Overview

Security Requirements for 03.01.03 Control CUI Flow

Information flow control regulates where information can travel within a system and between systems (versus who can access the information) and without explicit regard to subsequent accesses to that information. Flow control restrictions include the following: keeping exportcontrolled information from being transmitted in the clear to the Internet; blocking outside traffic that claims to be from within the organization; restricting requests to the Internet that are not from the internal web proxy server; and limiting information transfers between organizations based on data structures and content.Organizations commonly use information flow control policies and enforcement mechanisms to control the flow of information between designated sources and destinations (e.g., networks, individuals, and devices) within systems and between interconnected systems. Flow control is based on characteristics of the information or the information path. Enforcement occurs in boundary protection devices (e.g., gateways, routers, guards, encrypted tunnels, firewalls) that employ rule sets or establish configuration settings that restrict system services, provide a packetfiltering capability based on header information, or message-filtering capability based on message content (e.g., implementing key word searches or using document characteristics). Organizations also consider the trustworthiness of filtering and inspection mechanisms (i.e., hardware, firmware, and software components) that are critical to information flow enforcement.Transferring information between systems representing different security domains with different security policies introduces risk that such transfers violate one or more domain security policies. In such situations, information owners or stewards provide guidance at designated policy enforcement points between interconnected systems. Organizations consider mandating specific architectural solutions when required to enforce specific security policies. Enforcement includes: prohibiting information transfers between interconnected systems (i.e., allowing access only); employing hardware mechanisms to enforce one-way information flows; and implementing trustworthy regrading mechanisms to reassign security attributes and security labels.

Assessment GuidanceExamine 0/10

How an assessor determines this requirement is met. Source: CMMC Assessment Guide – Level 2, Version 2.13 (NIST SP 800-171 Rev. 2).

Discussion

Typically, companies will have a firewall between the internal network and the internet. Often multiple firewalls or routing switches are used inside a network to create zones to separate sensitive data, business units, or user groups. Proxy servers can be used to break the connection between multiple networks. All traffic entering or leaving a network is intercepted by the proxy, preventing direct access between networks. Companies should also ensure by policy and enforcement mechanisms that all CUI allowed to flow across the internet is encrypted.

Examples

  1. Example 1

    You configure a proxy device on your company’s network. CUI is stored within this environment. Your goal is to better mask and protect the devices inside the network while enforcing information flow policies. After the device is configured, information does not flow

  2. Example 2

    directly from the internal network to the internet. The proxy device intercepts the traffic and analyzes it to determine if the traffic conforms to organization information flow control policies. If it does, the device allows the information to pass to its destination [b]. The proxy blocks traffic that does not meet policy requirements [e].

  3. Example 3

    As a subcontractor on a DoD contract, your organization sometimes needs to transmit CUI to the prime contractor. You create a policy document that specifies who is allowed to transmit CUI and that such transmission requires manager approval [a, c, d]. The policy instructs users to encrypt any CUI transmitted via email or to use a designated secure file sharing utility [b, d]. The policy states that users who do not follow appropriate procedures may be subject to disciplinary action [e].

Assessment Methods

Examine
The process of reviewing, inspecting, observing, studying, or analyzing assessment objects (e.g., policies, procedures, plans, system designs, mechanisms) to facilitate understanding, achieve clarification, or obtain evidence.Example: An assessor reads the access control policy and inspects system configuration settings to confirm they match.

Not all of the evidence listed is required to meet this requirement — check the items your organization has collected.

Interview
The process of holding discussions with individuals or groups within an organization to facilitate understanding, achieve clarification, or identify the location of evidence.Example: An assessor asks a system administrator to describe how user accounts are approved, reviewed, and disabled.
  • System or network administrators
  • Personnel with information security responsibilities
  • System developers
Test
The process of exercising assessment objects (e.g., activities, mechanisms) under specified conditions to compare actual behavior with expected behavior.Example: An assessor attempts to sign in with a disabled account to confirm that access is denied.
  • Mechanisms implementing information flow enforcement policy

Potential Assessment Considerations

  • Are designated sources of regulated data identified within the system (e.g., internal network and IP address) and between interconnected systems (e.g., external networks, IP addresses, ports, and protocols) [c]?
  • Are designated destinations of regulated data identified within the system (e.g., internal network and IP address) and between interconnected systems (external networks and IP addresses) [c]?
  • Are authorizations defined for each source and destination within the system and between interconnected systems (e.g., allow or deny rules for each combination of source and destination) [d]?
  • Are approved authorizations for controlling the flow of regulated data enforced within the system and between interconnected systems (e.g., traffic between authorized sources and destinations is allowed and traffic between unauthorized sources and destinations is denied) [e]?

Key References

NIST SP 800-171 Rev. 2 3.1.3

Evidence

  1. 03.01.03.a

    Information flow control policies are defined

  1. 03.01.03.b

    Methods and enforcement mechanisms for controlling the flow of cui are defined

  1. 03.01.03.c

    Designated sources and destinations (e.g., networks, individuals, and devices) for cui within the system and between interconnected systems are identified

  1. 03.01.03.d

    Authorizations for controlling the flow of cui are defined

  1. 03.01.03.e

    Approved authorizations for controlling the flow of cui are enforced