Overview

Security Requirements for 03.13.11 CUI Encryption

Cryptography can be employed to support many security solutions including the protection of controlled unclassified information, the provision of digital signatures, and the enforcement of information separation when authorized individuals have the necessary clearances for such information but lack the necessary formal access approvals. Cryptography can also be used to support random number generation and hash generation. Cryptographic standards include FIPSvalidated cryptography and/or NSA-approved cryptography. See [NIST CRYPTO]; [NIST CAVP]; and [NIST CMVP].

Assessment GuidanceExamine 0/9

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

Discussion

FIPS-validated cryptography means the cryptographic module has to have been tested and validated to meet FIPS 140-2 requirements. Simply using an approved algorithm is not sufficient – the module (software and/or hardware) used to implement the algorithm must be separately validated under FIPS 140. Accordingly, FIPS-validated cryptography is

required to protect CUI when transmitted or stored outside the protected environment of the covered OSA information system (including wireless/remote access). Encryption used for other purposes, such as within applications or devices within the protected environment of the covered OSA information system, would not need to use FIPS-validated cryptography.

This requirement, SC.L2-3.13.11, complements AC.L2-3.1.19, MP.L2-3.8.6, SC.L2-3.13.8, and SC.L2-3.13.16 by specifying that FIPS-validated cryptography must be used. While FIPSvalidated modules and algorithms are critical for protecting CUI, in limited cases Enduring Exceptions and temporary deficiencies may apply when implementing such cryptographic mechanisms.

Examples

  1. Example 1

    You are a system administrator responsible for deploying encryption on all devices that contain CUI. You must ensure that the encryption you use on the devices is FIPS-validated cryptography [a]. An employee informs you of a need to carry a large volume of CUI offsite and asks for guidance on how to do so. You provide the user with disk encryption software that you have verified via the NIST website that uses a CMVP-validated encryption module [a]. Once the encryption software is active, the user copies the CUI data onto the drive for transport.

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
  • Personnel with responsibilities for cryptographic protection
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 supporting or implementing cryptographic protection

Potential Assessment Considerations

  • Is cryptography implemented to protect the confidentiality of CUI at rest and in transit, through the configuration of systems and applications or through the use of encryption tools [a]?

Key References

NIST SP 800-171 Rev. 2 3.13.11

Evidence

  1. 03.13.11.a

    Fips-validated cryptography is employed to protect the confidentiality of cui