Not CUI Compliant
5 NIST 800-171 gaps detected. Commercial Salesforce is not FedRAMP authorized. Data may be processed outside the US by non-US personnel. Cannot be used for CUI.
Salesforce (Commercial)
by Salesforce
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
CRM
Overview
Commercial Salesforce runs on shared multi-tenant infrastructure without the isolation, US-only data residency, or personnel screening required for CUI. Many small contractors default to commercial Salesforce without understanding it cannot hold CUI data.
CUI Risk Assessment
Commercial Salesforce is not FedRAMP authorized. Data may be processed outside the US by non-US personnel. Cannot be used for CUI.
Using Salesforce (Commercial) in a Defense Contractor Environment
Commercial Salesforce is frequently used by defense contractors for customer relationship management, storing CUI including technical specifications (CTI), procurement sensitive information, contractor performance assessments, and financial data from cost-plus contracts. In CMMC Level 2 environments, commercial Salesforce creates a critical compliance gap as it operates outside the authorization boundary on shared, multi-tenant infrastructure without FedRAMP authorization. The platform's global data processing model means CUI could be accessed by non-US personnel or stored in foreign data centers, violating controlled access requirements. DCMA and DIBCAC assessors consistently flag commercial Salesforce during CMMC assessments because it cannot demonstrate adequate safeguarding controls for CUI. Compensating controls are insufficient - the fundamental architecture violates baseline security requirements. Assessors specifically examine data flow diagrams to identify CUI touching commercial cloud services, making Salesforce Commercial an automatic finding that requires remediation before CMMC certification.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
Salesforce (Commercial) 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 migrate from commercial Salesforce within 60-90 days of CUI identification to maintain compliance. Begin with a comprehensive data inventory to identify all CUI within Salesforce objects, custom fields, and file attachments. Export critical data using Salesforce Data Export service or third-party tools like Talend. Migrate to Salesforce Government Cloud Plus (FedRAMP authorized) or alternative CRM solutions like Microsoft Dynamics 365 GCC High. Plan for 4-6 weeks of user retraining as Government Cloud has different feature sets and interface restrictions. Update System Security Plans to remove commercial Salesforce from the authorization boundary and document new CUI flow diagrams. Coordinate with contracts team to ensure new platform meets specific DFARS requirements. Consider staged migration approach: non-CUI data first (30 days), followed by CUI migration with parallel systems running for 2 weeks to ensure data integrity before final cutover.
Migration Checklist
- 1ISSO: Conduct immediate CUI data audit within Salesforce objects and attachments (Week 1)
- 2Contracts team: Procure Salesforce Government Cloud Plus or alternative FedRAMP authorized CRM (Week 2)
- 3Sysadmin: Configure data export procedures and backup all Salesforce data before migration (Week 3)
- 4ISSO: Update System Security Plan to remove commercial Salesforce from authorization boundary (Week 4)
- 5Sysadmin: Execute phased data migration starting with non-CUI customer data (Weeks 5-6)
- 6Security team: Implement access controls and audit logging in new compliant platform (Week 7)
- 7ISSO: Validate CUI handling procedures and update incident response plans (Week 8)
- 8Training coordinator: Complete user certification on new platform before CUI access (Week 8)
Compliance Cross-References
Commercial Salesforce violations directly impact NIST 800-171 Access Control (3.1.x) and System and Communications Protection (3.13.x) families, specifically failing controlled access requirements and data location controls. This triggers DFARS 252.204-7012 non-compliance, requiring immediate corrective action plans. CMMC assessment domains affected include Access Control (AC), System and Communications Protection (SC), and Configuration Management (CM) due to inadequate boundary controls. The violation creates a Level 1 finding in CMMC assessments, potentially blocking contract awards until remediated with FedRAMP authorized alternatives.
NIST 800-171 Violations
Using Salesforce (Commercial) for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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Related Compliance Assessments
Frequently Asked Questions
Is commercial Salesforce compliant for defense contractors?
No. Commercial Salesforce lacks FedRAMP authorization. Salesforce Government Cloud is the compliant version with FedRAMP High authorization and dedicated US infrastructure.
What is the difference between Salesforce commercial and Government Cloud?
Government Cloud runs on isolated infrastructure, restricts data to the US, screens all personnel, and holds FedRAMP High authorization. Commercial Salesforce has none of these protections.
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