CUI Compliant
0 NIST 800-171 gaps detected. FedRAMP authorized. Leading privileged access management (PAM) platform. Essential for NIST 800-171 3.1.x controls requiring privileged account management, session recording, and credential vaulting.
CyberArk
by CyberArk
FedRAMP Status
FedRAMP Authorized
Impact Level
Moderate
Category
Identity & Access Management
Authorized: June 15, 2020
Overview
CyberArk is a FedRAMP authorized privileged access management platform providing credential vaulting, session recording, privileged session management, and just-in-time access. Essential for NIST 800-171 controls around privileged account management and session monitoring.
CUI Risk Assessment
FedRAMP authorized. Leading privileged access management (PAM) platform. Essential for NIST 800-171 3.1.x controls requiring privileged account management, session recording, and credential vaulting.
Using CyberArk in a Defense Contractor Environment
CyberArk serves as the cornerstone privileged access management platform for defense contractors handling CUI across multiple categories including technical data packages (TDP), contract line item numbers (CLIN) financial data, and personally identifiable information (PII) from security clearance investigations. Within CMMC Level 2 authorization boundaries, CyberArk typically sits at the network perimeter managing privileged accounts for enterprise systems, SCADA/ICS networks, and cloud infrastructure containing CUI. Its FedRAMP Moderate authorization allows deployment in contractor networks processing CUI, with the vault infrastructure requiring placement within the assessed environment boundary. DCMA/DIBCAC assessors consistently evaluate CyberArk deployments during CMMC assessments by examining session recording configurations, privileged account discovery coverage, and integration with Active Directory for NIST 800-171 AC-2 compliance. Recent DCMA reviews have favorably noted CyberArk implementations that demonstrate comprehensive privileged session monitoring (AU-2, AU-3) and automated credential rotation (IA-5). Compensating controls typically include network segmentation between CyberArk components and CUI systems, dedicated service accounts with principle of least privilege, and integration with SIEM platforms for correlated analysis of privileged access events. Defense contractors using CyberArk must ensure proper configuration of session isolation policies to prevent cross-contamination between classified and CUI environments, particularly in cleared defense contractor facilities managing multiple security domains.
Deployment & Architecture
Deployment Model: Government Cloud (FedRAMP boundary)
CyberArk 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.
Implementation Guide
Defense contractors implementing CyberArk for CUI environments should plan an 8-12 week phased deployment starting with network architecture assessment and authorization boundary definition. Phase 1 (weeks 1-3) involves infrastructure provisioning within the FedRAMP boundary, including vault servers, CPM engines, and PSM components with appropriate network segmentation from CUI processing systems. Phase 2 (weeks 4-6) requires privileged account discovery across Windows domain controllers, Linux systems, and database servers containing CUI, followed by onboarding of service accounts supporting CUI applications. Phase 3 (weeks 7-9) focuses on session recording configuration for privileged access to CUI systems, requiring integration with existing SIEM platforms and establishment of retention policies meeting NIST 800-171 AU-11 requirements. User training demands 16 hours for system administrators and 8 hours for end-users accessing CUI systems through CyberArk, with role-based training on session isolation procedures and incident response protocols. Compliance documentation updates include SSP modifications for AC-2, AC-3, AC-6, and AU-2 controls, authorization boundary diagram updates showing CyberArk placement, and POA&M entries for any interim security measures. Implementation costs typically range from $150,000-$400,000 for mid-sized defense contractors (500-2000 users), including licensing, professional services, and infrastructure modifications. Organizations must budget additional $50,000-$100,000 annually for compliance maintenance and quarterly security assessments required under DFARS 252.204-7012.
Configuration Checklist
- 1ISSO must update the System Security Plan (SSP) to include CyberArk components within the authorization boundary and document privileged access management controls (AC-2, AC-6, AU-2).
- 2Network administrator must configure network segmentation between CyberArk vault infrastructure and CUI processing systems per NIST 800-171 SC-7 requirements.
- 3System administrator must install and configure CyberArk Vault server within FedRAMP authorized cloud infrastructure ensuring encryption at rest and in transit.
- 4Database administrator must onboard privileged service accounts supporting CUI applications into CyberArk vault with automated password rotation enabled.
- 5ISSO must configure session recording policies for all privileged access to CUI systems ensuring 90-day retention minimum per AU-11 requirements.
- 6Security administrator must integrate CyberArk with existing SIEM platform for centralized monitoring and alerting of privileged access events.
- 7Training coordinator must conduct role-based CyberArk training for 16 hours (administrators) and 8 hours (end users) with CUI handling procedures.
- 8Compliance officer must update DFARS 252.204-7012 implementation documentation to reflect CyberArk privileged access controls and monitoring capabilities.
- 9ISSO must create POA&M entries for any privileged accounts not yet onboarded to CyberArk with target completion dates.
- 10Quality assurance lead must validate CyberArk session recording functionality captures all privileged commands executed on CUI systems for audit purposes.
Compliance Cross-References
CyberArk's FedRAMP Moderate authorization directly supports NIST 800-171 control families AC (Access Control) through privileged account management and session isolation, AU (Audit and Accountability) via comprehensive session recording and privileged access logging, and SC (System and Communications Protection) through encrypted credential storage and secure session tunneling. The platform triggers DFARS 252.204-7012 compliance requirements for privileged access controls and 252.204-7021 cybersecurity maturity model certification at Level 2, specifically addressing assessment domains for Access Control (AC) and Audit and Accountability (AU). CMMC Level 2 assessments evaluate CyberArk implementations across AC.L2-3.1.1 (authorized access enforcement), AC.L2-3.1.2 (transaction and function controls), AU.L2-3.3.1 (audit record creation), and AU.L2-3.3.2 (audit record protection). FedRAMP continuous monitoring requirements mandate quarterly vulnerability scans of CyberArk infrastructure and annual penetration testing of privileged access pathways. Non-compliance or misconfiguration of CyberArk creates cascading findings in AC-2 (account management), AC-6 (least privilege), AU-2 (audit events), and AU-3 (audit record content) control families, potentially resulting in CMMC assessment findings that affect contractor eligibility for DoD contracts requiring CUI protection.
Other FedRAMP Authorized Identity & Access Management Tools
Related Compliance Assessments
Frequently Asked Questions
Do I need PAM for CMMC compliance?
NIST 800-171 requires controlling privileged access (3.1.5, 3.1.6, 3.1.7) and monitoring privileged sessions. A PAM solution like CyberArk provides centralized enforcement of these controls.
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