Not CUI Compliant
4 NIST 800-171 gaps detected. Not FedRAMP authorized despite marketing claims. Has suffered multiple data breaches. Cannot be used for credential management in CUI environments.
LastPass
by LastPass (GoTo)
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Identity & Access Management
Overview
LastPass is a widely used password manager that has suffered multiple significant data breaches. It is not FedRAMP authorized despite marketing language suggesting government trust. Defense contractors should not store credentials for CUI systems in LastPass.
CUI Risk Assessment
Not FedRAMP authorized despite marketing claims. Has suffered multiple data breaches. Cannot be used for credential management in CUI environments.
Using LastPass in a Defense Contractor Environment
LastPass presents significant compliance challenges for defense contractors handling CUI under DFARS 252.204-7012. As a password manager, it typically stores credentials for systems containing technical drawings (ITAR), procurement sensitive information, financial data, and contractor PII. Within a CMMC Level 2 authorization boundary, LastPass would be classified as a critical security component managing authentication credentials for CUI systems, making its own security posture paramount. The tool's lack of FedRAMP authorization and history of data breaches (2022 incidents exposing encrypted password vaults) creates immediate compliance violations. No compensating controls can adequately address the fundamental issue of storing CUI system credentials in a non-authorized cloud service. DCMA and DIBCAC assessors consistently flag LastPass during CMMC assessments, specifically citing violations of NIST 800-171 controls 3.1.1 (authorized access), 3.5.10 (cryptographic protection), and 3.13.8 (security engineering principles). Recent DCMA compliance reviews have explicitly called out LastPass as non-compliant, with assessors requiring immediate migration plans. Defense contractors using LastPass face automatic findings during CMMC assessments, as assessors cannot accept risk for storing CUI system credentials in a service that has demonstrated security failures.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
LastPass lacks FedRAMP authorization. Using this tool for CUI processing violates DFARS 252.204-7012 requirements. Defense contractors must evaluate FedRAMP-authorized alternatives or implement and document compensating controls in their POA&M.
Migration Guidance
Defense contractors must immediately begin migration away from LastPass for any systems handling CUI. The migration timeline requires 8-12 weeks across three phases: assessment (2-3 weeks), transition (4-6 weeks), and validation (2-3 weeks). Phase 1 involves cataloging all stored credentials, identifying CUI system passwords, and selecting a compliant alternative like CyberArk (FedRAMP authorized) or implementing on-premises solutions like KeePass Enterprise. Phase 2 requires exporting credential data using LastPass's CSV export function while ensuring CUI data remains encrypted during transfer, establishing new password management infrastructure, and conducting parallel operations. Phase 3 includes user training on new systems, updating all stored passwords, and validating migration completeness. Critical CUI data handling during migration must follow NIST 800-88 media sanitization guidelines. User training requires 4-8 hours per person covering new authentication workflows. Compliance documentation updates include SSP modifications to reflect new password management controls, authorization boundary diagram updates removing LastPass, and POA&M entries tracking migration progress. Recommended alternatives include CyberArk Privileged Access Manager ($150-300/user/year), Microsoft Azure AD with FedRAMP authorization, or on-premises KeePass deployment ($50-100/user setup). Total migration costs range from $25,000-75,000 for mid-size contractors including licensing, implementation, and training.
Migration Checklist
- 1ISSO must immediately add LastPass removal to the POA&M with 90-day completion target per DFARS 252.204-7012 requirements.
- 2Contracts officer should review all DoD contracts to identify CUI handling requirements triggering NIST 800-171 compliance.
- 3ISSO must export all credential data from LastPass using encrypted CSV export while maintaining CUI data protection protocols.
- 4System administrator should implement FedRAMP-authorized alternative (CyberArk, Azure AD) or deploy on-premises KeePass infrastructure.
- 5ISSO must update the System Security Plan to remove LastPass from the authorization boundary diagram and control implementations.
- 6System administrator should establish new password policies aligned with NIST 800-63B authenticator requirements for replacement system.
- 7ISSO must conduct user training on new password management system with emphasis on CUI handling procedures.
- 8System administrator should migrate all CUI system credentials to compliant password manager using secure transfer protocols.
- 9ISSO must validate complete removal of LastPass access to CUI systems and document compliance restoration in assessment report.
- 10Legal counsel should review cyber insurance policies for potential coverage gaps related to data breach exposure from LastPass usage.
Compliance Cross-References
LastPass non-compliance creates cascading violations across multiple NIST 800-171 control families. Access Control (AC) family violations include 3.1.1 (authorized access) as LastPass lacks proper authorization for CUI systems. System and Communications Protection (SC) controls 3.13.8 and 3.13.11 are violated through inadequate security engineering and use of non-approved cryptographic modules. Identification and Authentication (IA) control 3.5.10 fails due to insufficient cryptographic protection of stored credentials. These violations directly trigger DFARS 252.204-7012 non-compliance, potentially resulting in contract performance issues. Under DFARS 252.204-7021, contractors must report the data breaches affecting LastPass as cyber incidents impacting CUI. CMMC Level 2 assessment domains significantly affected include Access Control (AC.L2-3.1.1), System and Communications Protection (SC.L2-3.13.8), and Identification and Authentication (IA.L2-3.5.10). The tool's cloud-hosted nature without FedRAMP authorization creates additional violations of federal cloud security requirements, establishing a clear non-compliance chain requiring immediate remediation to maintain DoD contract eligibility.
NIST 800-171 Violations
Using LastPass for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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Frequently Asked Questions
Is LastPass FedRAMP authorized?
No. Despite marketing that uses terms like "trusted," LastPass does not hold FedRAMP authorization. Its multiple data breaches further undermine its suitability for defense environments.
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