What 3.3.1 means in practice

Decide which events matter (sign-ins, privilege use, changes, access to CUI), make sure every system records them with enough detail to investigate, and keep the records long enough to use. Assessors check both the list of event types and real logs that contain them.

SPRS points and the CMMC POA&M

CMMC Level 2 practice
AU.L2-3.3.1
SPRS points
5 points. When it is not met, the DoD Assessment Methodology subtracts 5 from the score of 110.
CMMC POA&M
Not allowed. It is worth 5 points, and 32 CFR 170.21(a)(2)(ii) admits only requirements worth 1 point, with one exception: 3.13.11 when encryption is used but not FIPS validated.

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 3.3.1

NIST SP 800-171A gives 6 determination statements for 3.3.1, each found satisfied or other than satisfied. Determine if:

  1. 3.3.1[a] audit logs needed (i.e., event types to be logged) to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity are specified.
  2. 3.3.1[b] the content of audit records needed to support monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity is defined.
  3. 3.3.1[c] audit records are created (generated).
  4. 3.3.1[d] audit records, once created, contain the defined content.
  5. 3.3.1[e] retention requirements for audit records are defined.
  6. 3.3.1[f] audit records are retained as defined.

NIST SP 800-171A (June 2018), assessment objectives for 3.3.1

Evidence that shows 3.3.1 is met

  • The list of event types to log and the content each record must hold.
  • Logging configuration for the identity provider, servers, network devices and cloud services.
  • Sample audit records showing the defined content.
  • The retention period and the storage settings that enforce it.

How PolicyCortex gathers the evidence

PolicyCortex reads this evidence with the collectors below, read only, and grades 3.3.1 from it. Each line says what the product checks.

  • Azure Monitor: Diagnostic settings. Checks that diagnostic settings capture the sign-in and audit log categories and send them to a Log Analytics workspace.
  • AWS: CloudTrail and CloudWatch. Checks that CloudTrail is on in every region, delivers to CloudWatch Logs and records S3 data events.
  • AWS: S3 buckets · EC2 and VPC networking · Data stores · Load balancers, API Gateway, CloudFront and Lambda. Checks that S3 server access logging, VPC flow logs, RDS log exports, and load balancer, API Gateway and CloudFront logging are turned on.

Meet the requirement once. Keep the evidence current.

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