What 3.3.5 means in practice

Log review should not happen in separate silos. When something suspicious shows up, the reviews of identity, endpoint, network and cloud logs are brought together, typically in a SIEM, so one investigation can follow activity across systems.

SPRS points and the CMMC POA&M

CMMC Level 2 practice
AU.L2-3.3.5
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 3.3.5

NIST SP 800-171A gives 2 determination statements for 3.3.5, each found satisfied or other than satisfied. Determine if:

  1. 3.3.5[a] audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity are defined.
  2. 3.3.5[b] defined audit record review, analysis, and reporting processes are correlated.

NIST SP 800-171A (June 2018), assessment objectives for 3.3.5

Evidence that shows 3.3.5 is met

  • The documented review, analysis and reporting process, and how the log sources are combined.
  • SIEM or log platform configuration showing the connected sources.
  • Correlation rules, or an investigation record that drew on several log sources.

How PolicyCortex gathers the evidence

No PolicyCortex collector reads the evidence for 3.3.5. Your team provides the evidence listed above.

Meet the requirement once. Keep the evidence current.

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