Partial CUI Compliance
1 NIST 800-171 gaps detected. AWS commercial regions are FedRAMP Moderate, NOT High. Many contractors use commercial AWS thinking any AWS is sufficient, but GovCloud is required for CUI needing FedRAMP High.
AWS (Commercial)
by Amazon Web Services
FedRAMP Status
FedRAMP Authorized
Impact Level
Moderate
Category
Cloud Storage
Overview
AWS commercial regions hold FedRAMP Moderate authorization. While suitable for some government workloads, they do not meet FedRAMP High requirements for DoD CUI. AWS GovCloud is the isolated, ITAR-compliant environment required for CUI.
CUI Risk Assessment
AWS commercial regions are FedRAMP Moderate, NOT High. Many contractors use commercial AWS thinking any AWS is sufficient, but GovCloud is required for CUI needing FedRAMP High.
Using AWS (Commercial) in a Defense Contractor Environment
AWS Commercial regions present significant compliance risks for defense contractors handling CUI. While FedRAMP Moderate authorized, AWS Commercial cannot process CUI requiring FedRAMP High controls, including technical data packages (TDP), engineering drawings with ITAR markings, financial performance reports, and contractor personnel records containing PII. In CMMC Level 2 environments, AWS Commercial creates authorization boundary complications as CUI data flows between compliant on-premises systems and non-High cloud storage. Required compensating controls include data classification at rest, encryption key management outside AWS Commercial, and documented data flow restrictions. DCMA assessors consistently flag AWS Commercial usage during CMMC readiness reviews, particularly when contractors store technical drawings or manufacturing data. Recent DIBCAC compliance reviews have identified AWS Commercial as a primary gap, with assessors requiring immediate migration plans to AWS GovCloud or alternative FedRAMP High solutions. The tool's broad permissions model and shared tenancy architecture conflict with NIST 800-171 access control requirements, making it unsuitable for prime contractors and critical subcontractors processing sensitive DoD technical data.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
AWS (Commercial) operates within a FedRAMP-authorized boundary. CUI can be processed within the authorization scope, but contractors must verify their specific use case falls within the system's security boundary as documented in the SSP.
Migration Guidance
Defense contractors must migrate from AWS Commercial to AWS GovCloud within 90-120 days to maintain CUI compliance. Phase 1 (weeks 1-4): ISSO conducts data inventory to identify all CUI assets in AWS Commercial, categorizes by sensitivity level, and creates migration priority matrix. Phase 2 (weeks 5-8): Establish AWS GovCloud environment with appropriate FISMA controls, configure IAM policies for CMMC Level 2 requirements, and implement encryption key management. Phase 3 (weeks 9-12): Execute phased data migration using AWS DataSync or AWS Storage Gateway, maintaining CUI handling procedures throughout transfer. Data export considerations include encrypting all CUI during transit, maintaining chain of custody documentation, and ensuring no CUI remains in Commercial regions post-migration. User training requires 8 hours covering GovCloud interface differences, new authentication procedures, and CUI marking requirements. Update System Security Plan to reflect new authorization boundary, modify POA&M entries for resolved SC-8 and SC-13 findings, and revise data flow diagrams. Migration costs range $50,000-$200,000 depending on data volume, including GovCloud premium pricing (30-50% higher), professional services, and compliance documentation updates.
Migration Checklist
- 1ISSO must immediately inventory all data stored in AWS Commercial and classify CUI vs non-CUI assets per NIST 800-60 guidelines.
- 2Contracts officer reviews all active DoD contracts to identify DFARS 252.204-7012 flowdown requirements affecting cloud storage decisions.
- 3ISSO creates AWS GovCloud account and configures FISMA Moderate baseline controls per NIST 800-53 requirements.
- 4System administrator implements customer-managed encryption keys using AWS KMS in GovCloud to satisfy NIST 800-171 control SC-13.
- 5ISSO updates System Security Plan authorization boundary diagrams to exclude AWS Commercial and include GovCloud environment.
- 6Data migration team executes CUI data transfer using AWS DataSync with encryption in transit per NIST 800-171 control SC-8.
- 7ISSO validates all CUI has been purged from AWS Commercial accounts and obtains certificate of destruction.
- 8Security team implements CloudTrail logging in GovCloud to satisfy NIST 800-171 audit requirements in control family AU.
- 9ISSO updates POA&M to close findings related to unauthorized CUI processing in non-FedRAMP High environments.
- 10Compliance officer notifies DCMA of completed migration and provides updated authorization boundary documentation.
Compliance Cross-References
AWS Commercial non-compliance directly impacts NIST 800-171 System and Communications Protection (SC) family, specifically SC-8 (transmission confidentiality) and SC-13 (cryptographic protection) due to inadequate FedRAMP High controls. Access Control (AC) family violations occur through shared tenancy and insufficient privilege management for CUI. Triggers DFARS 252.204-7012 flowdown requirements for adequate security, potentially invoking 252.204-7021 cybersecurity maturity assessments. CMMC Level 2 assessment domains affected include Access Control (AC.L2), System and Information Integrity (SI.L2), and Risk Management (RM.L2). The compliance gap creates findings in Configuration Management (CM) family when contractors cannot demonstrate adequate boundary controls. FedRAMP authorization boundary misalignment violates government-wide cloud security policies, requiring immediate remediation to maintain GSA schedules and DoD contract eligibility.
NIST 800-171 Violations
Using AWS (Commercial) for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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Frequently Asked Questions
Is commercial AWS sufficient for CUI?
Commercial AWS is FedRAMP Moderate only. For DoD CUI requiring FedRAMP High, you must use AWS GovCloud, which is physically isolated with US-person-only staff.
What is the difference between AWS commercial and GovCloud?
GovCloud runs in isolated US regions, restricts access to US persons, supports ITAR, and holds FedRAMP High. Commercial AWS regions are global, shared infrastructure with FedRAMP Moderate.
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