CUI Compliant
0 NIST 800-171 gaps detected. FedRAMP authorized at High impact level. Approved for CUI handling in DoD environments.
Zscaler Government Cloud
by Zscaler
FedRAMP Status
FedRAMP Authorized
Impact Level
High
Category
Cybersecurity
Authorized: August 28, 2019 | Sponsor: Department of Homeland Security
Overview
Zscaler Government Cloud is a FedRAMP High authorized zero-trust network security platform. It provides secure web gateway, cloud firewall, and zero-trust access for government network traffic.
CUI Risk Assessment
FedRAMP authorized at High impact level. Approved for CUI handling in DoD environments.
Using Zscaler Government Cloud in a Defense Contractor Environment
Zscaler Government Cloud serves as a critical security boundary for defense contractors handling CUI categories including technical data (ITAR-controlled drawings, specifications), procurement-sensitive information (bid data, pricing), and operational security data (network configurations, security procedures). Within CMMC Level 2 authorization boundaries, it typically functions as the primary egress control point for all internet-bound traffic from CUI-processing systems. The platform's FedRAMP High authorization makes it suitable for integration with DoD Enterprise Infrastructure Services and provides necessary audit logging for DFARS 252.204-7012 compliance. Compensating controls required include local network segmentation to ensure CUI traffic routes exclusively through Zscaler tunnels, endpoint DLP integration to prevent unauthorized data exfiltration, and robust identity federation with DoD PKI certificates. DCMA/DIBCAC assessors specifically evaluate Zscaler's configuration for proper traffic inspection policies, CUI marking preservation during transit, and integration with contractor SIEM systems for incident response. Recent DCMA reviews have highlighted the importance of documenting data flow diagrams showing how CUI traverses Zscaler's inspection engines and ensuring that all traffic policies align with data classification levels. Assessors also verify that contractors maintain local traffic logs to complement Zscaler's cloud-based logging for complete audit trails required under NIST 800-171 AU family controls.
Deployment & Architecture
Deployment Model: Government Cloud (FedRAMP boundary)
Zscaler Government Cloud 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 Zscaler Government Cloud for CUI environments should plan an 8-12 week phased deployment. Phase 1 (weeks 1-2) involves updating the System Security Plan to include Zscaler as a boundary protection component and revising authorization boundary diagrams to show traffic flow through Zscaler's FedRAMP environment. Phase 2 (weeks 3-5) requires establishing secure tunnels from contractor networks to Zscaler Government Cloud, configuring DLP policies to inspect CUI markings, and integrating with existing identity management systems. Phase 3 (weeks 6-8) focuses on policy migration from existing web gateways, including URL filtering rules, malware protection settings, and bandwidth management for CUI traffic. User training during weeks 7-8 should cover new authentication procedures and incident reporting protocols. Phase 4 (weeks 9-12) involves compliance validation, including penetration testing of the new traffic flows and SIEM integration testing. Data export considerations include preserving existing web access logs for NIST 800-171 audit requirements and ensuring CUI traffic policies migrate without gaps. Cost estimates range from $150,000-$300,000 annually depending on user count and bandwidth requirements, plus one-time implementation costs of $50,000-$100,000 for professional services and training. No migration away from Zscaler Government Cloud is needed given its compliant status.
Configuration Checklist
- 1ISSO must update the System Security Plan to document Zscaler Government Cloud as the primary internet gateway for CUI traffic processing, including data flow diagrams per NIST 800-171 control CM-8.
- 2Network administrators configure secure IPSec tunnels from all CUI-processing network segments to route traffic exclusively through Zscaler Government Cloud infrastructure.
- 3ISSO establishes DLP policies within Zscaler to detect and protect CUI markings during web traffic inspection, addressing NIST 800-171 control AC-4 information flow enforcement.
- 4System administrators integrate Zscaler with existing Active Directory or PKI infrastructure to ensure proper user authentication for CUI access per AC-2 account management controls.
- 5Security team configures Zscaler's advanced threat protection to scan all downloads for malware before reaching CUI-processing endpoints, supporting SI-3 malicious code protection.
- 6ISSO documents incident response procedures for Zscaler-detected threats in the Incident Response Plan, ensuring compliance with NIST 800-171 control IR-4.
- 7Network administrators establish bandwidth prioritization rules to ensure mission-critical CUI traffic receives adequate performance through Zscaler infrastructure.
- 8ISSO configures audit logging integration between Zscaler and contractor SIEM to meet NIST 800-171 control AU-6 audit review requirements for CUI access monitoring.
- 9Contracts officer updates DFARS 252.204-7012 flow-down language to reflect Zscaler Government Cloud as an approved CUI processing boundary in subcontractor agreements.
- 10Security team validates authorization boundary documentation includes Zscaler Government Cloud connections and updates POA&M entries for any implementation gaps.
Compliance Cross-References
Zscaler Government Cloud's FedRAMP High authorization directly supports NIST 800-171 control families including SC-System and Communications Protection through encrypted tunnel establishment, AC-Access Control via integrated authentication mechanisms, and AU-Audit and Accountability through comprehensive traffic logging. The platform's implementation triggers DFARS clause 252.204-7012 requirements for CUI protection during internet transit and 252.204-7021 for cybersecurity incident reporting when threats are detected. For CMMC Level 2 assessments, Zscaler Government Cloud impacts domains including Access Control (AC), System and Information Integrity (SI), and Incident Response (IR) by providing documented security boundaries and threat detection capabilities. The FedRAMP authorization satisfies supply chain risk management requirements under NIST 800-171 control SR-2 by providing a government-validated cloud service. Non-compliance scenarios would create findings in SC-7 boundary protection if traffic bypasses Zscaler, AU-2 audit events if logging integration fails, and AC-4 information flow enforcement if DLP policies don't properly handle CUI markings, potentially resulting in DFARS compliance violations and contract performance issues.
Other FedRAMP Authorized Cybersecurity Tools
Related Compliance Assessments
Frequently Asked Questions
Is Zscaler Government Cloud FedRAMP authorized?
Yes. Zscaler Government Cloud holds FedRAMP High authorization for zero-trust network security.
Can I use Zscaler Government with CUI network traffic?
Yes. Zscaler Government Cloud is approved for inspecting and securing network traffic containing CUI in defense environments.
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