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
Authorized: May 1, 2013
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.
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 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.
NIST 800-171 Violations
Using AWS (Commercial) for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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FedRAMP Compliant Alternatives
Related Compliance Assessments
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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