharing Program, and CERT Coordination Center. <br />
[NIST SP 800-30] provides guidance on threat and risk assessments, risk analyses, and risk
 
modeling.  [NIST SP  800-160-2] provides guidance on systems security engineering and
 
cyber resiliency. [NIST SP 800-150] provides guidance on cyber threat information sharing.
 
'''FURTHER DISCUSSION '''
 
For this requirement, threat hunting is conducted on an on-going aperiodic basis. On-going
 
aperiodic refers to activities that happen over and over but without an identifiable repeating
 
pattern over time. For threat hunting, on-going activities take place in an automated manner
 
(e.g.,  collecting logs, automated analysis,  and  alerts).  Aperiodicity  includes humans
 
performing the hunt activities, which take place on an as-needed or as-planned basis. <br />
APTs can penetrate an environment by means that defeat or avoid conventional monitoring
 
methods  and  alert triggers—for example,  by using zero-day attacks.  Zero-day attacks
 
become known only after the attack has happened and alerts are sent via threat intelligence
 
feeds based on expert analysis. Because of the nature of zero-day attacks, automated alerts
 
do not generally trigger when the event occurs but the activity is captured in system logs and
 
forwarded for analysis and retention by the SIEM. Threat intelligence information is typically
 
used by hunt teams to search SIEM systems, system event  and security logs, and other
 
components to identify activity that has already taken place on an environment. The hunt
 
team will identify systems related to the event(s) and pass the case to Incident Response
 
team for action on the event(s). The hunt team will also use indicators to identify smaller
 
components of an attack and search for that activity, which may help uncover a broader
 
attack on the environment. <br />
Threat hunting can also look for anomalous behavior or activity based on an organization’s
 
normal pattern of activity.  Understanding  the roles and information flows within an
 
organization can help identify activity that might be indicative of adversary behavior before
 
the adversary completes their attack or mission.
 
 
 
 
 
 
 
 
 
RA.L3-3.11.2e – Threat Hunting
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
53
 
''' '''
 
'''Example <br />
'''You are the lead for your organization’s cyber threat hunting team.  You have local and
 
remote staff on the team to process threat intelligence. Your team is tied closely with the SOC
 
and IR teams. Through a DoD (DC3) intelligence feed, you receive knowledge of a recent
 
APT’s attacks  on  defense  contractors.  The intelligence feed provided the indicators of
 
compromise for a zero-day attack that most likely started within the past month.  After
 
receiving the IOCs, you use a template for your organization to place the information in a
 
standard format your team understands.  You  then  email the information to your team
 
members and place the information in your hunt team’s dashboard, which tracks all IOCs [a]. <br />
Your team starts by using the information to hunt for IOCs on the environment [b]. One of
 
your team members quickly responds,  providing information  from the SIEM that an HR
 
system’s logs show evidence that IOCs related to this threat occurred three days ago. The
 
team contacts the owner of the system as they take the system offline into a quarantined
 
environment. Your team pulls all logs from the system and clones the storage on the system.
 
Members go through the logs to look for other systems that may be part of the APT’s attack
 
[c]. While the team is cloning the storage system for evidence, you alert the IR team about
 
the issue. After full forensics of the system, your team has verified your company has been
 
hit by the APT, but nothing was taken and no additional attacks happened. You also alert DoD
 
(DC3) about the finding and discuss the matter with them. There is an after action report and
 
a briefing given to management to make them aware of the issue.
 
'''Potential Assessment Considerations <br />
'''•
 
  Does the organization have a methodology for performing cyber threat hunting actions
 
[b,c]?
 
 
  Has the organization defined all organizational  systems within scope of cyber threat
 
hunting, including valid and approved documentation for any organization systems that
 
are not within scope [b,c]?
 
 
  Has  the organization identified a specific set of  individuals  to perform cyber threat
 
hunting [b,c]?
 
 
  Does the threat hunting team have qualified staff members using the threat feed
 
information [b,c]?
 
 
  Does the threat hunting team use  combinations of events to determine suspicious
 
behaviors [b,c]?
 
 
  Does the organization have a documented list of trusted threat feeds that are used by
 
their cyber hunt teams as the latest indicators of compromise during their efforts [a]?
 
 
  Does the organization have a clear methodology for processing threat feed information
 
and turning it into actionable information they can use for their threat hunting approach
 
[a]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.11.2e
 
 
 
 
 
 
 
 
 
 
RA.L3-3.11.3e – Advanced Risk Identification
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
54
 
''' '''
 
'''RA.L3-3.11.3E – ADVANCED RISK IDENTIFICATION '''
 
Employ advanced automation and analytics capabilities in support of analysts to predict and
 
identify risks to organizations, systems, and system components.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Advanced automation and analytics capabilities to predict and identify risks to
 
organizations, systems, and system components are identified;
 
[b] Analysts to predict and identify risks to organizations, systems, and system components
 
are identified; and
 
[c] Advanced automation and analytics capabilities are employed in support of analysts to
 
predict and identify risks to organizations, systems, and system components.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: System and information integrity policy; risk assessment policy; security
 
planning policy and procedures; procedures addressing organizational assessments of risk;
 
procedures addressing system monitoring; enterprise architecture documentation; system
 
design documentation; system architecture and configuration documentation; system
 
monitoring tools and techniques documentation; system configuration settings and
 
associated documentation; system monitoring logs or records; system audit records;
 
security plan; risk assessment artifacts; risk assessment results; risk assessment reviews;
 
risk assessment updates; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for information security;
 
organizational personnel responsible for risk assessments; risk analysts; system developers;
 
organizational personnel installing, configuring, and/or maintaining the system;
 
organizational personnel responsible for monitoring; system/network administrators].
 
'''Test <br />
'''[SELECT FROM: Automated mechanisms supporting and/or implementing risk analytics
 
capabilities; automated mechanisms supporting and/or implementing system monitoring
 
capability; automated mechanisms supporting and/or implementing the discovery,
 
collection, distribution, and use of indicators of compromise; automated mechanisms for
 
conducting, documenting, reviewing, disseminating, and updating risk assessments].
 
 
 
 
 
 
 
 
 
RA.L3-3.11.3e – Advanced Risk Identification
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
55
 
''' '''
 
'''DISCUSSION [NIST SP 800-172] '''
 
A properly resourced Security Operations Center (SOC) or Computer Incident Response
 
Team (CIRT) may be overwhelmed by the volume of information generated by the
 
proliferation of security tools and appliances unless it employs advanced automation and
 
analytics to analyze the data. Advanced automation and predictive analytics capabilities are
 
typically supported by artificial intelligence concepts and machine learning. Examples
 
include Automated Workflow Operations, Automated Threat Discovery and Response
 
(which includes broad-based collection, context-based analysis, and adaptive response
 
capabilities), and machine-assisted decision tools. <br />
[NIST SP 800-30] provides guidance on risk assessments and risk analyses.
 
'''FURTHER DISCUSSION '''
 
Advanced automation includes tools to correlate and reduce the cyber data overload created
 
by defensive tools, making the data understandable to the analyst. Automation also allows
 
the defensive mechanisms to respond rapidly when adversary events are identified.
 
Examples of such capabilities are SIEM; Security Orchestration, Automation, and Response
 
(SOAR); and Extended Detection and Response (XDR) tools. An example of an automated
 
rapid response action is a security alert being pushed to the SIEM while the organization’s
 
SOAR solution communicates to the network firewall to block communications to the remote
 
system identified in the security alert. <br />
SIEM is  primarily a log collection tool intended to support data storage and analysis. It
 
collects and sends alerts to security personnel for further investigation. SOAR is a software
 
stack that enables an organization to collect data about security threats and respond to
 
security events without human assistance in order to improve security operations.
 
Orchestration connects and integrates disparate internal and external tools. Automation, fed
 
by the data and alerts collected from security orchestration, ingests and analyzes data and
 
creates repeated, automated responses. SOAR incorporates these capabilities based on the
 
SIEM data and enables disparate security tools to coordinate with one another. SOAR can use
 
artificial intelligence to predict and respond to similar future threats,  if such tools are
 
employed. <br />
XDR streamlines security data ingestion, analysis, prevention, and remediation workflows
 
across an organization’s entire security stack, providing a single console to view and act on
 
threat data. However, the presence of these tools by themselves does not necessarily provide
 
an advanced capability.  It is essential that the security team employ  critical thinking in
 
support of the intrusion detection and threat hunting processes.
 
'''Example <br />
'''You are responsible for information security in your organization. The organization holds
 
and processes CUI in an enterprise. To protect that data, you want to minimize phishing
 
attacks through the use of Security Orchestration and Automated Response (SOAR). Rather
 
than relying on analysts to manually inspect each inbound item, emails containing links
 
and/or attachments are processed by your automation playbook. Implementation of these
 
 
 
 
 
 
 
 
 
RA.L3-3.11.3e – Advanced Risk Identification
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
56
 
''' '''
 
processes involves sending all email links and attachments to detonation chambers or
 
sandboxes prior to delivery to the recipient. When the email is received, SOAR extracts all
 
URL links and attachments from the content and sends them for analysis and testing [a]. The
 
domains in the URLs and the full URLs are processed against bad domain and URL lists. Next,
 
a browser in a sandbox downloads the URLs for malware testing. Lastly, any attachments are
 
sent to detonation chambers to identify if they attempt malicious activities. The hash of the
 
attachments is sent to services to identify if it is known malware [b]. If any one of the items
 
triggers a malware warning from the sandbox, detonation chamber, domain/URL validation
 
service, attachment hash check services, or AV software, an alert about the original email is
 
sent to team members with the recommendation to quarantine it. The team is given the
 
opportunity to select a  “take action” button,  which would have the SOAR solution take
 
actions to block that email and similar emails from being received by the organization [c].
 
'''Potential Assessment Considerations <br />
'''•
 
  Has the organization implemented a security information and event management system
 
[a,c]?
 
 
  Has the organization implemented security orchestration, automation,  and response
 
tools [a,b,c]?
 
 
  Does the organization use automated  processing  integrated with the  SIEM system  to
 
perform analytics [c]?
 
 
  Can the organization demonstrate use  of relevant threat data to inform detection
 
methods that in turn provide automated alerts/recommendations [c]?
 
 
  Has the organization implemented an extended detection capability [c]?
 
 
  Does the organization have the ability to merge traditional cyber data, such as network
 
packet captures (e.g., PCAP), or process logs with enrichment data, such as reputation or
 
categorization data [c]? 
 
 
  Can the organization provide examples of both basic and emerging  analytics used to
 
analyze alert anomalies, e.g., both simple queries and unsupervised machine learning
 
algorithms  that  both improve their effectiveness and automatically filter, reduce, or
 
enrich alerting capabilities [c]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.11.3e
 
 
''' '''
 
 
 
 
 
 
 
 
 
RA.L3-3.11.4e – Security Solution Rationale
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
57
 
''' '''
 
'''RA.L3-3.11.4E – SECURITY SOLUTION RATIONALE '''
 
Document or reference in the system security plan the security solution selected, the
 
rationale for the security solution, and the risk determination.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] The system security plan documents or references the security solution selected; <br />
[b] The system security plan documents or references the rationale for the security solution;
 
and
 
[c] The system security plan documents or references the risk determination. 
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: system security plan; records of security plan reviews and updates; system
 
design documentation; security planning policy; procedures addressing security plan
 
development; procedures addressing security plan reviews and updates; enterprise
 
architecture documentation; enterprise  security architecture documentation; system
 
interconnection security agreements and other information exchange agreements; other
 
relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for information security;
 
organizational personnel responsible for developing, implementing, or approving system
 
interconnection and information exchange agreements; personnel managing the systems to
 
which the Interconnection Security Agreement/Information Exchange Agreement applies;
 
system developers; organizational personnel responsible for security planning and plan
 
implementation; organizational personnel responsible for boundary protection; system
 
developers; system/network administrators].
 
'''Test <br />
'''[SELECT FROM: Organizational processes for security plan development, review, update,
 
and approval].
 
'''DISCUSSION [NIST SP 800-172] '''
 
System security plans relate security requirements to a set of security controls and solutions.
 
The plans describe how the controls and solutions meet the security requirements. For the
 
enhanced security requirements selected when the APT is a concern,  the security plan
 
provides traceability between threat and risk assessments and the risk-based selection of a
 
security solution, including discussion of relevant analyses of alternatives and rationale for
 
 
 
 
 
 
 
 
 
RA.L3-3.11.4e – Security Solution Rationale
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
58
 
''' '''
 
key security-relevant architectural and design decisions. This level of detail is important as
 
the threat changes, requiring reassessment of the risk and the basis for previous security
 
decisions. <br />
When incorporating external service providers into the system security plan, organizations
 
state the type of service provided (e.g., software as a service, platform as a service), the point
 
and type of connections  (including ports and protocols), the nature and type of the
 
information flows to and from the service provider, and the security controls implemented
 
by the service provider. For safety critical systems, organizations document situations for
 
which safety is the primary reason for not implementing a security solution (i.e., the solution
 
is appropriate to address the threat but causes a safety concern). <br />
[NIST SP 800-18] provides guidance on the development of system security plans.
 
'''FURTHER DISCUSSION '''
 
The System Security Plan (SSP) is a fundamental component of an organization’s security
 
posture. When solutions for implementing a requirement have differing levels of capabilities
 
associated with their implementation, it is essential that the plan specifically document the
 
rationale for the selected solution and what was acquired for the implementation.  This
 
information allows the organization to monitor the environment for threat changes and
 
identify which solutions may no longer be applicable. While not required, it may also be
 
useful to document alternative solutions reviewed and differing levels of risk associated with
 
each alternative, as that information may facilitate future analyses when the threat changes.
 
In addition to the implementations required for Level 2 certification, which may not be risk
 
based, at Level 3, the SSP must carefully document the link between the assessed threat and
 
the risk-based selection of a security solution for the enhanced security requirements (i.e.,
 
all CMMC L3 requirements derived from NIST SP 800-172).
 
'''Example <br />
'''You are responsible for information security in your organization. Following CMMC
 
requirement  RA.L3-3.11.1e  –  ''Threat Informed Risk Assessment'',  your team uses threat
 
intelligence to complete a risk assessment and make a risk determination for all elements of
 
your enterprise.  Based on that view of risk, your team decides that requirement
 
RA.L3-3.11.2e – ''Threat Hunting'' is a requirement that is very important in protecting your
 
organization’s use of CUI, and you have determined the solution selected could potentially
 
add risk. You want to detect an adversary as soon as possible when they breach the network
 
before any CUI can be exfiltrated. However, there are multiple threat hunting solutions, and
 
each solution has a different set of features that will provide different success rates in
 
identifying IOCs. <br />
As a result, some solutions increase the risk to the organization by being less capable in
 
detecting and tracking an adversary in your networks. To reduce risk, you evaluate five
 
threat hunting solutions and in each case determine the number of IOCs for which there is a
 
monitoring mechanism. You pick the solution that is cost effective, easy to operate, and
 
optimizes IOC detection for your enterprise; purchase, install, and train SOC personnel on its
 
use; and document the risk-based analysis  of  alternatives in the SSP. In creating that
 
 
 
 
 
 
 
 
 
RA.L3-3.11.4e – Security Solution Rationale
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
59
 
''' '''
 
documentation in the SSP, you follow the guidance found in NIST  SP 800-18,  ''Guide for ''
 
''Developing Security Plans for Federal Information Systems'' [a,b,c].
 
'''Potential Assessment Considerations <br />
'''•
 
  Has the organization completed a risk assessment and made a risk determinations for
 
enterprise components that need to be protected [c]?
 
 
  Can the organization identify what is being protected and explain why specific protection
 
solutions were selected [a,b]?
 
 
  Have all the decisions been documented in the SSP [a,b,c]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.11.4e
 
 
''' '''
 
 
 
 
 
 
 
 
 
RA.L3-3.11.5e – Security Solution Effectiveness
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
60
 
''' '''
 
'''RA.L3-3.11.5E – SECURITY SOLUTION EFFECTIVENESS '''
 
Assess the effectiveness of security solutions at least annually or upon receipt of relevant
 
cyber threat information, or in response to a relevant cyber incident, to address anticipated
 
risk to organizational systems and the organization based on current and accumulated threat
 
intelligence.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Security solutions are identified; <br />
[b] Current and accumulated threat intelligence is identified; <br />
[c] Anticipated risk to organizational systems and the organization based on current and
 
accumulated threat intelligence is identified; and
 
[d] The effectiveness of security solutions is assessed at least annually or upon receipt of
 
relevant cyber threat information, or in response to a relevant cyber incident, to address
 
anticipated risk to organizational systems and the organization based on current and
 
accumulated threat intelligence.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Risk assessment policy; security planning policy and procedures; security
 
assessment policy and procedures; security assessment plans; security assessment results;
 
procedures addressing organizational assessments of risk; security plan; risk assessment;
 
risk assessment results; risk assessment reviews; risk assessment updates; threat
 
intelligence information; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for security assessments;
 
organizational personnel responsible for risk assessments; organizational personnel
 
responsible for threat analysis; organizational personnel responsible for information
 
security].
 
'''Test <br />
'''[SELECT FROM: Mechanisms supporting, conducting, documenting, reviewing,
 
disseminating, and updating risk assessments; mechanisms supporting and/or
 
implementing security assessments].
 
 
 
 
 
 
 
 
 
RA.L3-3.11.5e – Security Solution Effectiveness
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
61
 
''' '''
 
'''DISCUSSION [NIST SP 800-172] '''
 
Threat awareness and risk assessment of the organization are dynamic, continuous, and
 
inform system operations, security requirements for the system, and the security solutions
 
employed to meet those requirements. Threat intelligence (i.e., threat information that has
 
been aggregated, transformed, analyzed, interpreted, or enriched to help provide the
 
necessary context for decision making) is infused into the risk assessment processes and
 
information security operations of the organization to identify any changes required to
 
address the dynamic threat environment. <br />
[NIST SP  800-30] provides guidance on risk assessments, threat assessments, and risk
 
analyses.
 
'''FURTHER DISCUSSION '''
 
This requirement requires the organization to analyze threat intelligence and consider the
 
effectiveness of currently deployed cybersecurity solutions against existing, new, and
 
emerging threats. The goal is to understand the risk to the systems and the organization
 
based on threat intelligence and to make adjustments to security solutions to reduce the risk
 
to an acceptable level. Analysis of solutions should include analysis of operational system
 
settings of the deployed systems and not be solely a conceptual capability analysis. This
 
analysis includes verifying configuration settings are configured as desired by the
 
organization and have not been changed over time. <br />
Threat information can be thought of as raw data that may be limited in terms of evaluating
 
the effectiveness of controls across the enterprise. For example, knowledge of a threat that
 
has not been correlated with other threats may result in evaluation of an implementation
 
that only provides partial protection for one set of systems when, in fact, the emerging threat
 
is applicable to the entire enterprise. Large organizations may also have the resources to
 
aggregate, transform, analyze, correlate, interpret, and enrich information to support
 
decision-making about adequacy of existing security mechanisms and methods.
 
'''Example <br />
'''You are responsible for information security in your organization, which holds and
 
processes CUI. The organization subscribes to multiple threat intelligence sources [b]. In
 
order to assess the effectiveness of current security solutions, the security team analyzes any
 
new incidents reported in the threat feed. They identify weaknesses that were leveraged by
 
malicious actors and subsequently look for similar weaknesses in their own security
 
architecture[a,c]. This analysis is passed to the architecture team for engineering change
 
recommendations, including system patching guidance, new sensors, and associated alerts
 
that should be generated, and to identify ways to mitigate, transfer, or accept the risk
 
necessary to respond to events if they occur within their own organization [d].
 
 
 
 
 
 
 
 
 
RA.L3-3.11.5e – Security Solution Effectiveness
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
62
 
''' '''
 
'''Potential Assessment Considerations <br />
'''•
 
  Does the organization make adjustments during an incident or operational
 
improvements after an incident has occurred [d]?
 
 
  Has the organization implemented an analytical process to assess the effectiveness of
 
security solutions against new or compiled threat intelligence [b,c,d]?
 
 
  Has the organization implemented  a process to identify if an operational security
 
solution fails to contribute to the protections needed against specific adversarial actions
 
based on new threat intelligence [a,b,c,d]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.11.5e
 
 
''' '''
 
 
 
 
 
 
 
 
 
RA.L3-3.11.6e – Supply Chain Risk Response
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
63
 
''' '''
 
'''RA.L3-3.11.6E – SUPPLY CHAIN RISK RESPONSE '''
 
Assess, respond to, and monitor supply chain risks associated with organizational systems
 
and system components.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Supply chain risks associated with organizational systems and system components are
 
identified;
 
[b] Supply chain risks associated with organizational systems and system components are
 
assessed;
 
[c] Supply chain risks associated with organizational systems and system components are
 
responded to; and
 
[d] Supply chain risks associated with organizational systems and system components are
 
monitored.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Risk assessment policy; procedures addressing organizational assessments
 
of risk; security planning policy and procedures; supply chain risk management plan;
 
security plan; risk assessment; risk assessment results; risk assessment reviews; risk
 
assessment updates; threat intelligence information; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for information security;
 
organizational personnel responsible for risk assessments; organizational personnel
 
responsible for supply chain risk management].
 
'''Test <br />
'''[SELECT FROM: Mechanisms supporting, conducting, documenting, reviewing,
 
disseminating, and updating risk assessments].
 
'''DISCUSSION [NIST SP 800-172] '''
 
Supply chain events include disruption, use of defective components, insertion of
 
counterfeits, theft, malicious development practices, improper delivery practices, and
 
insertion of malicious code. These events can have a significant impact on a system and its
 
information and, therefore, can also adversely impact organizational operations (i.e.,
 
mission, functions, image, or reputation), organizational assets, individuals, other
 
organizations, and the Nation. The supply chain-related events may be unintentional or
 
malicious and can occur at any point during the system life cycle. An analysis of supply chain
 
 
 
 
 
 
 
 
 
RA.L3-3.11.6e – Supply Chain Risk Response
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
64
 
''' '''
 
risk can help an organization identify systems or components for which additional supply
 
chain risk mitigations are required. <br />
[NIST SP  800-30] provides guidance on risk assessments, threat assessments, and risk
 
analyses. [NIST SP 800-161 Rev. 1] provides guidance on supply chain risk management.
 
'''FURTHER DISCUSSION '''
 
Organizations will have varying policies, definitions, and actions for this requirement. It is
 
important for a single organization to be consistent and to build a process that makes sense
 
for their organization, strategy, unique supply chain, and the technologies available to them.
 
'''Example ''' <br />
You are responsible for information security in your organization,  which holds and
 
processes CUI. One of your responsibilities is to manage risk associated with your supply
 
chain that may provide an entry point for the adversary. First, you acquire threat information
 
by subscribing to reports that identify supply chain attacks in enough detail that you are able
 
to identify the risk points in your organization’s supply chain [a]. You create an organization-
 
defined prioritized list of risks the organization may encounter and determine the responses
 
to be implemented to mitigate those risks [b,c]. <br />
In addition to incident information, the intelligence provider also makes recommendations
 
for monitoring and auditing your supply chain. You assess, integrate, correlate, and analyze
 
this information so you can use it to acquire monitoring tools to help identify supply chain
 
events that could be an indicator of an incident. This monitoring tool provides visibility of
 
the entire attack surface, including your vendors’ security posture [d]. Second, you analyze
 
the incident information in the intelligence report to help identify defensive tools that will
 
help respond to each of those known supply chain attack techniques as soon as possible after
 
such an incident is detected, thus mitigating risk associated with known techniques.
 
'''Potential Assessment Considerations <br />
'''•
 
  Has the organization prioritized risks to the supply chain [a,b]?
 
 
  Does the organization have viable service-level agreements that describe and enable
 
responses to supply chain incidents [c,d]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.11.6e
 
 
''' '''
 
 
 
 
 
 
 
 
 
RA.L3-3.11.7e – Supply Chain Risk Plan
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
65
 
''' '''
 
'''RA.L3-3.11.7E – SUPPLY CHAIN RISK PLAN '''
 
Develop a plan for managing supply chain risks associated with organizational systems and
 
system components; update the plan at least annually, and upon receipt of relevant cyber
 
threat information, or in response to a relevant cyber incident.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Supply chain risks associated with organizational systems and system components are
 
identified;
 
[b] Organizational systems and system components to include in a supply chain risk
 
management plan are identified;
 
[c] A plan for managing supply chain risks associated with organizational systems and
 
system components is developed; and
 
[d] The plan for managing supply chain risks is updated at least annually, and upon receipt
 
of relevant cyber threat information, or in response to a relevant cyber incident.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Risk assessment policy; supply chain risk management plan; security
 
planning policy and procedures; procedures addressing organizational assessments of risk;
 
security plan; risk assessment; risk assessment results; risk assessment reviews; risk
 
assessment updates; threat intelligence information; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for information security;
 
organizational personnel responsible for risk assessments; organizational personnel
 
responsible for supply chain risk management].
 
'''Test <br />
'''[SELECT FROM: Automated mechanisms supporting, conducting, documenting, reviewing,
 
disseminating, and updating risk assessments].
 
'''DISCUSSION [NIST SP 800-172] '''
 
The growing dependence on products, systems, and services from external providers, along
 
with the nature of the relationships with those providers, present an increasing level of risk
 
to an organization. Threat actions that  may increase risk include the insertion or use of
 
counterfeits, unauthorized production, tampering, theft, insertion of malicious software and
 
hardware, and poor manufacturing and development practices in the supply chain. Supply
 
chain risks can be endemic or systemic within a system element or component, a system, an
 
 
 
 
 
 
 
 
 
RA.L3-3.11.7e – Supply Chain Risk Plan
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
66
 
''' '''
 
organization, a sector, or the Nation. Managing supply chain risk is a multifaceted
 
undertaking that requires a coordinated effort across an organization to build trust
 
relationships and communicate with both internal and external stakeholders. Supply chain
 
risk management (SCRM) activities involve identifying and assessing risks, determining
 
appropriate mitigating actions, developing SCRM plans to document selected mitigating
 
actions, and monitoring performance against plans. SCRM plans address requirements for
 
developing trustworthy, secure, and resilient systems and system components, including the
 
application of the security design principles implemented as part of life cycle-based systems
 
security engineering processes. <br />
[NIST SP 800-161 Rev. 1] provides guidance on supply chain risk management.
 
'''FURTHER DISCUSSION '''
 
An organization is required to have a supply chain risk management plan that assesses and
 
responds to the identified risks from those organizations that provide IT products or
 
services, including any cloud or other third-party services with a role in the operation of the
 
system. The organization should be cognizant of services outside the scope of the system but
 
required for the operation of the system as part of their plan. Since the cyber environment
 
changes rapidly and continuously, it is equally important for the organization to update the
 
plan in response to supply chain cyber incidents or emerging information.
 
'''Example <br />
'''You are responsible for information security in your organization, and you have created a
 
supply chain risk management plan [a,b,c]. One of the organization’s suppliers determines
 
that it has been the victim of a cyberattack. Your security team meets with the supplier to
 
determine the nature of the attack and to understand the adversary, the attack, the potential
 
for corruption of delivered goods or services, and  current as well as future risks.  The
 
understanding of the supply chain will help protect the local environment. Subsequently, you
 
update the risk management plan to include a description of the necessary configuration
 
changes or upgrades to monitoring tools to improve the ability to identify the new risks, and
 
when  improved tools are available, you document the acquisition of defensive tools  and
 
associated functionality to help mitigate any of the identified techniques [d].
 
'''Potential Assessment Considerations <br />
'''•
 
  Does the organization’s current supply chain risk management plan apply across the
 
enterprise, or does it only apply to a limited portion of the supply chain [b]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.11.7e
 
 
 
 
 
 
 
 
 
CA.L3-3.12.1e – Penetration Testing
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
67
 
''' '''
 
Security Assessment (CA) <br />
'''CA.L3-3.12.1E – PENETRATION TESTING '''
 
Conduct penetration testing at least annually or when significant security changes are made
 
to the system, leveraging automated scanning tools and ad hoc tests using subject matter
 
experts.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Automated scanning tools are identified; <br />
[b] Ad hoc tests using subject matter experts are identified; and <br />
[c] Penetration testing is conducted at least annually or when significant security changes
 
are made to the system,  leveraging automated scanning tools and ad hoc tests using
 
subject matter experts.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Security assessment policy; procedures addressing penetration testing;
 
security plan; security assessment plan; penetration test report; security assessment report;
 
security assessment evidence; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for security assessments; penetration
 
testing team; system/network administrators; organizational personnel responsible for
 
information security].
 
'''Test <br />
'''[SELECT FROM: Automated mechanisms supporting security assessments; automated
 
mechanisms supporting penetration testing].
 
'''DISCUSSION [NIST SP 800-172] '''
 
Penetration testing is a specialized type of assessment conducted on systems or individual
 
system components to identify vulnerabilities that could be exploited by adversaries.
 
Penetration testing goes beyond automated vulnerability scanning. It is conducted by
 
penetration testing agents and teams with particular skills and experience that include
 
technical expertise in network, operating system, and application-level security. Penetration
 
testing can be used to validate vulnerabilities or determine a system’s penetration resistance
 
to adversaries within specified constraints. Such constraints include time, resources, and
 
 
 
 
 
 
 
 
 
CA.L3-3.12.1e – Penetration Testing
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
68
 
''' '''
 
skills. Organizations may also supplement penetration testing with red team exercises. Red
 
teams attempt to duplicate the actions of adversaries in carrying out attacks against
 
organizations and provide an in-depth analysis of security-related weaknesses or
 
deficiencies. <br />
Organizations can use the results of vulnerability analyses to support penetration testing
 
activities. Penetration testing can be conducted internally or externally on the hardware,
 
software, or firmware components of a system and can exercise both physical and technical
 
controls. A standard method for penetration testing includes pretest analysis based on full
 
knowledge of the system, pretest identification of potential vulnerabilities based on the
 
pretest analysis, and testing designed to determine the exploitability of vulnerabilities. All
 
parties agree to the specified rules of engagement before the commencement of penetration
 
testing. Organizations correlate the rules of engagement for penetration tests and red
 
teaming exercises (if used) with the tools, techniques, and procedures that they anticipate
 
adversaries may employ. The penetration testing or red team exercises may be organization-
 
based or external to the organization. In either case, it is important that the team possesses
 
the necessary skills and resources to do the job and is objective in its assessment. <br />
[NIST SP 800-53A] provides guidance on conducting security assessments.
 
'''FURTHER DISCUSSION '''
 
It is important  that the organization has a repeatable penetration testing capability,
 
regardless of who performs the penetration testing. This requirement entails performing
 
tests against components of the organization’s architecture to identify cyber weaknesses and
 
vulnerabilities. It does not mean everything in the architecture requires penetration testing.
 
This requirement provides findings and mitigation strategies that benefit the organization
 
and help create a stronger environment against adversary efforts. It may be beneficial for
 
the organization to define the scope of penetration testing. The organization’s approach may
 
involve  hiring an expert penetration testing team to perform testing on behalf of the
 
organization. When an organization has penetration testing performed, either by an internal
 
team or external firm, they should establish rules of engagement and impose limits on what
 
can be performed by the penetration test team(s). <br />
Ensuring the objectivity of the test team is important as well. Potential conflicts of interest,
 
such as having internal testers report directly or indirectly to network defenders or an
 
external test team contracted by network defense leadership, must be carefully managed by
 
organizational leadership. <br />
Reports on the findings should be used by the organization to determine where to focus
 
funding, staffing, training, or technical improvements for future mitigation strategies.
 
 
 
 
 
 
 
 
 
CA.L3-3.12.1e – Penetration Testing
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
69
 
''' '''
 
'''Example <br />
'''You are responsible for information security in your organization. Leveraging  a contract
 
managed by the CIO,  you hire  an external expert penetration team  annually  to test the
 
security of the organization’s enclave that stores and processes CUI [a,c]. You hire the same
 
firm annually or on an ad hoc basis when significant changes are made to the architecture or
 
components that affect security [b,c].
 
'''Potential Assessment Considerations <br />
'''•
 
  Does the organization have internal team members who  possess the proper level of
 
expertise to perform a valued penetration testing effort [b]?
 
 
  If the penetration  testing  is  performed  by an internal team, are the individuals
 
performing the testing objectively [b]?
 
 
  Is  a  penetration  testing final report  provided  to the internal  team  responsible for
 
organizational defense?
 
 
  If previous penetration tests have been conducted, can the organization provide samples
 
of penetration test plans, findings reports, and mitigation guidance based on the findings
 
[a,b,c]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.12.1e
 
 
 
 
 
 
 
 
 
SC.L3-3.13.4e – isolation
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
70
 
''' '''
 
System and Communications Protection (SC) <br />
'''SC.L3-3.13.4E – ISOLATION '''
 
Employ physical isolation techniques or logical isolation techniques or both in organizational
 
systems and system components.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[ODP1] One or more of the following is/are selected: physical isolation techniques;
 
logical isolation techniques; <br />
[ODP2] Physical isolation techniques are defined (if selected); <br />
[ODP3] Logical isolation techniques are defined (if selected); <br />
[a] Physical isolation techniques or logical isolation techniques or both  are employed in
 
organizational systems and system components.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: System and communications protection policy; procedures addressing
 
boundary protection; system design documentation; procedures addressing the use of thin
 
nodes; list of key internal boundaries of the system; security plan; boundary protection
 
hardware and software; system configuration settings and associated documentation;
 
enterprise architecture documentation; system architecture; security architecture
 
documentation; system audit records; system component inventory; list of security tools and
 
support components to be isolated from other system components; other relevant
 
documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for information security;
 
system/network administrators; system developers; organizational personnel responsible
 
for boundary protection].
 
'''Test <br />
'''[SELECT FROM: Mechanisms implementing the boundary protection capability; mechanisms
 
implementing physical isolation techniques; mechanisms supporting and/or implementing
 
the isolation of information security tools, mechanisms, and support components;
 
mechanisms supporting and/or implementing the capability to separate system components
 
supporting organizational missions and business functions; mechanisms implementing
 
 
 
 
 
 
 
 
 
SC.L3-3.13.4e – isolation
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
71
 
''' '''
 
logical isolation techniques; mechanisms supporting or implementing separate network
 
addresses/different subnets; mechanisms supporting and/or implementing thin nodes].
 
'''DISCUSSION [NIST SP 800-172] '''
 
A mix of physical and logical isolation techniques (described below) implemented as part of
 
the system architecture can limit the unauthorized flow of CUI, reduce the system attack
 
surface, constrain the number of system components that must be secure, and impede the
 
movement of an adversary. When implemented with a set of managed interfaces, physical
 
and logical isolation techniques for organizational systems and components can isolate CUI
 
into separate security domains where additional protections can be implemented. Any
 
communications across the managed interfaces (i.e., across security domains), including for
 
management or administrative purposes, constitutes remote access even if the
 
communications remain within the organization. Separating system components with
 
boundary protection mechanisms allows for the increased protection of individual
 
components and more effective control of information flows between those components.
 
This enhanced protection limits the potential harm from and susceptibility to hostile cyber-
 
attacks and errors. The degree of isolation can vary depending on the boundary protection
 
mechanisms selected. Boundary protection mechanisms include routers, gateways, and
 
firewalls separating system components into physically separate networks or subnetworks;
 
virtualization and micro-virtualization techniques; encrypting information flows among
 
system components using distinct encryption keys; cross-domain devices separating
 
subnetworks; and complete physical separation (i.e., air gaps). <br />
System architectures include logical isolation, partial physical and logical isolation, or
 
complete physical isolation between subsystems and at system boundaries between
 
resources that store, process, transmit, or protect CUI and other resources. Examples
 
include: <br />
 
  Logical isolation: Data tagging, digital rights  management (DRM), and data loss
 
prevention (DLP) that tags, monitors, and restricts the flow of CUI; virtual machines or
 
containers that separate CUI and other information on hosts; and virtual local area
 
networks (VLAN) that keep CUI and other information separate on networks.
 
 
  Partial physical and logical isolation: Physically or cryptographically isolated networks,
 
dedicated hardware in data centers, and secure clients that (a) may not directly access
 
resources outside of the domain (i.e., all applications with cross-enclave connectivity
 
execute as remote virtual applications hosted in a demilitarized zone [DMZ] or internal
 
and protected enclave), (b) access via remote virtualized applications or virtual desktop
 
with no file transfer capability other than  with dual authorization, or (c) employ
 
dedicated client hardware (e.g., a zero or thin client) or hardware approved for multi-
 
level secure (MLS) usage.
 
 
  Complete physical isolation: Dedicated (not shared) client and server hardware;
 
physically isolated, stand-alone enclaves for clients and servers; and (a) logically
 
separate network traffic (e.g., using a VLAN) with end-to-end encryption using Public Key
 
Infrastructure (PKI)-based cryptography or (b) physical isolation from other networks.
 
 
 
 
 
 
 
 
 
SC.L3-3.13.4e – isolation
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
72
 
''' '''
 
Isolation techniques are selected based on a risk management perspective that balances the
 
threat, the information being protected, and the cost of the options for protection.
 
Architectural and design decisions are guided and informed by the security requirements
 
and selected solutions. Organizations consider the trustworthiness of the isolation
 
techniques employed (e.g., the logical isolation relies on information technology that could
 
be considered a high value target because of the function being performed), introducing its
 
own set of vulnerabilities. <br />
[NIST SP  800-160-1] provides guidance on developing trustworthy, secure, and cyber
 
resilient systems using systems security engineering practices and security design concepts.
 
'''FURTHER DISCUSSION '''
 
For this requirement, organizations must identify the systems or enclaves that need to be
 
isolated,  then design and implement the isolation.  The resulting isolation solutions are
 
documented  or referenced in the SSP.  Documentation will be dependent on the design
 
selected and may include a high-level diagram, but specific details that may change on some
 
frequency would be omitted. During an assessment, providing details such as subnet and
 
VLAN implementation identifiers, internal boundary protection hardware and software,
 
interface device functionality, and system configuration and  Access Control List (ACL)
 
settings will be useful.
 
'''Example <br />
'''You are responsible for information security in your organization,  which holds and
 
processes CUI. You have decided  to isolate the  systems processing  CUI  by limiting all
 
communications in and out that enclave with cross-domain interface devices that implement
 
access control [a]. Your security team has identified all the systems containing such CUI,
 
documented network design details, developed network diagrams showing access control
 
points, documented the logic for the access control enforcement decisions, described the
 
interface and protocol to the identification and authentication mechanisms, and documented
 
all details associated with the ACLs, including review, updates, and credential revocation
 
procedures.
 
'''Potential Assessment Considerations <br />
'''•
 
  Has the organization clearly identified where they use physical, logical, or both isolation
 
techniques [a]?
 
 
  Can the organization describe the isolation techniques they have employed [a]?
 
 
  Has the organization deployed subnetting, internal firewalls, and VLANs  to control
 
packet flow between internal segments [a]?
 
 
  Does the organization employ metadata to inform isolation techniques [a]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.13.4e
 
 
 
 
 
 
 
 
 
SI.L3-3.14.1e – Integrity Verification
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
73
 
''' '''
 
System and Information Integrity (SI) <br />
'''SI.L3-3.14.1E – INTEGRITY VERIFICATION '''
 
Verify the integrity of security critical and essential software using root of trust mechanisms
 
or cryptographic signatures.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[ODP1] Security critical or essential software is defined; <br />
[a] Root of trust mechanisms or cryptographic signatures are identified; and <br />
[b] The integrity of security critical and essential software  is verified using root of trust
 
mechanisms or cryptographic signatures.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: System and information integrity policy; procedures addressing software,
 
firmware, and information integrity; system design documentation; security plan; system
 
configuration settings and associated documentation; system component inventory;
 
integrity verification tools and associated documentation; records of integrity verification
 
scans; system audit records; cryptographic mechanisms and associated documentation;
 
records of detected unauthorized changes to software, firmware, and information; other
 
relevant documents or records].
 
'''Interview <br />
'''[SELECT  FROM:  Organizational personnel responsible for information security;
 
organizational personnel responsible for software, firmware, and/or information integrity;
 
system developers; system/network administrators].
 
'''Test <br />
'''[SELECT FROM: Software, firmware, and information integrity verification tools;
 
mechanisms supporting and/or implementing integrity verification of the boot process;
 
mechanisms supporting and/or implementing protection of the integrity of boot firmware;
 
cryptographic mechanisms implementing software, firmware, and information integrity;
 
safeguards implementing protection of the integrity of boot firmware].
 
 
 
 
 
 
 
 
 
SI.L3-3.14.1e – Integrity Verification
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
74
 
''' '''
 
'''DISCUSSION [NIST SP 800-172] '''
 
Verifying the integrity of the organization’s security-critical or essential software is an
 
important capability since corrupted software is the primary attack vector used by
 
adversaries to undermine or disrupt the proper functioning of organizational systems. There
 
are many ways to verify software integrity throughout the system development life cycle.
 
Root of trust mechanisms (e.g., secure boot, trusted platform modules, Unified Extensible
 
Firmware Interface [UEFI]), verify that only trusted code is executed during boot processes.
 
This capability helps system components protect the integrity of boot firmware in
 
organizational systems by verifying the integrity and authenticity of updates to the firmware
 
prior to applying changes to the system component and preventing unauthorized processes
 
from modifying the boot firmware. The employment of cryptographic signatures ensures the
 
integrity and authenticity of critical and essential software that stores, processes, or
 
transmits, CUI. Cryptographic signatures include digital signatures and the computation and
 
application of signed hashes using asymmetric cryptography, protecting the confidentiality
 
of the key used to generate the hash, and using the public key to verify the hash information.
 
Hardware roots of trust are considered to be more secure. This requirement supports 3.4.1e
 
and 3.4.3.e. <br />
[FIPS 140-3] provides security requirements for cryptographic modules. [FIPS 180-4] and
 
[FIPS 202] provide secure hash standards. [FIPS 186-4] provides a digital signature
 
standard.  [NIST SP  800-147] provides BIOS protection guidance. [NIST TRUST] provides
 
guidance on the roots of trust project.
 
'''FURTHER DISCUSSION '''
 
Organizations verify the integrity of security critical and essential software every time that
 
software  is executed.  Secure boot mechanisms for firmware and a cryptographically
 
protected boot chain ensure the integrity of the operating system (OS) and security critical
 
software, and cryptographic techniques ensure  the  essential  software has not been
 
tampered with after development prior to execution. If software is itself considered to be
 
CUI or if it uses CUI, this requirement ensures it has not been compromised. <br />
Software and information integrity verification tools can help check the integrity during the
 
development process for those organizations developing software. As critical software is
 
updated, the integrity of any configuration data and the software must result in updated
 
signatures and an ongoing verification process. <br />
Operating systems include mechanisms to validate digital signatures for installed software.
 
Most software packages use signatures to prove the integrity of the provided software, and
 
the organization should leverage these capabilities.  Similarly, most hardware appliance
 
vendors have secure boot checks in place for their devices and built-in features that check
 
the digital signature of an upgrade/update package before they allow an upgrade to take
 
place. For locally developed software, the organization should sign the software to ensure its
 
integrity.
 
 
 
 
 
 
 
 
 
SI.L3-3.14.1e – Integrity Verification
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
75
 
''' '''
 
'''Example 1 <br />
'''You are responsible for information security in your organization. Your security team has
 
identified the software used to process CUI, and the organization has decided it is mission-
 
critical software that must be protected. You take three actions. First, you ensure all of the
 
platform’s configuration information used at boot is hashed and stored in a TPM [a]. Second,
 
you ensure that the platforms used to execute the software are started with a digitally signed
 
software chain to a secure boot process using the TPM. Finally, you ensure the essential
 
applications are cryptographically protected with a digital signature when stored and the
 
signature is verified prior to execution [b].
 
'''Example 2 <br />
'''Your organization has a software security team, and they are required to validate unsigned
 
essential software provided to systems that do not have TPM modules. The organization has
 
a policy stating no software can be executed on a system unless its hash value matches that
 
of a hash stored in the approved software library kept by the software security team [a]. This
 
action is performed by implementing software restriction policies on systems.  The team
 
tests the software on a sandbox system,  and once it is proven safe, they run a hashing
 
function on the software to create a hash value. This hash value is placed in a software library
 
so the system will know it can execute the software [b]. Any changes to the software without
 
the software security team’s approval will result in the software failing the security tests,
 
and it will be prevented from executing.
 
'''Potential Assessment Considerations <br />
'''•
 
  Does the organization use cryptographic signatures to ensure the integrity and
 
authenticity of critical and essential software and data [b]?
 
 
  Has the organization identified those devices that require integrity verification of the
 
boot process [a]?
 
 
  Does the organization use a TPM to store  hashes  of  pre-run time configuration
 
parameters for those systems [b]?
 
 
  Does the organization leverage the TPM configuration hash to verify the hardware and
 
software configuration is unchanged in order to determine that a system is trustworthy
 
before running mission-essential applications [b,c]?
 
 
  Does the organization use the TPM for remote attestation to determine to which extent
 
information can be trusted from another system [b,c]?
 
 
  Has the organization identified devices requiring organization-defined security
 
safeguards that must be implemented to protect the integrity of boot firmware [a]?
 
 
  Has the organization defined security safeguards that will be implemented to protect the
 
integrity of boot firmware in mission-essential devices [a]?
 
 
  Has the organization implemented organization-defined security safeguards to protect
 
the integrity of boot firmware in organization-defined essential devices [b]?
 
 
 
 
 
 
 
 
 
SI.L3-3.14.1e – Integrity Verification
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
76
 
''' '''
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.14.1e
 
 
''' '''
 
 
 
 
 
 
 
 
 
SI.L3-3.14.3e – Specialized Asset Security
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
77
 
''' '''
 
'''SI.L3-3.14.3E – SPECIALIZED ASSET SECURITY '''
 
Ensure that specialized assets including IoT, IIoT, OT, GFE, Restricted Information Systems
 
and test equipment  are included in the scope of the specified enhanced security
 
requirements or are segregated in purpose-specific networks.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[a] Specialized assets including IoT, IIoT, OT, GFE, Restricted Information Systems and test
 
equipment are included in the scope of the specified enhanced security requirements;
 
and
 
[b] Systems and system components that are not included in specialized assets including IoT,
 
IIoT, OT, GFE, Restricted Information Systems and test equipment  are segregated in
 
purpose-specific networks.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: Access control policy; information flow control policies; system and services
 
acquisition policy; system and communications protection policy; procedures addressing
 
security function isolation; procedures addressing application partitioning; procedures
 
addressing security engineering principles used in the specification, design, development,
 
implementation, and modification of the system; procedures addressing information flow
 
enforcement; procedures addressing access enforcement; system architecture; system
 
design documentation; security plan; system component inventory; system configuration
 
settings and associated documentation; system baseline configuration; list of security
 
functions to be isolated from non-security functions; system audit records; security
 
requirements and specifications for the system; list of approved authorizations (user
 
privileges); list of information flow authorizations; other relevant documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for access enforcement;
 
system/network administrators; organizational personnel responsible for information
 
security; system developers; system integrators; organizational personnel responsible for
 
acquisition/contracting; organizational personnel responsible for determining system
 
security requirements; system security architects; enterprise architects; organizational
 
personnel responsible for system specification, design, development, implementation, and
 
modification].
 
'''Test <br />
'''[SELECT FROM: Mechanisms implementing the access control policy; mechanisms
 
implementing the information flow enforcement policy; mechanisms supporting the
 
 
 
 
 
 
 
 
 
SI.L3-3.14.3e – Specialized Asset Security
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
78
 
''' '''
 
application of security engineering principles in system specification, design, development,
 
implementation, and modification].
 
'''DISCUSSION [NIST SP 800-172] '''
 
Organizations may have a variety of systems and system components in their inventory,
 
including Information Technology (IT), Internet of Things (IoT), Operational Technology
 
(OT), and Industrial Internet of Things (IIoT). The convergence of IT, OT, IoT, and IIoT
 
significantly increases the attack surface of organizations and provides attack vectors that
 
are challenging to address. Compromised IoT, OT, and IIoT system components can serve as
 
launching points for attacks on organizational IT systems that handle CUI. Some IoT, OT, and
 
IIoT system components can store, transmit, or process CUI (e.g., specifications or
 
parameters for objects manufactured in support of critical programs). Most of the current
 
generation of IoT, OT, and IIoT system components are not designed with security as a
 
foundational property and may not be able to be configured to support security functionality.
 
Connections to and from such system components are generally not encrypted, do not
 
provide the necessary authentication, are not monitored, and are not logged. Therefore,
 
these components pose a significant cyber threat. Gaps in IoT, OT, and IIoT security
 
capabilities may be addressed by employing intermediary system components that can
 
provide encryption, authentication, security scanning, and logging capabilities—thus,
 
preventing the components from being accessible from the Internet. However, such
 
mitigation options are not always available or practicable. The situation is further
 
complicated because some of the IoT, OT, and IIoT devices may be needed for essential
 
missions and business functions. In those instances, it is necessary for such devices to be
 
isolated from the Internet to reduce the susceptibility to cyber-attacks.  <br />
[NIST SP  800-160-1] provides guidance on security engineering practices and security
 
design concepts.
 
'''FURTHER DISCUSSION  '''
 
Specialized Assets are addressed in the scoping guidance, which should be overlaid on this
 
requirement. The OSC must document Specialized Assets in the asset inventory; develop,
 
document, and periodically update system security plans; and include Specialized Assets in
 
the network diagram. The Specialized Asset section of the SSP should describe associated
 
system boundaries, system environments of operation, how security requirements are
 
implemented, and the relationships with or connections to other systems. <br />
Specialized Assets within the Level  3  CMMC  assessment  scope  must  be  either  assessed
 
against all CMMC security  requirements  or  separated  into purpose-specific networks.
 
Specialized Assets may have limitations on the application of certain security requirements.
 
To accommodate such issues, the SSP should describe any mitigations. <br />
Intermediary devices are permitted to mitigate an inability for the asset itself to implement
 
one or more CMMC requirements. An example of an intermediary device used in conjunction
 
with a specialized asset is a boundary device or a proxy. <br />
The high-level list of Specialized Assets includes:
 
 
 
 
 
 
 
 
 
SI.L3-3.14.3e – Specialized Asset Security
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
79
 
''' '''
 
 
  Government Furnished Equipment;
 
 
  IoT and IIoT devices (physical or virtual) with sensing/actuation capability and
 
programmability features;
 
 
  OT  used  in manufacturing systems, industrial control systems (ICS), or supervisory
 
control and data acquisition (SCADA) systems;
 
 
  Restricted Information Systems, which can include systems and IT components that are
 
configured based on government requirements; and
 
 
  Test equipment.
 
'''Example <br />
'''You are responsible for information security in your organization, which processes CUI on
 
the network, and this same network includes GFE for which the configuration is mandated
 
by the government. The GFE is needed to process CUI information [a]. Because the company
 
cannot manage the configuration of the GFE, it has been augmented by placing a bastion host
 
between it and the network. The bastion host meets the requirements that the GFE cannot,
 
and is used to send CUI files to and from the GFE for processing. You and your security team
 
document in the SSP all of the GFE to include GFE connectivity diagrams, a description of the
 
isolation mechanism, and a description of how your organization manages risk associated
 
with that GFE [a].
 
'''Potential Assessment Considerations <br />
'''•
 
  Has the organization documented all specialized assets in asset inventory [a]?
 
 
  Has the organization documented all specialized assets in the SSP to show how risk is
 
managed [b]?
 
 
  Has the organization provided a network diagram for specialized assets [a,b]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.14.3e
 
 
''' '''
 
 
 
 
 
 
 
 
 
SI.L3-3.14.6e – Threat-Guided Intrusion Detection
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
80
 
''' '''
 
'''SI.L3-3.14.6E – THREAT-GUIDED INTRUSION DETECTION '''
 
Use threat indicator information and effective mitigations obtained from,  at a minimum,
 
open or commercial sources, and any DoD-provided sources, to guide and inform intrusion
 
detection and threat hunting.
 
'''ASSESSMENT OBJECTIVES [NIST SP 800-172A] '''
 
Determine if: <br />
[ODP1] External organizations from which to obtain threat indicator information and
 
effective mitigations are defined; <br />
[a] Threat indicator information is identified; <br />
[b] Effective mitigations are identified; <br />
[c] Intrusion detection approaches are identified; <br />
[d] Threat hunting activities are identified; and <br />
[e] Threat indicator information and effective mitigations obtained from,  at a minimum,
 
open or commercial sources and any DoD-provided sources, are used to guide and inform
 
intrusion detection and threat hunting.
 
'''POTENTIAL ASSESSMENT METHODS AND OBJECTS [NIST SP 800-172A] '''
 
'''Examine <br />
'''[SELECT FROM: System and information integrity policy; information security program plan;
 
procedures addressing security alerts, advisories, and directives; threat awareness program
 
documentation; procedures addressing system monitoring; procedures for the threat
 
awareness program; risk assessment results relevant to threat awareness; records of
 
security alerts and advisories; system design documentation; security plan; system
 
monitoring tools and techniques documentation; system configuration settings and
 
associated documentation; system monitoring logs or records; system audit records;
 
documentation on the cross-organization information-sharing capability; other relevant
 
documents or records].
 
'''Interview <br />
'''[SELECT FROM: Organizational personnel responsible for information security program
 
planning and plan implementation; system/network administrators; organizational
 
personnel responsible for the threat awareness program; organizational personnel
 
responsible for the cross-organization information-sharing capability; organizational
 
personnel responsible for information security; organizational personnel responsible for
 
installing, configuring, and/or maintaining the system; organizational personnel  security
 
alerts and advisories; organizational personnel responsible for  implementing, operating,
 
maintaining, and using the system; organizational personnel, organizational elements,
 
and/or external organizations to whom alerts, advisories, and directives are to be
 
 
 
 
 
 
 
 
 
SI.L3-3.14.6e – Threat-Guided Intrusion Detection
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
81
 
''' '''
 
disseminated; personnel with whom threat awareness information is shared by the
 
organization; system developers].
 
'''Test <br />
'''[SELECT FROM: Mechanisms supporting and/or implementing the threat awareness
 
program; mechanisms supporting and/or implementing the cross-organization information-
 
sharing capability; mechanisms supporting and/or implementing the system monitoring
 
capability; mechanisms supporting and/or implementing the definition, receipt, generation,
 
and dissemination of security alerts, advisories, and directives; mechanisms supporting
 
and/or implementing security  directives; mechanisms supporting and/or implementing
 
threat hunting; mechanisms supporting and/or implementing intrusion detection;
 
mechanisms supporting and/or implementing the discovery, collection, distribution, and use
 
of indicators of compromise].
 
'''DISCUSSION [NIST SP 800-172] '''
 
Threat information related to specific threat events (e.g., TTPs, targets) that organizations
 
have experienced, threat mitigations that organizations have found to be effective against
 
certain types of threats, and threat intelligence (i.e., indications and warnings about threats
 
that can occur) are sourced from and shared with trusted organizations. This threat
 
information can be used by organizational Security Operations Centers (SOC) and
 
incorporated into monitoring capabilities. Threat information sharing includes threat
 
indicators, signatures, and adversary TTPs from organizations participating in threat-
 
sharing consortia, government-commercial cooperatives, and government-government
 
cooperatives (e.g., CERTCC, CISA/US-CERT,  FIRST, ISAO, DIB CS Program). Unclassified
 
indicators, based on classified information but which can be readily incorporated into
 
organizational intrusion detection systems, are available to qualified nonfederal
 
organizations from government sources.
 
'''FURTHER DISCUSSION '''
 
One way to effectively leverage threat indicator information is to access human- or machine-
 
readable threat intelligence feeds. Effectiveness may also require the organization to create
 
TTPs in support of operational requirements, which will typically include defensive cyber
 
tools supporting incident detection,  alerts, incident response, and threat hunting.  It is
 
possible that this requirement  will be implemented by a  third-party managed service
 
provider, and in that  case,  it  will  be necessary to carefully define the boundary and
 
responsibilities between the OSC and the ESP to guarantee a robust implementation. It is also
 
important that the OSC validate threat indicator integration into the defensive cyber toolset
 
by  being able to (1)  implement  mitigations for sample industry relevant indicators  of
 
compromise (e.g., IP address, file hash), (2) identify sample indicators of compromise across
 
sample endpoints, and  (3) identify sample indicators  of compromise using analytical
 
processes on a system data repository.
 
 
 
 
 
 
 
 
 
SI.L3-3.14.6e – Threat-Guided Intrusion Detection
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
82
 
''' '''
 
'''Example <br />
'''You are responsible for information security in your organization. You have maintained an
 
effective intrusion detection capability for some time, but now you decide to introduce a
 
threat hunting capability informed by internal and external threat intelligence [a,c,d,e]. You
 
install a SIEM system that leverages threat information to provide functionality to: <br />
 
  analyze logs, data sources, and alerts;
 
 
  query data to identify anomalies;
 
 
  identify variations from baseline threat levels;
 
 
  provide machine learning capabilities associated with the correlation of anomalous data
 
characteristics across the enterprise; and
 
 
  categorize data sets based on expected data values.
 
Your team also manages an internal mitigation plan (playbook) for all known threats for your
 
environment. This playbook is used to implement effective mitigation strategies across the
 
environment [b]. Some of the mitigation strategies are developed by team members, and
 
others are obtained by threat feed services.
 
'''Potential Assessment Considerations <br />
'''•
 
  Which external sources has the organization identified as threat information sources [a]?
 
 
  Does the organization understand the TTPs of key attackers [c,d]?
 
 
  Does the organization deploy threat indicators to EDR systems, network  intrusion
 
detection systems, or both [c,d,e]?
 
 
  What actions does the organization implement when a threat alert/indicator is signaled
 
[c,d,e]?
 
 
  Does the organization use internal threat capabilities within their existing security tools
 
[e]?
 
 
  How does the organization respond to a third-party notification of a threat indicator [e]?
 
'''KEY REFERENCES '''
 
 
  NIST SP 800-172 3.14.6e
 
 
 
 
 
 
 
 
 
Appendix A – Acronyms and Abbreviations
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
83
 
''' '''
 
Appendix A – Acronyms and Abbreviations
 
AC
 
Access Control
 
ACL
 
Access Control List
 
ACM
 
Automated Configuration Management
 
ACMS
 
Automated Configuration Management System
 
APT
 
Advanced Persistent Threat
 
AT
 
Awareness and Training
 
C3PAO
 
CMMC Third-Party Assessment Organization
 
CA
 
Certification Authority
 
CA
 
Security Assessment
 
CERT
 
Computer Emergency Response Team
 
CFR
 
Code of Federal Regulations
 
CIO
 
Chief Information Officer
 
CIRT
 
Computer Incident Response Team; Cyber Incident Response Team
 
CISO
 
Chief Information Security Officer
 
CM
 
Configuration Management
 
CMMC
 
Cybersecurity Maturity Model Certification
 
CUI
 
Controlled Unclassified Information
 
DCSA
 
Defense Counterintelligence and Security Agency
 
DFARS
 
Defense Federal Acquisition Regulation Supplement
 
DIB
 
Defense Industrial Base
 
DLP
 
Data Loss Prevention
 
DMZ
 
Demilitarized Zone
 
DoD
 
Department of Defense
 
DRM
 
Digital Rights Management
 
ESP
 
External Service Provider
 
FIPS
 
Federal Information Processing Standard
 
GFE
 
Government Furnished Equipment
 
GPO
 
Group Policy Object
 
HR
 
Human Resources
 
IA
 
Identification and Authentication
 
ICS
 
Industrial Control System
 
IIoT
 
Industrial Internet of Things
 
IOC
 
Indicators of Compromise
 
IoT
 
Internet of Things
 
IP
 
Internet Protocol
 
IR
 
Incident Response
 
ISAC
 
Information Sharing and Analysis Center
 
 
 
 
 
 
 
 
 
Appendix A – Acronyms and Abbreviations
 
'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
 
84
 
''' '''
 
ISAO
 
Information Sharing and Analysis Organization
 
IT
 
Information Technology
 
MLS
 
Multi-Level Secure
 
N/A
 
Not Applicable
 
NAC
 
Network Access Control
 
NIST
 
National Institute of Standards and Technology
 
ODP
 
Organization-Defined Parameters
 
OS
 
Operating System
 
OT
 
Operational Technology
 
PKI
 
Public Key Infrastructure
 
PS
 
Personnel Security
 
RA
 
Risk Assessment
 
SC
 
System and Communications Protection
 
SCADA
 
Supervisory Control and Data Acquisition
 
SCRM
 
Supply Chain Risk Management
 
SI
 
System and Information Integrity
 
SIEM
 
Security Information and Event Management
 
SOAR
 
Security Orchestration, Automation, and Response
 
SOC
 
Security Operations Center
 
SP
 
Special Publication
 
SSP
 
System Security Plan
 
TEE
 
Trusted Execution Environment
 
TLS
 
Transport Layer Security
 
TPM
 
Trusted Platform Module
 
TTP
 
Tactics, Techniques, and Procedures
 
UEFI
 
Unified Extensible Firmware Interface
 
USB
 
Universal Serial Bus
 
VLAN
 
Virtual Local Area Network


VPN
=== Purpose and Audience ===
This guide is intended for assessors, OSCs, cybersecurity professionals, and individuals and companies that support CMMC efforts. This document can be used as part of preparation for and conducting a Level 3 certification assessment.


Virtual Private Network
=== Document Organization ===
This document is organized into the following sections:
* '''Assessment and Certification:''' provides an overview of the Level 3 assessment processes set forth in 32 CFR § 170.18. It provides guidance regarding the scope requirements set forth in 32 CFR § 170.19(d).
* '''CMMC-Custom Terms:''' incorporates definitions from 32 CFR § 170.4, definitions included by reference from 32 CFR § 170.2, and provides clarification of the intent and scope of specific terms as used in the context of CMMC.
* '''Assessment Criteria and Methodology:''' provides guidance on the criteria and methodology (i.e., ''interview'', ''examine'', and ''test'') to be employed during a Level 3 assessment, as well as on assessment findings.
* '''Requirement Descriptions:''' Provides guidance specific to each Level 3 security requirement.


XDR
== Assessment and Certification ==
The DCMA DIBCAC will use the assessment methods defined in NIST SP 800-172A<ref>NIST SP800-172A, March 2022</ref>, ''Assessing Enhanced Security Requirements for Controlled Unclassified Information'', along with the supplemental information in this guide to conduct Level 3 certification assessments. Assessors will review information and evidence to verify that an OSC meets the stated assessment objectives for all of the requirements.


Extended Detection and Response
An OSC can obtain a Level 3 certification assessment for an entire enterprise network or for specific enclave(s), depending on how the CMMC Assessment Scope is defined in accordance with 32 CFR § 170.19(d).


=== Assessment Scope ===
Prior to conducting a CMMC Level 3 certification assessment, the Level 3 CMMC Assessment Scope must be defined as addressed in 32 CFR § 170.19(d) and the ''CMMC Scoping Guide – Level 3'' document<ref>Note that an OSC ought to be mindful of their full Level 3 scoping in their request for a Level 2 assessment.</ref>. The CMMC Assessment Scope informs which assets within the OSC’s environment will be assessed and the details of the assessment. The OSC must have achieved a CMMC Status of Final Level 2 (C3PAO) of all systems included within the Level 3 CMMC Assessment Scope prior to requesting the Level 3 assessment, as set forth in 32 CFR § 170.18.


The Level 3 assessment scoping is based on the requirements defined in 32 CFR § 170.19(d) and supported by the ''CMMC Scoping Guide – Level 3 ''document. The ''CMMC Scoping Guide – Level 3'' document is available on the official CMMC documentation site at https://dodcio.defense.gov/CMMC/Documentation/. If a Final Level 2 (C3PAO) CMMC Status has not already been achieved for the desired CMMC Assessment Scope, the OSC may not proceed with the Level 3 assessment.


== CMMC-Custom Terms ==
The CMMC Program has custom terms that align with program requirements. Although some terms may have other definitions in open forums, it is important to understand these terms as they apply to the CMMC Program.


The custom terms associated with Level 3 are:
* '''Assessment:''' As defined 32 CFR § 170.4 means the testing or evaluation of security controls to determine the extent to which the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for an information system or organization defined in 32 CFR § 170.15 to 32 CFR § 170.18.
** Level 3 certification assessment is the term for the activity performed by the DCMA DIBCAC to evaluate the information system of an OSC when seeking a CMMC Status of Level 3 (DIBCAC).
** POA&M closeout certification assessment is the term for the activity performed by a C3PAO or DCMA DIBCAC to evaluate only the NOT MET requirements that were identified with POA&amp;M during the initial assessment, when seeking a CMMC Status of Final Level 2 (C3PAO) or Final Level 3 (DIBCAC) respectively.
* '''Assessment Objective:''' Means a set of determination statements that, taken together, expresses the desired outcome for the assessment of a security requirement. Successful implementation of the corresponding CMMC security requirement requires meeting all applicable assessment objectives defined in NIST SP 800–171A or NIST SP 800-172A.
* '''Asset:''' Means an item of value to stakeholders. An asset may be tangible (e.g., a physical item such as hardware, firmware, computing platform, network device, or other technology component) or intangible (e.g., humans, data, information, software, capability, function, service, trademark, copyright, patent, intellectual property, image, or reputation). The value of an asset is determined by stakeholders in consideration of loss concerns across the entire system life cycle. Such concerns include but are not limited to business or mission concerns. Understanding ''assets'' is critical to identifying the ''CMMC Assessment Scope''; for more information see ''CMMC Scoping Guide – Level 3''.
* '''CMMC Assessment Scope:''' As defined in 32 CFR § 170.4 means the set of all ''assets'' in the OSC’s environment that will be assessed against CMMC security requirements.
* '''CMMC Status:''' The result of meeting or exceeding the minimum required score for the corresponding assessment. The CMMC Status of an OSA information system is officially stored in SPRS and additionally presented on a Certificate of CMMC Status, if the assessment was conducted by a C3PAO or DCMA DIBCAC.
** '''Conditional Level 3 (DIBCAC):''' Defined in 32 CFR § 170.18(a)(1)(ii). The OSC will achieve CMMC Status of Conditional Level 3 (DIBCAC) if a POA&amp;M exists upon completion of the assessment and the POA&amp;M meets all Level 3 POA&amp;M requirements listed in 32 CFR § 170.21(a)(3).
** '''Final Level 3 (DIBCAC):''' Defined in 32 CFR § 170.18(a)(1)(iii). The OSC will achieve Final Level 3 (DIBCAC) CMMC Status for the information systems within the CMMC Assessment Scope upon implementation of all security requirements and, if applicable a POA&amp;M closeout assessment within 180 days. Additional guidance can be found in 32 CFR §170.21.
* '''Enduring Exception:''' As defined 32 CFR § 170.4 means a special circumstance or system where remediation and full compliance with CMMC security requirements is not feasible. Examples include systems required to replicate the configuration of ‘fielded’ systems, medical devices, test equipment, OT, and IoT. No operational plan of action is required but the circumstance must be documented within a system security plan. Specialized Assets and Government Furnished Equipment (GFE) may be Enduring Exceptions.
* '''Event:''' Any observable occurrence in a system<ref>NIST SP 800-53 Rev. 5, p. 402</ref>. As described in NIST SP 800-171A<ref>NIST SP 800-171A, June 2018, p. v</ref>, the terms “information system” and “system” can be used interchangeably. ''Events'' sometimes provide indication that an ''incident'' is occurring.
* '''Incident:''' An occurrence that actually or potentially jeopardizes the confidentiality, integrity, or availability of a system or the information the system processes, stores, or transmits or that constitutes a violation or imminent threat of violation of security policies, security procedures, or acceptable use policies.<ref>NIST SP 800-171 Rev. 2, Appendix B, p. 54 (adapted)</ref>
* '''Monitoring:''' The act of continually checking, supervising, critically observing, or determining the status in order to identify change from the performance level required or expected at an ''organization-defined'' frequency and rate.<ref>NIST SP 800-160 Vol. 1 R1, Engineering Trustworthy Secure Systems, 2022, Appendix B., p. 55</ref>
* '''Operational plan of action:''' As used in security requirement CA.L2-3.12.2, means the formal artifact which identifies temporary vulnerabilities and temporary deficiencies in implementation of requirements and documents how and when they will be mitigated, corrected, or eliminated. The OSA defines the format (e.g., document, spreadsheet, database) and specific content of its operational plan of action. An operational plan of action is not the same as a POA&amp;M associated with an assessment.
* '''Organization-defined:''' As determined by the OSC being assessed except as defined in the case of Organization-Defined Parameter (ODP). This can be applied to a frequency or rate at which something occurs within a given time period, or it could be associated with describing the configuration of a OSC’s solution.
* '''Organization-Defined Parameters (ODPs):''' Selected enhanced security requirements contain selection and assignment operations to give organizations<ref>The organization defining the parameters is the DoD.</ref> flexibility in defining variable parts of those requirements, as defined in NIST SP 800-172A. ODPs are used in NIST SP 800-172 and NIST SP 800-172A to allow Federal agencies, in this case the DoD, to customize security requirements. Once specified, the values for the assignment and selection operations become part of the requirement and objectives, where applicable.
: The assignments and selections chosen for Level 3 are underlined in the requirement statement and objectives. In some cases, further specificity of the assignment or selection will need to be made by the OSC. In those cases, the term and abbreviation ODPs is used in the assessment objectives to denote where additional definition is required.
* '''Periodically:''' Means occurring at a regular interval as determined by the OSA that may not exceed one year. As used in many requirements within CMMC, the interval length is ''organization-defined'' to provide OSC flexibility, with an interval length of no more than one year.
* '''Security Protection Data:''' As defined 32 CFR § 170.4 means data stored or processed by Security Protection Assets (SPA) that are used to protect an OSC's assessed environment. Security Protection Data is security relevant information and includes, but is not limited to: configuration data required to operate an SPA, log files generated by or ingested by an SPA, data related to the configuration or vulnerability status of in-scope assets, and passwords that grant access to the in-scope environment.
* '''System Security Plan (SSP):''' Means the formal document that provides an overview of the security requirements for an information system or an information security program and describes the security controls in place or planned for meeting those requirements. The system security plan describes the system components that are included within the system, the environment in which the system operates, how the security requirements are implemented, and the relationships with or connections to other systems.
* '''Temporary deficiency:''' As defined 32 CFR § 170.4 means a condition where remediation of a discovered deficiency is feasible and a known fix is available or is in process. The deficiency must be documented in an operational plan of action. A temporary deficiency is not based on an ‘in progress’ initial implementation of a CMMC security requirement but arises after implementation. A temporary deficiency may apply during the initial implementation of a security requirement if, during roll-out, specific issues with a very limited subset of equipment is discovered that must be separately addressed. There is no standard duration for which a temporary deficiency may be active. For example, FIPS-validated cryptography that requires a patch and the patched version is no longer the validated version may be a temporary deficiency.


== Assessment Criteria and Methodology ==
The ''CMMC Assessment Guide – Level 3'' leverages the assessment procedure described in NIST SP 800-172A Section 2.1:


: ''An assessment procedure consists of an assessment objective and a set of potential assessment methods and objects that can be used to conduct the assessment. Each assessment objective includes a set of determination statements related to the CUI enhanced security requirement that is the subject of the assessment. Organization-defined parameters (ODP) that are part of selected enhanced security requirements are included in the initial determination statements for the assessment procedure. ODPs are included since the specified parameter values are used in subsequent determination statements. ODPs are numbered sequentially and noted in bold italics.
: Determination statements reflect the content of the enhanced security requirements to ensure traceability of the assessment results to the requirements. The application of an assessment procedure to an enhanced security requirement produces assessment findings. The findings are used to determine if the enhanced security requirement has been satisfied.
: Assessment objects are associated with the specific items being assessed. These objects can include specifications, mechanisms, activities, and individuals.''
: * ''Specifications are the document-based artifacts (e.g., policies, procedures, security plans, security requirements, functional specifications, architectural designs) associated with a system.''
: * ''Mechanisms are the specific hardware, software, or firmware safeguards employed within a system.''
: * ''Activities are the protection-related actions supporting a system that involve people (e.g., conducting system backup operations, exercising a contingency plan, and monitoring network traffic).''
: * ''Individuals, or groups of individuals, are people applying the specifications, mechanisms, or activities described above.''
: ''Assessment methods define the nature and the extent of the assessor’s actions. The methods include examine, interview, and test.''
: * ''The examine method is the process of reviewing, inspecting, observing, studying, or analyzing assessment objects (i.e., specifications, mechanisms, activities).''
: * ''The interview method is the process of holding discussions with individuals or groups of individuals to facilitate understanding, achieve clarification, or obtain evidence.''
: * ''The test method is the process of exercising assessment objects (i.e., activities, mechanisms) under specified conditions to compare actual with expected behavior.''
: ''The purpose of the assessment methods is to facilitate understanding, achieve clarification, and obtain evidence. The results obtained from applying the methods are used for making the specific determinations called for in the determination statements and thereby achieving the objectives for the assessment procedure.''


=== Criteria ===
Assessment objectives are provided for each requirement and are based on existing criteria from NIST SP 800-172A. The criteria are authoritative and provide a basis for the assessor to conduct an assessment of a requirement.


=== Methodology ===
During the CMMC certification assessment, the assessor will verify and validate that the OSC has met the requirements. Because an OSC can meet the assessment objectives in different ways (e.g., through documentation, computer configuration, network configuration, or training), the assessor may use a variety of techniques, including one or more of the three assessment methods described above from NIST SP 800-172A, to determine if the OSC meets the intent of the requirements.


The assessor will follow the guidance in NIST SP 800-172A when determining which assessment methods to use:


: ''Organizations [DoD] are not expected to use all of the assessment methods and objects contained within the assessment procedures identified in this publication. Rather, organizations have the flexibility to establish the level of effort needed and the assurance required for an assessment (e.g., which assessment methods and objects are deemed to be the most useful in obtaining the desired results). The decision on level of effort is made based on how the organization can accomplish the assessment objectives in the most cost-effective and efficient manner and with sufficient confidence to support the determination that the CUI enhanced security requirements have been satisfied.''


The primary deliverable of an assessment is a compliance score and accompanying report that contains the findings associated with each requirement. For more detailed information on assessment methods, see Appendix C of NIST SP 800-172A.


Figure 1 illustrates an example of an assessment procedure for requirement AC.L3-3.1.3e.




Appendix A – Acronyms and Abbreviations
=== Who Is Interviewed ===
The assessor has discussions with OSC staff to understand if a requirement has been addressed. Interviews with applicable staff (possibly at different organizational levels) determine if CMMC security requirements are implemented and if adequate resourcing, training, and planning have occurred for individuals to perform the requirements.


'''CMMC Assessment Guide – Level 3 '''|''' Version 2.13 '''
=== What Is Examined ===
Examination includes reviewing, inspecting, observing, studying, or analyzing assessment objects. The objects can be documents, mechanisms, or activities. The primary focus will be to examine through demonstrations during interviews.


85
For some requirements, the assessor reviews documentation to determine if assessment objectives are met. Interviews with OSC staff may identify the documents uses. Documents need to be in their final forms; working papers (e.g., drafts) of documentation are not eligible to be submitted as evidence because they are not yet official and are still subject to change.


''' '''
Common types of documents that can be used as evidence include:
* policy, process, and procedure documents;
* training materials;
* plans and planning documents; and
* system-level, network, and data flow diagrams.


''This page intentionally left blank. ''
This list of documents is not exhaustive or prescriptive. An OSC may not have these specific documents, and other documents may be used to provide evidence of compliance.


In other cases, the requirement is best assessed by observing that safeguards are in place by viewing hardware or associated configuration information or observe staff exercising a process.


=== What Is Tested ===
Testing is an important part of the assessment process. Interviews tell the assessor what the OSC staff believe to be true, documentation provides evidence of intent, and testing demonstrates what has or has not been done and is the preferred assessment method when possible. For example, staff may talk about how users are identified and documentation may provide details on how users are identified, but seeing a demonstration of user identification provides evidence that the requirement is met. The assessor will determine which requirements or objectives within a requirement need demonstration or testing. Most objectives will require testing.


=== Assessment Findings ===
The assessment of a CMMC security requirement results in one of three possible findings: MET, NOT MET, or NOT APPLICABLE as defined in 32 CFR § 170.24. To achieve CMMC Status of Final Level 3 (DIBCAC) as described in 32 CFR § 170.18, the OSC will need a finding of MET or NOT APPLICABLE on all Level 3 security requirements.


* '''MET:''' All applicable assessment objectives for the security requirement are satisfied based on evidence. All evidence must be in final form and a not draft. Unacceptable forms of evidence include working papers, drafts, and unofficial or unapproved policies. For each security requirement marked MET, it is best practice to record statements that indicate the response conforms to all objectives and document the appropriate evidence to support the response.
** Enduring Exceptions when described, along with any mitigations, in the system security plan shall be assessed as MET.
** Temporary deficiencies that are appropriately addressed in operational plans of action (i.e., include deficiency reviews, milestones, and show progress towards the implementation of corrections to reduce or eliminate identified vulnerabilities) shall be assessed as MET.
* '''NOT MET:''' One or more objectives for the security requirement is not satisfied. During a Level 3 certification assessment, for each requirement objective marked NOT MET, the assessor will document why the evidence provided by the OSC does not conform.
* '''NOT APPLICABLE (N/A):''' A security requirement and/or objective does not apply at the time of the assessment. For example, SI.L3-3.14.3e might be N/A if there are no Internet of Things (IoT), Industrial Internet of Things (IIoT), Operational Technology (OT), Government Furnished Equipment (GFE), Restricted Information Systems, or test equipment included in the Level 3 CMMC Assessment Scope.


If an OSC previously received a favorable adjudication from the DoD CIO indicating that a requirement is not applicable or that an alternative security measure is equally effective, the DoD CIO adjudication must be included in the system security plan to receive consideration during an assessment. Implemented security measures adjudicated by the DoD CIO as equally effective are assessed as MET if there have been no changes in the environment.


Each assessment objective in NIST SP 800-171A and NIST SP 800-172A must yield a finding of MET or NOT APPLICABLE in order for the overall security requirement to be scored as MET. Assessors exercise judgment in determining when sufficient and adequate evidence has been presented to make an assessment finding.


CMMC certification assessments are conducted and results are captured at the assessment objective level. One NOT MET assessment objective results in a failure of the entire security requirement.


A security requirement can be applicable even when assessment objectives included in the security requirements are scored as N/A. The security requirement is NOT MET when one or more applicable assessment objectives is NOT MET.


Satisfaction of security requirements may be accomplished by other parts of the enterprise or an External Service Provider (ESP), as defined in 32 CFR § 170.4. A security requirement is considered MET if adequate evidence is provided that the enterprise or ESP, implements the requirement objectives. An ESP may be external people, technology, or facilities that the OSC uses, including cloud service providers, managed service providers, managed security service providers, or cybersecurity-as-a-service providers.


== Requirement Descriptions ==
This section provides detailed information and guidance for assessing each Level 3 security requirement. The section is organized first by domain and then by individual security requirement. Each security requirement description contains the following elements as described in 32 CFR § 170.14(c):
* '''Requirement Number, Name, and Statement:''' Headed by the requirement identification number in the format DD.L#-REQ (e.g., AC.L3-3.1.2e); followed by the requirement short name identifier, meant to be used for quick reference only; and finally followed by the complete CMMC security requirement statement. In the case where the original NIST SP 800-172 requirement requires an assignment and/or selection statement, the Level 3 assignment (and any necessary selection) text is emphasized using underlining. See Section 2.2 in NIST SP 800-172 for the discussion on assignments and selections.
* '''Assessment Objectives [NIST SP 800-172A]:''' Identifies the specific list of objectives that must be met to receive MET for the requirement as defined in NIST SP 800-172A and includes the Level 3 assignment/selection text (as appropriate). In cases where a Level 3 assignment fully satisfies the definition(s) required in an organization-defined parameter (ODP) in NIST SP 800-172A, the ODP statement is not included as an objective, since that objective has been met by the assignment itself. However, when the assignment does not fully contain all required aspects of a NIST SP 800-172A ODP, the ODP is included as its own objective, using the original NIST SP 800-172A ODP number (e.g., “[ODP4]”). See the breakout box ''ORGANIZATION-DEFINED PARAMETERS'' in Section 2.1 of NIST SP 800-172A for additional details on an ODP. In all cases where an assignment is used within an objective, it also emphasized using underlining.
* '''Potential Assessment Methods and Objects [NIST SP 800-172A]:''' Defines the nature and extent of the assessor’s actions. Potential assessment methods and objects are as defined in NIST SP 800-172A. The methods include ''examine'', ''interview'', and ''test''. Assessment objects identify the items being assessed and can include specifications, mechanisms, activities, and individuals.
* '''Discussion [NIST SP 800-172]:''' Contains discussion from the associated NIST SP 800-172 security requirement.
* '''Further Discussion:'''
** Expands upon the NIST content to provide supplemental information on the requirement intent.
** Contains examples illustrating how the OSC might apply the requirement. These examples provide insight but are not intended to be prescriptive of how the requirement must be implemented, nor comprehensive of all assessment objectives necessary to achieve the requirement. The assessment objectives met within the example are referenced by letter in brackets (e.g., [a,d] for objectives “a” and “d”) within the text. Note that some of the examples contain company names; all company names used in this document are fictitious.
** Provides potential assessment considerations. These may include common considerations for assessing the requirement and potential questions the assessor may ask when assessing the objectives.
* '''Key References:''' Lists the security requirement from NIST SP 800-172.


== Access Control (AC) ==
=== AC.L3-3.1.2e – Organizationally Controlled Assets ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Restrict access to systems and system components to only those information resources that are owned, provisioned, or issued by the organization.
|-
|'''ASSESSMENT OBJECTIVES'''
: [a] Information resources that are owned, provisioned, or issued by the organization are identified; and
: [b] Access to systems and system components is restricted to only those information resources that are owned, provisioned, or issued by the organization.
|-
|[[Practice_AC.L3-3.1.2e_Details|More Practice Details...]]
|}
=== AC.L3-3.1.3e – Secured Information Transfer ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Employ secure information transfer solutions to control information flows between security domains on connected systems.
|-
|'''ASSESSMENT OBJECTIVES'''
: [ODP1] Secure information transfer solutions are defined;
: [a] Information flows between security domains on connected systems are identified; and
: [b] Secure information transfer solutions are employed to control information flows between security domains on connected systems.
|-
|[[Practice_AC.L3-3.1.3e_Details|More Practice Details...]]
|}


   
== Awareness and Training (AT) ==
=== AT.L3-3.2.1e – Advanced Threat Awareness ===
  {|class="wikitable"
|'''SECURITY REQUIREMENT'''
Provide awareness training upon initial hire, following a significant cyber event, and at least annually, focused on recognizing and responding to threats from social engineering, advanced persistent threat actors, breaches, and suspicious behaviors; update the training at least annually or when there are significant changes to the threat.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] Threats from social engineering, advanced persistent threat actors, breaches, and suspicious behaviors are identified;
: [b] Awareness training focused on recognizing and responding to threats from social engineering, advanced persistent threat actors, breaches, and suspicious behaviors is provided upon initial hire, following a significant cyber event, and at least annually;
: [c] Significant changes to the threats from social engineering, advanced persistent threat actors, breaches, and suspicious behaviors are identified; and
: [d] Awareness training is updated at least annually or when there are significant changes to the threat.
|-
|[[Practice_AT.L3-3.2.1e_Details|More Practice Details...]]
|}
=== AT.L3-3.2.2e – Practical Training Exercises ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Include practical exercises in awareness training for all users, tailored by roles, to include general users, users with specialized roles, and privileged users, that are aligned with current threat scenarios and provide feedback to individuals involved in the training and their supervisors.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] Practical exercises are identified;
: [b] Current threat scenarios are identified;
: [c] Individuals involved in training and their supervisors are identified;
: [d] Practical exercises that are aligned with current threat scenarios are included in awareness training for all users, tailored by roles, to include general users, users with specialized roles, and privileged users; and
: [e] Feedback is provided to individuals involved in the training and their supervisors.
|-
|[[Practice_AT.L3-3.2.2e_Details|More Practice Details...]]
|}


== Configuration Management (CM) ==
=== CM.L3-3.4.1e – Authoritative Repository ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Establish and maintain an authoritative source and repository to provide a trusted source and accountability for approved and implemented system components.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] Approved system components are identified;
: [b] Implemented system components are identified;
: [c] An authoritative source and repository are established to provide a trusted source and accountability for approved and implemented system components; and
: [d] An authoritative source and repository are maintained to provide a trusted source and accountability for approved and implemented system components.
|-
|[[Practice_CM.L3-3.4.1e_Details|More Practice Details...]]
|}
=== CM.L3-3.4.2e – Automated Detection & Remediation ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Employ automated mechanisms to detect misconfigured or unauthorized system components; after detection, remove the components or place the components in a quarantine or remediation network to facilitate patching, re-configuration, or other mitigations.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] Automated mechanisms to detect misconfigured or unauthorized system components are identified;
: [b] Automated mechanisms are employed to detect misconfigured or unauthorized system components;
: [c] Misconfigured or unauthorized system components are detected; and
: [d] After detection, system components are removed or placed in a quarantine or remediation network to facilitate patching, re-configuration, or other mitigations.
|-
|[[Practice_CM.L3-3.4.2e_Details|More Practice Details...]]
|}
=== CM.L3-3.4.3e – Automated Inventory ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Employ automated discovery and management tools to maintain an up-to-date, complete, accurate, and readily available inventory of system components.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] Automated discovery and management tools for the inventory of system components are identified;
: [b] An up-to-date, complete, accurate, and readily available inventory of system components exists; and
: [c] Automated discovery and management tools are employed to maintain an up-to-date, complete, accurate, and readily available inventory of system components.
|-
|[[Practice_CM.L3-3.4.3e_Details|More Practice Details...]]
|}


== Identification and Authentication (IA) ==
=== IA.L3-3.5.1e – Bidirectional Authentication ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Identify and authenticate <u>systems and system components, where possible</u>, before establishing a network connection using bidirectional authentication that is cryptographically based and replay resistant.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [ODP1] Systems and system components to identify and authenticate are defined;
: [a] Bidirectional authentication that is cryptographically-based is implemented;
: [b] Bidirectional authentication that is replay-resistant is implemented; and
: [c] <u>Systems and system components, where possible</u>, are identified and authenticated before establishing a network connection using bidirectional authentication that is cryptographically-based and replay-resistant.
|-
|[[Practice_IA.L3-3.5.1e_Details|More Practice Details...]]
|}
=== IA.L3-3.5.3e – Block Untrusted Assets ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Employ automated or manual/procedural mechanisms to prohibit system components from connecting to organizational systems unless the components are known, authenticated, in a properly configured state, or in a trust profile.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] System components that are known, authenticated, in a properly configured state, or in a trust profile are identified;
: [b] Automated or manual/procedural mechanisms to prohibit system components from connecting to organizational systems are identified; and
: [c] Automated or manual/procedural mechanisms are employed to prohibit system components from connecting to organizational systems unless the components are known, authenticated, in a properly configured state, or in a trust profile.
|-
|[[Practice_IA.L3-3.5.3e_Details|More Practice Details...]]
|}


== Incident Response (IR) ==
=== IR.L3-3.6.1e – Security Operations Center ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Establish and maintain a security operations center capability that operates <u>24/7, with allowance for remote/on-call staff<u>.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] A security operations center capability is established;
: [b] The security operations center capability operates <u>24/7, with allowance for remote/on-call staff</u>; and
: [c] The security operations center capability is maintained.
|-
|[[Practice_IR.L3-3.6.1e_Details|More Practice Details...]]
|}
=== IR.L3-3.6.2e – Cyber Incident Response Team ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Establish and maintain a cyber incident response team that can be deployed by the organization within <u>24 hours</u>.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] A cyber incident response team is established;
: [b] The cyber incident response team can be deployed by the organization <u>within 24 hours</u>; and
: [c] The cyber incident response team is maintained.
|-
|[[Practice_IR.L3-3.6.2e_Details|More Practice Details...]]
|}


== Personnel Security (PS) ==
=== PS.L3-3.9.2e – Adverse Information ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Ensure that organizational systems are protected if adverse information develops or is obtained about individuals with access to CUI.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] Individuals with access to CUI are identified;
: [b] Adverse information about individuals with access to CUI is defined;
: [c] Organizational systems to which individuals have access are identified; and
: [d] Mechanisms are in place to protect organizational systems if adverse information develops or is obtained about individuals with access to CUI.
|-
|[[Practice_PS.L3-3.9.2e_Details|More Practice Details...]]
|}


== Risk Assessment (RA) ==
=== RA.L3-3.11.1e – Threat-Informed Risk Assessment ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Employ <u>threat intelligence, at a minimum from open or commercial sources, and any DoD-provided sources</u>, as part of a risk assessment to guide and inform the development of organizational systems, security architectures, selection of security solutions, monitoring, threat hunting, and response and recovery activities.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [ODP1] Sources of threat intelligence are defined;
: [a] A risk assessment methodology is identified;
: [b] <u>Threat intelligence, at a minimum from open or commercial sources, and any DoD-provided sources</u>, are employed as part of a risk assessment to guide and inform the development of organizational systems and security architectures;
: [c] <u>Threat intelligence, at a minimum from open or commercial sources, and any DoD-provided sources</u>, are employed as part of a risk assessment to guide and inform the selection of security solutions;
: [d] <u>Threat intelligence, at a minimum from open or commercial sources, and any DoD-provided sources</u>, are employed as part of a risk assessment to guide and inform system monitoring activities;
: [e] <u>Threat intelligence, at a minimum from open or commercial sources</u>, and any DoD-provided sources, are employed as part of a risk assessment to guide and inform threat hunting activities; and
: [f] <u>Threat intelligence, at a minimum from open or commercial sources, and any DoD-provided sources</u>, are employed as part of a risk assessment to guide and inform response and recovery activities.
|-
|[[Practice_RA.L3-3.11.1e_Details|More Practice Details...]]
|}
=== RA.L3-3.11.2e – Threat Hunting ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Conduct cyber threat hunting activities <u>on an on-going aperiodic basis or when indications warrant</u>, to search for indicators of compromise in <u>organizational systems</u> and detect, track, and disrupt threats that evade existing controls.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [ODP4] Organizational systems to search for indicators of compromise are defined;
: [a] Indicators of compromise are identified;
: [b] Cyber threat hunting activities are conducted <u>on an on-going aperiodic basis or when indications warrant</u>, to search for indicators of compromise in <u>organizational systems</u>; and
: [c] Cyber threat hunting activities are conducted on an on-going aperiodic basis or when indications warrant, to detect, track, and disrupt threats that evade existing controls.
|-
|[[Practice_RA.L3-3.11.2e_Details|More Practice Details...]]
|}
=== RA.L3-3.11.3e – Advanced Risk Identification ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Employ advanced automation and analytics capabilities in support of analysts to predict and identify risks to organizations, systems, and system components.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] Advanced automation and analytics capabilities to predict and identify risks to organizations, systems, and system components are identified;
: [b] Analysts to predict and identify risks to organizations, systems, and system components are identified; and
: [c] Advanced automation and analytics capabilities are employed in support of analysts to predict and identify risks to organizations, systems, and system components.
|-
|[[Practice_RA.L3-3.11.3e_Details|More Practice Details...]]
|}
=== RA.L3-3.11.4e – Security Solution Rationale ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Document or reference in the system security plan the security solution selected, the rationale for the security solution, and the risk determination.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] The system security plan documents or references the security solution selected;
: [b] The system security plan documents or references the rationale for the security solution; and
: [c] The system security plan documents or references the risk determination.
|-
|[[Practice_RA.L3-3.11.4e_Details|More Practice Details...]]
|}
=== RA.L3-3.11.5e – Security Solution Effectiveness ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Assess the effectiveness of security solutions <u>at least annually or upon receipt of relevant cyber threat information, or in response to a relevant cyber incident</u>, to address anticipated risk to organizational systems and the organization based on current and accumulated threat intelligence.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] Security solutions are identified;
: [b] Current and accumulated threat intelligence is identified;
: [c] Anticipated risk to organizational systems and the organization based on current and accumulated threat intelligence is identified; and
: [d] The effectiveness of security solutions is assessed <u>at least annually or upon receipt of relevant cyber threat information, or in response to a relevant cyber incident</u>, to address anticipated risk to organizational systems and the organization based on current and accumulated threat intelligence.
|-
|[[Practice_RA.L3-3.11.5e_Details|More Practice Details...]]
|}


= Document Outline =
=== RA.L3-3.11.6e – Supply Chain Risk Response ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Assess, respond to, and monitor supply chain risks associated with organizational systems and system components.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] Supply chain risks associated with organizational systems and system components are identified;
: [b] Supply chain risks associated with organizational systems and system components are assessed;
: [c] Supply chain risks associated with organizational systems and system components are responded to; and
: [d] Supply chain risks associated with organizational systems and system components are monitored.
|-
|[[Practice_RA.L3-3.11.6e_Details|More Practice Details...]]
|}
=== RA.L3-3.11.7e – Supply Chain Risk Plan ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Develop a plan for managing supply chain risks associated with organizational systems and system components; update the plan <u>at least annually, and upon receipt of relevant cyber threat information, or in response to a relevant cyber incident</u>.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] Supply chain risks associated with organizational systems and system components are identified;
: [b] Organizational systems and system components to include in a supply chain risk management plan are identified;
: [c] A plan for managing supply chain risks associated with organizational systems and system components is developed; and
: [d] The plan for managing supply chain risks is updated <u>at least annually, and upon receipt of relevant cyber threat information, or in response to a relevant cyber incident</u>.
|-
|[[Practice_RA.L3-3.11.7e_Details|More Practice Details...]]
|}


* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#5|Introduction]]
== Security Assessment (CA) ==
** [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#5|Level 3 Description]]
=== CA.L3-3.12.1e – Penetration Testing ===
** [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#6|Purpose and Audience]]
{|class="wikitable"
** [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#6|Document Organization]]
|'''SECURITY REQUIREMENT'''
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#8|Assessment and Certification]]
Conduct penetration testing <u>at least annually or when significant security changes are made to the system</u>, leveraging automated scanning tools and ad hoc tests using subject matter experts.
** [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#8|Assessment Scope]]
|-
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#9|CMMC-Custom Terms]]
|'''ASSESSMENT OBJECTIVES'''
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#12|Assessment Criteria and Methodology]]
Determine if:
** [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#13|Criteria]]
: [a] Automated scanning tools are identified;
** [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#13|Methodology]]
: [b] Ad hoc tests using subject matter experts are identified; and
** [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#14|Who Is Interviewed]]
: [c] Penetration testing is conducted <u>at least annually or when significant security changes are made to the system</u>, leveraging automated scanning tools and ad hoc tests using subject matter experts.
** [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#14|What Is Examined]]
|-
** [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#15|What Is Tested]]
|[[Practice_CA.L3-3.12.1e_Details|More Practice Details...]]
** [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#15|Assessment Findings]]
|}
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#17|Requirement Descriptions]]
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#19|Access Control (AC)]]
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#24|Awareness and Training (AT)]]
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#29|Configuration Management (CM)]]
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#38|Identification and Authentication (IA)]]
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#44|Incident Response (IR)]]
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#50|Personnel Security (PS)]]
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#52|Risk Assessment (RA)]]
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#71|Security Assessment (CA)]]
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#74|System and Communications Protection (SC)]]
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#77|System and Information Integrity (SI)]]
* [[6198c0a322e23aa1e1020689fc487ef0dcad6945.html#87|Appendix A – Acronyms and Abbreviations]]


== System and Communications Protection (SC) ==
=== SC.L3-3.13.4e – isolation ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Employ <u>physical isolation techniques or logical isolation techniques or both</u> in organizational systems and system components.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [ODP1] One or more of the following is/are selected: physical isolation techniques; logical isolation techniques;
: [ODP2] Physical isolation techniques are defined (if selected);
: [ODP3] Logical isolation techniques are defined (if selected);
: [a] <u>Physical isolation techniques or logical isolation techniques or both</u> are employed in organizational systems and system components.
|-
|[[Practice_SC.L3-3.13.4e_Details|More Practice Details...]]
|}


-----
== System and Information Integrity (SI) ==
=== SI.L3-3.14.1e – Integrity Verification ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Verify the integrity of <u>security critical and essential software</u> using root of trust mechanisms or cryptographic signatures.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [ODP1] Security critical or essential software is defined;
: [a] Root of trust mechanisms or cryptographic signatures are identified; and
: [b] The integrity of <u>security critical and essential software</u> is verified using root of trust mechanisms or cryptographic signatures.
|-
|[[Practice_SI.L3-3.14.1e_Details|More Practice Details...]]
|}
=== SI.L3-3.14.3e – Specialized Asset Security ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Ensure that <u>specialized assets including IoT, IIoT, OT, GFE, Restricted Information Systems and test equipment</u> are included in the scope of the specified enhanced security requirements or are segregated in purpose-specific networks.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [a] <u>Specialized assets including IoT, IIoT, OT, GFE, Restricted Information Systems and test equipment</u> are included in the scope of the specified enhanced security requirements; and
: [b] Systems and system components that are not included in specialized assets including IoT, IIoT, OT, GFE, Restricted Information Systems and test equipment are segregated in purpose-specific networks.
|-
|[[Practice_SI.L3-3.14.3e_Details|More Practice Details...]]
|}
=== SI.L3-3.14.6e – Threat-Guided Intrusion Detection ===
{|class="wikitable"
|'''SECURITY REQUIREMENT'''
Use threat indicator information and effective mitigations obtained from, <u>at a minimum, open or commercial sources, and any DoD-provided sources</u>, to guide and inform intrusion detection and threat hunting.
|-
|'''ASSESSMENT OBJECTIVES'''
Determine if:
: [ODP1] External organizations from which to obtain threat indicator information and effective mitigations are defined;
: [a] Threat indicator information is identified;
: [b] Effective mitigations are identified;
: [c] Intrusion detection approaches are identified;
: [d] Threat hunting activities are identified; and
: [e] Threat indicator information and effective mitigations obtained from, <u>at a minimum, open or commercial sources and any DoD-provided sources</u>, are used to guide and inform intrusion detection and threat hunting.
|-
|[[Practice_SI.L3-3.14.6e_Details|More Practice Details...]]
|}


Original source: https://dodcio.defense.gov/Portals/0/Documents/CMMC/AssessmentGuideL3v2.pdf
== Appendix A – Acronyms and Abbreviations ==
{| class="wikitable"
|-
|| AC || Access Control
|-
|| ACL || Access Control List
|-
|| ACM || Automated Configuration Management
|-
|| ACMS || Automated Configuration Management System
|-
|| APT || Advanced Persistent Threat
|-
|| AT || Awareness and Training
|-
|| C3PAO || CMMC Third-Party Assessment Organization
|-
|| CA || Certification Authority
|-
|| CA || Security Assessment
|-
|| CERT || Computer Emergency Response Team
|-
|| CFR || Code of Federal Regulations
|-
|| CIO || Chief Information Officer
|-
|| CIRT || Computer Incident Response Team; Cyber Incident Response Team
|-
|| CISO || Chief Information Security Officer
|-
|| CM || Configuration Management
|-
|| CMMC || Cybersecurity Maturity Model Certification
|-
|| CUI || Controlled Unclassified Information
|-
|| DCSA || Defense Counterintelligence and Security Agency
|-
|| DFARS || Defense Federal Acquisition Regulation Supplement
|-
|| DIB || Defense Industrial Base
|-
|| DLP || Data Loss Prevention
|-
|| DMZ || Demilitarized Zone
|-
|| DoD || Department of Defense
|-
|| DRM || Digital Rights Management
|-
|| ESP || External Service Provider
|-
|| FIPS || Federal Information Processing Standard
|-
|| GFE || Government Furnished Equipment
|-
|| GPO || Group Policy Object
|-
|| HR || Human Resources
|-
|| IA || Identification and Authentication
|-
|| ICS || Industrial Control System
|-
|| IIoT || Industrial Internet of Things
|-
|| IOC || Indicators of Compromise
|-
|| IoT || Internet of Things
|-
|| IP || Internet Protocol
|-
|| IR || Incident Response
|-
|| ISAC || Information Sharing and Analysis Center
|-
|| ISAO || Information Sharing and Analysis Organization
|-
|| IT || Information Technology
|-
|| MLS || Multi-Level Secure
|-
|| N/A || Not Applicable
|-
|| NAC || Network Access Control
|-
|| NIST || National Institute of Standards and Technology
|-
|| ODP || Organization-Defined Parameters
|-
|| OS || Operating System
|-
|| OT || Operational Technology
|-
|| PKI || Public Key Infrastructure
|-
|| PS || Personnel Security
|-
|| RA || Risk Assessment
|-
|| SC || System and Communications Protection
|-
|| SCADA || Supervisory Control and Data Acquisition
|-
|| SCRM || Supply Chain Risk Management
|-
|| SI || System and Information Integrity
|-
|| SIEM || Security Information and Event Management
|-
|| SOAR || Security Orchestration, Automation, and Response
|-
|| SOC || Security Operations Center
|-
|| SP || Special Publication
|-
|| SSP || System Security Plan
|-
|| TEE || Trusted Execution Environment
|-
|| TLS || Transport Layer Security
|-
|| TPM || Trusted Platform Module
|-
|| TTP || Tactics, Techniques, and Procedures
|-
|| UEFI || Unified Extensible Firmware Interface
|-
|| USB || Universal Serial Bus
|-
|| VLAN || Virtual Local Area Network
|-
|| VPN || Virtual Private Network
|-
|| XDR || Extended Detection and Response
|}

Latest revision as of 03:17, 28 March 2025

Source of Reference: The official CMMC Level 3 Assessment Guide Version 2.13, September 2024 from the Department of Defense Chief Information Officer (DoD CIO).

For inquiries and reporting errors on this wiki, please contact us. Thank you.

NOTICES

The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing CMMC requirements under the law or departmental policies.

DISTRIBUTION STATEMENT A. Approved for public release. Distribution is unlimited.

Introduction

This document provides guidance in the preparation for and conduct of a Level 3 certification assessment under the Cybersecurity Maturity Model Certification (CMMC) Program as set forth in section 170.18 of title 32, Code of Federal Regulations (CFR). Certification at each CMMC level occurs independently. Guidance for conducting a Level 1 self-assessment can be found in CMMC Assessment Guide – Level 1. Guidance for conducting both a Level 2 self-assessment and Level 2 certification assessment, can be found in CMMC Assessment Guide – Level 2. More details on the model can be found in the CMMC Model Overview document.

An Assessment as defined in 32 CFR § 170.4 means the testing or evaluation of security controls to determine the extent to which the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for an information system, or organization as defined in 32 CFR § 170.15 to 32 CFR § 170.18. A Level 3 certification assessment as defined in 32 CFR § 170.4 is the activity performed by the Department of Defense (DoD) to evaluate the CMMC level of an Organization Seeking Certification (OSC). For Level 3, assessments are conducted exclusively by the DCMA DIBCAC.

An OSC seeking a Level 3 certification assessment must have first achieved a CMMC Status of Final Level 2 (C3PAO), as set forth in 32 CFR § 170.18(a), for all applicable information systems within the CMMC Assessment Scope, and the OSC must implement the Level 3 requirements specified in 32 CFR § 170.14(c)(4). This is followed by the Level 3 certification assessment conducted by the DCMA DIBCAC.

OSCs may also use this guide to perform Level 3 self-assessments (for example, in preparation for an annual affirmation); however, they are not eligible to submit results from a self-assessment in support of a Level 3 certification assessment. Only the results from an assessment by DCMA DIBCAC are considered for award of the CMMC Statuses Conditional Level 3 (DIBCAC) or Final Level 3 (DIBCAC). Level 3 reporting and affirmation requirements can be found in 32 CFR § 170.18 and 32 CFR § 170.22.

Level 3 Description

Level 3 consists of selected security requirements derived from National Institute of Standards and Technology (NIST) Special Publication (SP) 800-172, Enhanced Security Requirements for Protecting Controlled Unclassified Information: A Supplement to NIST Special Publication 800-171, with DoD-approved parameters where applicable. Level 3 only applies to systems that have already achieved a Final Level 2 (C3PAO) CMMC Status. Level 2 consists of the security requirements specified in NIST SP 800-171, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations.

Like Level 2, Level 3 addresses the protection of Controlled Unclassified Information (CUI), as defined in 32 CFR § 2002.4(h):

Information the Government creates or possesses, or that an entity creates or possesses for or on behalf of the Government, that a law, regulation, or Government-wide policy requires or permits an agency to handle using safeguarding or dissemination controls. However, CUI does not include classified information (see paragraph (e) of this section) or information a non-executive branch entity possesses and maintains in its own systems that did not come from, or was not created or possessed by or for, an executive branch agency or an entity acting for an agency. Law, regulation, or Government-wide policy may require or permit safeguarding or dissemination controls in three ways: Requiring or permitting agencies to control or protect the information but providing no specific controls, which makes the information CUI Basic; requiring or permitting agencies to control or protect the information and providing specific controls for doing so, which makes the information CUI Specified; or requiring or permitting agencies to control the information and specifying only some of those controls, which makes the information CUI Specified, but with CUI Basic controls where the authority does not specify.

Level 3 provides additional protections against advanced persistent threats (APTs), and increased assurance to the DoD that an OSC can adequately protect CUI at a level commensurate with the adversarial risk, to include protecting information flow with the government and with subcontractors in a multitier supply chain.

Purpose and Audience

This guide is intended for assessors, OSCs, cybersecurity professionals, and individuals and companies that support CMMC efforts. This document can be used as part of preparation for and conducting a Level 3 certification assessment.

Document Organization

This document is organized into the following sections:

  • Assessment and Certification: provides an overview of the Level 3 assessment processes set forth in 32 CFR § 170.18. It provides guidance regarding the scope requirements set forth in 32 CFR § 170.19(d).
  • CMMC-Custom Terms: incorporates definitions from 32 CFR § 170.4, definitions included by reference from 32 CFR § 170.2, and provides clarification of the intent and scope of specific terms as used in the context of CMMC.
  • Assessment Criteria and Methodology: provides guidance on the criteria and methodology (i.e., interview, examine, and test) to be employed during a Level 3 assessment, as well as on assessment findings.
  • Requirement Descriptions: Provides guidance specific to each Level 3 security requirement.

Assessment and Certification

The DCMA DIBCAC will use the assessment methods defined in NIST SP 800-172A[1], Assessing Enhanced Security Requirements for Controlled Unclassified Information, along with the supplemental information in this guide to conduct Level 3 certification assessments. Assessors will review information and evidence to verify that an OSC meets the stated assessment objectives for all of the requirements.

An OSC can obtain a Level 3 certification assessment for an entire enterprise network or for specific enclave(s), depending on how the CMMC Assessment Scope is defined in accordance with 32 CFR § 170.19(d).

Assessment Scope

Prior to conducting a CMMC Level 3 certification assessment, the Level 3 CMMC Assessment Scope must be defined as addressed in 32 CFR § 170.19(d) and the CMMC Scoping Guide – Level 3 document[2]. The CMMC Assessment Scope informs which assets within the OSC’s environment will be assessed and the details of the assessment. The OSC must have achieved a CMMC Status of Final Level 2 (C3PAO) of all systems included within the Level 3 CMMC Assessment Scope prior to requesting the Level 3 assessment, as set forth in 32 CFR § 170.18.

The Level 3 assessment scoping is based on the requirements defined in 32 CFR § 170.19(d) and supported by the CMMC Scoping Guide – Level 3 document. The CMMC Scoping Guide – Level 3 document is available on the official CMMC documentation site at https://dodcio.defense.gov/CMMC/Documentation/. If a Final Level 2 (C3PAO) CMMC Status has not already been achieved for the desired CMMC Assessment Scope, the OSC may not proceed with the Level 3 assessment.

CMMC-Custom Terms

The CMMC Program has custom terms that align with program requirements. Although some terms may have other definitions in open forums, it is important to understand these terms as they apply to the CMMC Program.

The custom terms associated with Level 3 are:

  • Assessment: As defined 32 CFR § 170.4 means the testing or evaluation of security controls to determine the extent to which the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for an information system or organization defined in 32 CFR § 170.15 to 32 CFR § 170.18.
    • Level 3 certification assessment is the term for the activity performed by the DCMA DIBCAC to evaluate the information system of an OSC when seeking a CMMC Status of Level 3 (DIBCAC).
    • POA&M closeout certification assessment is the term for the activity performed by a C3PAO or DCMA DIBCAC to evaluate only the NOT MET requirements that were identified with POA&M during the initial assessment, when seeking a CMMC Status of Final Level 2 (C3PAO) or Final Level 3 (DIBCAC) respectively.
  • Assessment Objective: Means a set of determination statements that, taken together, expresses the desired outcome for the assessment of a security requirement. Successful implementation of the corresponding CMMC security requirement requires meeting all applicable assessment objectives defined in NIST SP 800–171A or NIST SP 800-172A.
  • Asset: Means an item of value to stakeholders. An asset may be tangible (e.g., a physical item such as hardware, firmware, computing platform, network device, or other technology component) or intangible (e.g., humans, data, information, software, capability, function, service, trademark, copyright, patent, intellectual property, image, or reputation). The value of an asset is determined by stakeholders in consideration of loss concerns across the entire system life cycle. Such concerns include but are not limited to business or mission concerns. Understanding assets is critical to identifying the CMMC Assessment Scope; for more information see CMMC Scoping Guide – Level 3.
  • CMMC Assessment Scope: As defined in 32 CFR § 170.4 means the set of all assets in the OSC’s environment that will be assessed against CMMC security requirements.
  • CMMC Status: The result of meeting or exceeding the minimum required score for the corresponding assessment. The CMMC Status of an OSA information system is officially stored in SPRS and additionally presented on a Certificate of CMMC Status, if the assessment was conducted by a C3PAO or DCMA DIBCAC.
    • Conditional Level 3 (DIBCAC): Defined in 32 CFR § 170.18(a)(1)(ii). The OSC will achieve CMMC Status of Conditional Level 3 (DIBCAC) if a POA&M exists upon completion of the assessment and the POA&M meets all Level 3 POA&M requirements listed in 32 CFR § 170.21(a)(3).
    • Final Level 3 (DIBCAC): Defined in 32 CFR § 170.18(a)(1)(iii). The OSC will achieve Final Level 3 (DIBCAC) CMMC Status for the information systems within the CMMC Assessment Scope upon implementation of all security requirements and, if applicable a POA&M closeout assessment within 180 days. Additional guidance can be found in 32 CFR §170.21.
  • Enduring Exception: As defined 32 CFR § 170.4 means a special circumstance or system where remediation and full compliance with CMMC security requirements is not feasible. Examples include systems required to replicate the configuration of ‘fielded’ systems, medical devices, test equipment, OT, and IoT. No operational plan of action is required but the circumstance must be documented within a system security plan. Specialized Assets and Government Furnished Equipment (GFE) may be Enduring Exceptions.
  • Event: Any observable occurrence in a system[3]. As described in NIST SP 800-171A[4], the terms “information system” and “system” can be used interchangeably. Events sometimes provide indication that an incident is occurring.
  • Incident: An occurrence that actually or potentially jeopardizes the confidentiality, integrity, or availability of a system or the information the system processes, stores, or transmits or that constitutes a violation or imminent threat of violation of security policies, security procedures, or acceptable use policies.[5]
  • Monitoring: The act of continually checking, supervising, critically observing, or determining the status in order to identify change from the performance level required or expected at an organization-defined frequency and rate.[6]
  • Operational plan of action: As used in security requirement CA.L2-3.12.2, means the formal artifact which identifies temporary vulnerabilities and temporary deficiencies in implementation of requirements and documents how and when they will be mitigated, corrected, or eliminated. The OSA defines the format (e.g., document, spreadsheet, database) and specific content of its operational plan of action. An operational plan of action is not the same as a POA&M associated with an assessment.
  • Organization-defined: As determined by the OSC being assessed except as defined in the case of Organization-Defined Parameter (ODP). This can be applied to a frequency or rate at which something occurs within a given time period, or it could be associated with describing the configuration of a OSC’s solution.
  • Organization-Defined Parameters (ODPs): Selected enhanced security requirements contain selection and assignment operations to give organizations[7] flexibility in defining variable parts of those requirements, as defined in NIST SP 800-172A. ODPs are used in NIST SP 800-172 and NIST SP 800-172A to allow Federal agencies, in this case the DoD, to customize security requirements. Once specified, the values for the assignment and selection operations become part of the requirement and objectives, where applicable.
The assignments and selections chosen for Level 3 are underlined in the requirement statement and objectives. In some cases, further specificity of the assignment or selection will need to be made by the OSC. In those cases, the term and abbreviation ODPs is used in the assessment objectives to denote where additional definition is required.
  • Periodically: Means occurring at a regular interval as determined by the OSA that may not exceed one year. As used in many requirements within CMMC, the interval length is organization-defined to provide OSC flexibility, with an interval length of no more than one year.
  • Security Protection Data: As defined 32 CFR § 170.4 means data stored or processed by Security Protection Assets (SPA) that are used to protect an OSC's assessed environment. Security Protection Data is security relevant information and includes, but is not limited to: configuration data required to operate an SPA, log files generated by or ingested by an SPA, data related to the configuration or vulnerability status of in-scope assets, and passwords that grant access to the in-scope environment.
  • System Security Plan (SSP): Means the formal document that provides an overview of the security requirements for an information system or an information security program and describes the security controls in place or planned for meeting those requirements. The system security plan describes the system components that are included within the system, the environment in which the system operates, how the security requirements are implemented, and the relationships with or connections to other systems.
  • Temporary deficiency: As defined 32 CFR § 170.4 means a condition where remediation of a discovered deficiency is feasible and a known fix is available or is in process. The deficiency must be documented in an operational plan of action. A temporary deficiency is not based on an ‘in progress’ initial implementation of a CMMC security requirement but arises after implementation. A temporary deficiency may apply during the initial implementation of a security requirement if, during roll-out, specific issues with a very limited subset of equipment is discovered that must be separately addressed. There is no standard duration for which a temporary deficiency may be active. For example, FIPS-validated cryptography that requires a patch and the patched version is no longer the validated version may be a temporary deficiency.

Assessment Criteria and Methodology

The CMMC Assessment Guide – Level 3 leverages the assessment procedure described in NIST SP 800-172A Section 2.1:

An assessment procedure consists of an assessment objective and a set of potential assessment methods and objects that can be used to conduct the assessment. Each assessment objective includes a set of determination statements related to the CUI enhanced security requirement that is the subject of the assessment. Organization-defined parameters (ODP) that are part of selected enhanced security requirements are included in the initial determination statements for the assessment procedure. ODPs are included since the specified parameter values are used in subsequent determination statements. ODPs are numbered sequentially and noted in bold italics.
Determination statements reflect the content of the enhanced security requirements to ensure traceability of the assessment results to the requirements. The application of an assessment procedure to an enhanced security requirement produces assessment findings. The findings are used to determine if the enhanced security requirement has been satisfied.
Assessment objects are associated with the specific items being assessed. These objects can include specifications, mechanisms, activities, and individuals.
* Specifications are the document-based artifacts (e.g., policies, procedures, security plans, security requirements, functional specifications, architectural designs) associated with a system.
* Mechanisms are the specific hardware, software, or firmware safeguards employed within a system.
* Activities are the protection-related actions supporting a system that involve people (e.g., conducting system backup operations, exercising a contingency plan, and monitoring network traffic).
* Individuals, or groups of individuals, are people applying the specifications, mechanisms, or activities described above.
Assessment methods define the nature and the extent of the assessor’s actions. The methods include examine, interview, and test.
* The examine method is the process of reviewing, inspecting, observing, studying, or analyzing assessment objects (i.e., specifications, mechanisms, activities).
* The interview method is the process of holding discussions with individuals or groups of individuals to facilitate understanding, achieve clarification, or obtain evidence.
* The test method is the process of exercising assessment objects (i.e., activities, mechanisms) under specified conditions to compare actual with expected behavior.
The purpose of the assessment methods is to facilitate understanding, achieve clarification, and obtain evidence. The results obtained from applying the methods are used for making the specific determinations called for in the determination statements and thereby achieving the objectives for the assessment procedure.

Criteria

Assessment objectives are provided for each requirement and are based on existing criteria from NIST SP 800-172A. The criteria are authoritative and provide a basis for the assessor to conduct an assessment of a requirement.

Methodology

During the CMMC certification assessment, the assessor will verify and validate that the OSC has met the requirements. Because an OSC can meet the assessment objectives in different ways (e.g., through documentation, computer configuration, network configuration, or training), the assessor may use a variety of techniques, including one or more of the three assessment methods described above from NIST SP 800-172A, to determine if the OSC meets the intent of the requirements.

The assessor will follow the guidance in NIST SP 800-172A when determining which assessment methods to use:

Organizations [DoD] are not expected to use all of the assessment methods and objects contained within the assessment procedures identified in this publication. Rather, organizations have the flexibility to establish the level of effort needed and the assurance required for an assessment (e.g., which assessment methods and objects are deemed to be the most useful in obtaining the desired results). The decision on level of effort is made based on how the organization can accomplish the assessment objectives in the most cost-effective and efficient manner and with sufficient confidence to support the determination that the CUI enhanced security requirements have been satisfied.

The primary deliverable of an assessment is a compliance score and accompanying report that contains the findings associated with each requirement. For more detailed information on assessment methods, see Appendix C of NIST SP 800-172A.

Figure 1 illustrates an example of an assessment procedure for requirement AC.L3-3.1.3e.


Who Is Interviewed

The assessor has discussions with OSC staff to understand if a requirement has been addressed. Interviews with applicable staff (possibly at different organizational levels) determine if CMMC security requirements are implemented and if adequate resourcing, training, and planning have occurred for individuals to perform the requirements.

What Is Examined

Examination includes reviewing, inspecting, observing, studying, or analyzing assessment objects. The objects can be documents, mechanisms, or activities. The primary focus will be to examine through demonstrations during interviews.

For some requirements, the assessor reviews documentation to determine if assessment objectives are met. Interviews with OSC staff may identify the documents uses. Documents need to be in their final forms; working papers (e.g., drafts) of documentation are not eligible to be submitted as evidence because they are not yet official and are still subject to change.

Common types of documents that can be used as evidence include:

  • policy, process, and procedure documents;
  • training materials;
  • plans and planning documents; and
  • system-level, network, and data flow diagrams.

This list of documents is not exhaustive or prescriptive. An OSC may not have these specific documents, and other documents may be used to provide evidence of compliance.

In other cases, the requirement is best assessed by observing that safeguards are in place by viewing hardware or associated configuration information or observe staff exercising a process.

What Is Tested

Testing is an important part of the assessment process. Interviews tell the assessor what the OSC staff believe to be true, documentation provides evidence of intent, and testing demonstrates what has or has not been done and is the preferred assessment method when possible. For example, staff may talk about how users are identified and documentation may provide details on how users are identified, but seeing a demonstration of user identification provides evidence that the requirement is met. The assessor will determine which requirements or objectives within a requirement need demonstration or testing. Most objectives will require testing.

Assessment Findings

The assessment of a CMMC security requirement results in one of three possible findings: MET, NOT MET, or NOT APPLICABLE as defined in 32 CFR § 170.24. To achieve CMMC Status of Final Level 3 (DIBCAC) as described in 32 CFR § 170.18, the OSC will need a finding of MET or NOT APPLICABLE on all Level 3 security requirements.

  • MET: All applicable assessment objectives for the security requirement are satisfied based on evidence. All evidence must be in final form and a not draft. Unacceptable forms of evidence include working papers, drafts, and unofficial or unapproved policies. For each security requirement marked MET, it is best practice to record statements that indicate the response conforms to all objectives and document the appropriate evidence to support the response.
    • Enduring Exceptions when described, along with any mitigations, in the system security plan shall be assessed as MET.
    • Temporary deficiencies that are appropriately addressed in operational plans of action (i.e., include deficiency reviews, milestones, and show progress towards the implementation of corrections to reduce or eliminate identified vulnerabilities) shall be assessed as MET.
  • NOT MET: One or more objectives for the security requirement is not satisfied. During a Level 3 certification assessment, for each requirement objective marked NOT MET, the assessor will document why the evidence provided by the OSC does not conform.
  • NOT APPLICABLE (N/A): A security requirement and/or objective does not apply at the time of the assessment. For example, SI.L3-3.14.3e might be N/A if there are no Internet of Things (IoT), Industrial Internet of Things (IIoT), Operational Technology (OT), Government Furnished Equipment (GFE), Restricted Information Systems, or test equipment included in the Level 3 CMMC Assessment Scope.

If an OSC previously received a favorable adjudication from the DoD CIO indicating that a requirement is not applicable or that an alternative security measure is equally effective, the DoD CIO adjudication must be included in the system security plan to receive consideration during an assessment. Implemented security measures adjudicated by the DoD CIO as equally effective are assessed as MET if there have been no changes in the environment.

Each assessment objective in NIST SP 800-171A and NIST SP 800-172A must yield a finding of MET or NOT APPLICABLE in order for the overall security requirement to be scored as MET. Assessors exercise judgment in determining when sufficient and adequate evidence has been presented to make an assessment finding.

CMMC certification assessments are conducted and results are captured at the assessment objective level. One NOT MET assessment objective results in a failure of the entire security requirement.

A security requirement can be applicable even when assessment objectives included in the security requirements are scored as N/A. The security requirement is NOT MET when one or more applicable assessment objectives is NOT MET.

Satisfaction of security requirements may be accomplished by other parts of the enterprise or an External Service Provider (ESP), as defined in 32 CFR § 170.4. A security requirement is considered MET if adequate evidence is provided that the enterprise or ESP, implements the requirement objectives. An ESP may be external people, technology, or facilities that the OSC uses, including cloud service providers, managed service providers, managed security service providers, or cybersecurity-as-a-service providers.

Requirement Descriptions

This section provides detailed information and guidance for assessing each Level 3 security requirement. The section is organized first by domain and then by individual security requirement. Each security requirement description contains the following elements as described in 32 CFR § 170.14(c):

  • Requirement Number, Name, and Statement: Headed by the requirement identification number in the format DD.L#-REQ (e.g., AC.L3-3.1.2e); followed by the requirement short name identifier, meant to be used for quick reference only; and finally followed by the complete CMMC security requirement statement. In the case where the original NIST SP 800-172 requirement requires an assignment and/or selection statement, the Level 3 assignment (and any necessary selection) text is emphasized using underlining. See Section 2.2 in NIST SP 800-172 for the discussion on assignments and selections.
  • Assessment Objectives [NIST SP 800-172A]: Identifies the specific list of objectives that must be met to receive MET for the requirement as defined in NIST SP 800-172A and includes the Level 3 assignment/selection text (as appropriate). In cases where a Level 3 assignment fully satisfies the definition(s) required in an organization-defined parameter (ODP) in NIST SP 800-172A, the ODP statement is not included as an objective, since that objective has been met by the assignment itself. However, when the assignment does not fully contain all required aspects of a NIST SP 800-172A ODP, the ODP is included as its own objective, using the original NIST SP 800-172A ODP number (e.g., “[ODP4]”). See the breakout box ORGANIZATION-DEFINED PARAMETERS in Section 2.1 of NIST SP 800-172A for additional details on an ODP. In all cases where an assignment is used within an objective, it also emphasized using underlining.
  • Potential Assessment Methods and Objects [NIST SP 800-172A]: Defines the nature and extent of the assessor’s actions. Potential assessment methods and objects are as defined in NIST SP 800-172A. The methods include examine, interview, and test. Assessment objects identify the items being assessed and can include specifications, mechanisms, activities, and individuals.
  • Discussion [NIST SP 800-172]: Contains discussion from the associated NIST SP 800-172 security requirement.
  • Further Discussion:
    • Expands upon the NIST content to provide supplemental information on the requirement intent.
    • Contains examples illustrating how the OSC might apply the requirement. These examples provide insight but are not intended to be prescriptive of how the requirement must be implemented, nor comprehensive of all assessment objectives necessary to achieve the requirement. The assessment objectives met within the example are referenced by letter in brackets (e.g., [a,d] for objectives “a” and “d”) within the text. Note that some of the examples contain company names; all company names used in this document are fictitious.
    • Provides potential assessment considerations. These may include common considerations for assessing the requirement and potential questions the assessor may ask when assessing the objectives.
  • Key References: Lists the security requirement from NIST SP 800-172.

Access Control (AC)

AC.L3-3.1.2e – Organizationally Controlled Assets

SECURITY REQUIREMENT

Restrict access to systems and system components to only those information resources that are owned, provisioned, or issued by the organization.

ASSESSMENT OBJECTIVES
[a] Information resources that are owned, provisioned, or issued by the organization are identified; and
[b] Access to systems and system components is restricted to only those information resources that are owned, provisioned, or issued by the organization.
More Practice Details...

AC.L3-3.1.3e – Secured Information Transfer

SECURITY REQUIREMENT

Employ secure information transfer solutions to control information flows between security domains on connected systems.

ASSESSMENT OBJECTIVES
[ODP1] Secure information transfer solutions are defined;
[a] Information flows between security domains on connected systems are identified; and
[b] Secure information transfer solutions are employed to control information flows between security domains on connected systems.
More Practice Details...

Awareness and Training (AT)

AT.L3-3.2.1e – Advanced Threat Awareness

SECURITY REQUIREMENT

Provide awareness training upon initial hire, following a significant cyber event, and at least annually, focused on recognizing and responding to threats from social engineering, advanced persistent threat actors, breaches, and suspicious behaviors; update the training at least annually or when there are significant changes to the threat.

ASSESSMENT OBJECTIVES

Determine if:

[a] Threats from social engineering, advanced persistent threat actors, breaches, and suspicious behaviors are identified;
[b] Awareness training focused on recognizing and responding to threats from social engineering, advanced persistent threat actors, breaches, and suspicious behaviors is provided upon initial hire, following a significant cyber event, and at least annually;
[c] Significant changes to the threats from social engineering, advanced persistent threat actors, breaches, and suspicious behaviors are identified; and
[d] Awareness training is updated at least annually or when there are significant changes to the threat.
More Practice Details...

AT.L3-3.2.2e – Practical Training Exercises

SECURITY REQUIREMENT

Include practical exercises in awareness training for all users, tailored by roles, to include general users, users with specialized roles, and privileged users, that are aligned with current threat scenarios and provide feedback to individuals involved in the training and their supervisors.

ASSESSMENT OBJECTIVES

Determine if:

[a] Practical exercises are identified;
[b] Current threat scenarios are identified;
[c] Individuals involved in training and their supervisors are identified;
[d] Practical exercises that are aligned with current threat scenarios are included in awareness training for all users, tailored by roles, to include general users, users with specialized roles, and privileged users; and
[e] Feedback is provided to individuals involved in the training and their supervisors.
More Practice Details...

Configuration Management (CM)

CM.L3-3.4.1e – Authoritative Repository

SECURITY REQUIREMENT

Establish and maintain an authoritative source and repository to provide a trusted source and accountability for approved and implemented system components.

ASSESSMENT OBJECTIVES

Determine if:

[a] Approved system components are identified;
[b] Implemented system components are identified;
[c] An authoritative source and repository are established to provide a trusted source and accountability for approved and implemented system components; and
[d] An authoritative source and repository are maintained to provide a trusted source and accountability for approved and implemented system components.
More Practice Details...

CM.L3-3.4.2e – Automated Detection & Remediation

SECURITY REQUIREMENT

Employ automated mechanisms to detect misconfigured or unauthorized system components; after detection, remove the components or place the components in a quarantine or remediation network to facilitate patching, re-configuration, or other mitigations.

ASSESSMENT OBJECTIVES

Determine if:

[a] Automated mechanisms to detect misconfigured or unauthorized system components are identified;
[b] Automated mechanisms are employed to detect misconfigured or unauthorized system components;
[c] Misconfigured or unauthorized system components are detected; and
[d] After detection, system components are removed or placed in a quarantine or remediation network to facilitate patching, re-configuration, or other mitigations.
More Practice Details...

CM.L3-3.4.3e – Automated Inventory

SECURITY REQUIREMENT

Employ automated discovery and management tools to maintain an up-to-date, complete, accurate, and readily available inventory of system components.

ASSESSMENT OBJECTIVES

Determine if:

[a] Automated discovery and management tools for the inventory of system components are identified;
[b] An up-to-date, complete, accurate, and readily available inventory of system components exists; and
[c] Automated discovery and management tools are employed to maintain an up-to-date, complete, accurate, and readily available inventory of system components.
More Practice Details...

Identification and Authentication (IA)

IA.L3-3.5.1e – Bidirectional Authentication

SECURITY REQUIREMENT

Identify and authenticate systems and system components, where possible, before establishing a network connection using bidirectional authentication that is cryptographically based and replay resistant.

ASSESSMENT OBJECTIVES

Determine if:

[ODP1] Systems and system components to identify and authenticate are defined;
[a] Bidirectional authentication that is cryptographically-based is implemented;
[b] Bidirectional authentication that is replay-resistant is implemented; and
[c] Systems and system components, where possible, are identified and authenticated before establishing a network connection using bidirectional authentication that is cryptographically-based and replay-resistant.
More Practice Details...

IA.L3-3.5.3e – Block Untrusted Assets

SECURITY REQUIREMENT

Employ automated or manual/procedural mechanisms to prohibit system components from connecting to organizational systems unless the components are known, authenticated, in a properly configured state, or in a trust profile.

ASSESSMENT OBJECTIVES

Determine if:

[a] System components that are known, authenticated, in a properly configured state, or in a trust profile are identified;
[b] Automated or manual/procedural mechanisms to prohibit system components from connecting to organizational systems are identified; and
[c] Automated or manual/procedural mechanisms are employed to prohibit system components from connecting to organizational systems unless the components are known, authenticated, in a properly configured state, or in a trust profile.
More Practice Details...

Incident Response (IR)

IR.L3-3.6.1e – Security Operations Center

SECURITY REQUIREMENT

Establish and maintain a security operations center capability that operates 24/7, with allowance for remote/on-call staff.

ASSESSMENT OBJECTIVES

Determine if:

[a] A security operations center capability is established;
[b] The security operations center capability operates 24/7, with allowance for remote/on-call staff; and
[c] The security operations center capability is maintained.
More Practice Details...

IR.L3-3.6.2e – Cyber Incident Response Team

SECURITY REQUIREMENT

Establish and maintain a cyber incident response team that can be deployed by the organization within 24 hours.

ASSESSMENT OBJECTIVES

Determine if:

[a] A cyber incident response team is established;
[b] The cyber incident response team can be deployed by the organization within 24 hours; and
[c] The cyber incident response team is maintained.
More Practice Details...

Personnel Security (PS)

PS.L3-3.9.2e – Adverse Information

SECURITY REQUIREMENT

Ensure that organizational systems are protected if adverse information develops or is obtained about individuals with access to CUI.

ASSESSMENT OBJECTIVES

Determine if:

[a] Individuals with access to CUI are identified;
[b] Adverse information about individuals with access to CUI is defined;
[c] Organizational systems to which individuals have access are identified; and
[d] Mechanisms are in place to protect organizational systems if adverse information develops or is obtained about individuals with access to CUI.
More Practice Details...

Risk Assessment (RA)

RA.L3-3.11.1e – Threat-Informed Risk Assessment

SECURITY REQUIREMENT

Employ threat intelligence, at a minimum from open or commercial sources, and any DoD-provided sources, as part of a risk assessment to guide and inform the development of organizational systems, security architectures, selection of security solutions, monitoring, threat hunting, and response and recovery activities.

ASSESSMENT OBJECTIVES

Determine if:

[ODP1] Sources of threat intelligence are defined;
[a] A risk assessment methodology is identified;
[b] Threat intelligence, at a minimum from open or commercial sources, and any DoD-provided sources, are employed as part of a risk assessment to guide and inform the development of organizational systems and security architectures;
[c] Threat intelligence, at a minimum from open or commercial sources, and any DoD-provided sources, are employed as part of a risk assessment to guide and inform the selection of security solutions;
[d] Threat intelligence, at a minimum from open or commercial sources, and any DoD-provided sources, are employed as part of a risk assessment to guide and inform system monitoring activities;
[e] Threat intelligence, at a minimum from open or commercial sources, and any DoD-provided sources, are employed as part of a risk assessment to guide and inform threat hunting activities; and
[f] Threat intelligence, at a minimum from open or commercial sources, and any DoD-provided sources, are employed as part of a risk assessment to guide and inform response and recovery activities.
More Practice Details...

RA.L3-3.11.2e – Threat Hunting

SECURITY REQUIREMENT

Conduct cyber threat hunting activities on an on-going aperiodic basis or when indications warrant, to search for indicators of compromise in organizational systems and detect, track, and disrupt threats that evade existing controls.

ASSESSMENT OBJECTIVES

Determine if:

[ODP4] Organizational systems to search for indicators of compromise are defined;
[a] Indicators of compromise are identified;
[b] Cyber threat hunting activities are conducted on an on-going aperiodic basis or when indications warrant, to search for indicators of compromise in organizational systems; and
[c] Cyber threat hunting activities are conducted on an on-going aperiodic basis or when indications warrant, to detect, track, and disrupt threats that evade existing controls.
More Practice Details...

RA.L3-3.11.3e – Advanced Risk Identification

SECURITY REQUIREMENT

Employ advanced automation and analytics capabilities in support of analysts to predict and identify risks to organizations, systems, and system components.

ASSESSMENT OBJECTIVES

Determine if:

[a] Advanced automation and analytics capabilities to predict and identify risks to organizations, systems, and system components are identified;
[b] Analysts to predict and identify risks to organizations, systems, and system components are identified; and
[c] Advanced automation and analytics capabilities are employed in support of analysts to predict and identify risks to organizations, systems, and system components.
More Practice Details...

RA.L3-3.11.4e – Security Solution Rationale

SECURITY REQUIREMENT

Document or reference in the system security plan the security solution selected, the rationale for the security solution, and the risk determination.

ASSESSMENT OBJECTIVES

Determine if:

[a] The system security plan documents or references the security solution selected;
[b] The system security plan documents or references the rationale for the security solution; and
[c] The system security plan documents or references the risk determination.
More Practice Details...

RA.L3-3.11.5e – Security Solution Effectiveness

SECURITY REQUIREMENT

Assess the effectiveness of security solutions at least annually or upon receipt of relevant cyber threat information, or in response to a relevant cyber incident, to address anticipated risk to organizational systems and the organization based on current and accumulated threat intelligence.

ASSESSMENT OBJECTIVES

Determine if:

[a] Security solutions are identified;
[b] Current and accumulated threat intelligence is identified;
[c] Anticipated risk to organizational systems and the organization based on current and accumulated threat intelligence is identified; and
[d] The effectiveness of security solutions is assessed at least annually or upon receipt of relevant cyber threat information, or in response to a relevant cyber incident, to address anticipated risk to organizational systems and the organization based on current and accumulated threat intelligence.
More Practice Details...

RA.L3-3.11.6e – Supply Chain Risk Response

SECURITY REQUIREMENT

Assess, respond to, and monitor supply chain risks associated with organizational systems and system components.

ASSESSMENT OBJECTIVES

Determine if:

[a] Supply chain risks associated with organizational systems and system components are identified;
[b] Supply chain risks associated with organizational systems and system components are assessed;
[c] Supply chain risks associated with organizational systems and system components are responded to; and
[d] Supply chain risks associated with organizational systems and system components are monitored.
More Practice Details...

RA.L3-3.11.7e – Supply Chain Risk Plan

SECURITY REQUIREMENT

Develop a plan for managing supply chain risks associated with organizational systems and system components; update the plan at least annually, and upon receipt of relevant cyber threat information, or in response to a relevant cyber incident.

ASSESSMENT OBJECTIVES

Determine if:

[a] Supply chain risks associated with organizational systems and system components are identified;
[b] Organizational systems and system components to include in a supply chain risk management plan are identified;
[c] A plan for managing supply chain risks associated with organizational systems and system components is developed; and
[d] The plan for managing supply chain risks is updated at least annually, and upon receipt of relevant cyber threat information, or in response to a relevant cyber incident.
More Practice Details...

Security Assessment (CA)

CA.L3-3.12.1e – Penetration Testing

SECURITY REQUIREMENT

Conduct penetration testing at least annually or when significant security changes are made to the system, leveraging automated scanning tools and ad hoc tests using subject matter experts.

ASSESSMENT OBJECTIVES

Determine if:

[a] Automated scanning tools are identified;
[b] Ad hoc tests using subject matter experts are identified; and
[c] Penetration testing is conducted at least annually or when significant security changes are made to the system, leveraging automated scanning tools and ad hoc tests using subject matter experts.
More Practice Details...

System and Communications Protection (SC)

SC.L3-3.13.4e – isolation

SECURITY REQUIREMENT

Employ physical isolation techniques or logical isolation techniques or both in organizational systems and system components.

ASSESSMENT OBJECTIVES

Determine if:

[ODP1] One or more of the following is/are selected: physical isolation techniques; logical isolation techniques;
[ODP2] Physical isolation techniques are defined (if selected);
[ODP3] Logical isolation techniques are defined (if selected);
[a] Physical isolation techniques or logical isolation techniques or both are employed in organizational systems and system components.
More Practice Details...

System and Information Integrity (SI)

SI.L3-3.14.1e – Integrity Verification

SECURITY REQUIREMENT

Verify the integrity of security critical and essential software using root of trust mechanisms or cryptographic signatures.

ASSESSMENT OBJECTIVES

Determine if:

[ODP1] Security critical or essential software is defined;
[a] Root of trust mechanisms or cryptographic signatures are identified; and
[b] The integrity of security critical and essential software is verified using root of trust mechanisms or cryptographic signatures.
More Practice Details...

SI.L3-3.14.3e – Specialized Asset Security

SECURITY REQUIREMENT

Ensure that specialized assets including IoT, IIoT, OT, GFE, Restricted Information Systems and test equipment are included in the scope of the specified enhanced security requirements or are segregated in purpose-specific networks.

ASSESSMENT OBJECTIVES

Determine if:

[a] Specialized assets including IoT, IIoT, OT, GFE, Restricted Information Systems and test equipment are included in the scope of the specified enhanced security requirements; and
[b] Systems and system components that are not included in specialized assets including IoT, IIoT, OT, GFE, Restricted Information Systems and test equipment are segregated in purpose-specific networks.
More Practice Details...

SI.L3-3.14.6e – Threat-Guided Intrusion Detection

SECURITY REQUIREMENT

Use threat indicator information and effective mitigations obtained from, at a minimum, open or commercial sources, and any DoD-provided sources, to guide and inform intrusion detection and threat hunting.

ASSESSMENT OBJECTIVES

Determine if:

[ODP1] External organizations from which to obtain threat indicator information and effective mitigations are defined;
[a] Threat indicator information is identified;
[b] Effective mitigations are identified;
[c] Intrusion detection approaches are identified;
[d] Threat hunting activities are identified; and
[e] Threat indicator information and effective mitigations obtained from, at a minimum, open or commercial sources and any DoD-provided sources, are used to guide and inform intrusion detection and threat hunting.
More Practice Details...

Appendix A – Acronyms and Abbreviations

AC Access Control
ACL Access Control List
ACM Automated Configuration Management
ACMS Automated Configuration Management System
APT Advanced Persistent Threat
AT Awareness and Training
C3PAO CMMC Third-Party Assessment Organization
CA Certification Authority
CA Security Assessment
CERT Computer Emergency Response Team
CFR Code of Federal Regulations
CIO Chief Information Officer
CIRT Computer Incident Response Team; Cyber Incident Response Team
CISO Chief Information Security Officer
CM Configuration Management
CMMC Cybersecurity Maturity Model Certification
CUI Controlled Unclassified Information
DCSA Defense Counterintelligence and Security Agency
DFARS Defense Federal Acquisition Regulation Supplement
DIB Defense Industrial Base
DLP Data Loss Prevention
DMZ Demilitarized Zone
DoD Department of Defense
DRM Digital Rights Management
ESP External Service Provider
FIPS Federal Information Processing Standard
GFE Government Furnished Equipment
GPO Group Policy Object
HR Human Resources
IA Identification and Authentication
ICS Industrial Control System
IIoT Industrial Internet of Things
IOC Indicators of Compromise
IoT Internet of Things
IP Internet Protocol
IR Incident Response
ISAC Information Sharing and Analysis Center
ISAO Information Sharing and Analysis Organization
IT Information Technology
MLS Multi-Level Secure
N/A Not Applicable
NAC Network Access Control
NIST National Institute of Standards and Technology
ODP Organization-Defined Parameters
OS Operating System
OT Operational Technology
PKI Public Key Infrastructure
PS Personnel Security
RA Risk Assessment
SC System and Communications Protection
SCADA Supervisory Control and Data Acquisition
SCRM Supply Chain Risk Management
SI System and Information Integrity
SIEM Security Information and Event Management
SOAR Security Orchestration, Automation, and Response
SOC Security Operations Center
SP Special Publication
SSP System Security Plan
TEE Trusted Execution Environment
TLS Transport Layer Security
TPM Trusted Platform Module
TTP Tactics, Techniques, and Procedures
UEFI Unified Extensible Firmware Interface
USB Universal Serial Bus
VLAN Virtual Local Area Network
VPN Virtual Private Network
XDR Extended Detection and Response
  1. NIST SP800-172A, March 2022
  2. Note that an OSC ought to be mindful of their full Level 3 scoping in their request for a Level 2 assessment.
  3. NIST SP 800-53 Rev. 5, p. 402
  4. NIST SP 800-171A, June 2018, p. v
  5. NIST SP 800-171 Rev. 2, Appendix B, p. 54 (adapted)
  6. NIST SP 800-160 Vol. 1 R1, Engineering Trustworthy Secure Systems, 2022, Appendix B., p. 55
  7. The organization defining the parameters is the DoD.