What 3.1.3 means in practice

This requirement is about where CUI may travel, not who may read it. Decide which networks, systems, people and services CUI may move between, then enforce those routes with firewalls, network rules, proxies or data loss prevention, so CUI cannot leave the approved paths by accident.

SPRS points and the CMMC POA&M

CMMC Level 2 practice
AC.L2-3.1.3
SPRS points
1 point. When it is not met, the DoD Assessment Methodology subtracts 1 from the score of 110.
CMMC POA&M
Allowed. It is worth 1 point, and 32 CFR 170.21(a)(2)(ii) admits requirements worth 1 point. Conditional status also needs a score of at least 88, and the item must be closed within 180 days.

Sources: NIST SP 800-171 DoD Assessment Methodology, version 1.2.1 (June 24, 2020), Annex A; 32 CFR 170.21, Plan of Action and Milestones requirements.

What an assessor checks for 3.1.3

NIST SP 800-171A gives 5 determination statements for 3.1.3, each found satisfied or other than satisfied. Determine if:

  1. 3.1.3[a] information flow control policies are defined.
  2. 3.1.3[b] methods and enforcement mechanisms for controlling the flow of CUI are defined.
  3. 3.1.3[c] designated sources and destinations (e.g., networks, individuals, and devices) for CUI within the system and between interconnected systems are identified.
  4. 3.1.3[d] authorizations for controlling the flow of CUI are defined.
  5. 3.1.3[e] approved authorizations for controlling the flow of CUI are enforced.

NIST SP 800-171A (June 2018), assessment objectives for 3.1.3

Evidence that shows 3.1.3 is met

  • A data flow diagram showing where CUI enters, moves within and leaves the system boundary.
  • The written information flow policy naming approved sources and destinations for CUI.
  • Firewall, network security group or proxy rules that enforce those routes.
  • Data loss prevention or mail gateway rules that stop CUI from reaching unapproved destinations.

How PolicyCortex gathers the evidence

PolicyCortex reads this evidence with the collectors below, read only, and grades 3.1.3 from it. Each line says what the product checks.

  • Azure: Network security groups. Checks that network security group rules control the network traffic that can flow between enclaves.
  • AWS: EC2 and VPC networking. Checks that security groups restrict SSH and common ports from the internet and that each VPC's default security group has no rules.
  • AWS: S3 buckets. Checks that no S3 bucket is publicly readable or publicly writable.

Meet the requirement once. Keep the evidence current.

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