Not CUI Compliant
4 NIST 800-171 gaps detected. Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Dropbox Transfer
by Dropbox
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
File Sharing
Overview
Dropbox Transfer is a commercial file delivery tool for sending large files. It is not FedRAMP authorized and should not be used to transfer CUI between defense contractors or government agencies.
CUI Risk Assessment
Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
Dropbox Transfer has no FedRAMP authorization on record. DFARS 252.204-7012(b)(2)(ii)(D) requires an external cloud service provider to meet security requirements equivalent to the FedRAMP Moderate baseline — an authorization is the straightforward way to show that, but it is not the only one. Without one, the burden is on you to establish, document, and defend equivalency, and to meet the clause's incident-reporting and media-preservation obligations. Most contractors find an authorized alternative cheaper than carrying that burden.
Migration Checklist
- 1ISSO shall immediately conduct a comprehensive audit of all Dropbox Transfer accounts to identify CUI exposure and document findings in accordance with DFARS 252.204-7012 incident reporting requirements.
- 2System administrators must disable all Dropbox Transfer access through network controls and endpoint protection policies within 48 hours of assessment completion.
- 3Contracts officer shall review all active DoD contracts to identify potential CUI handling requirements that may have been violated through Dropbox Transfer usage.
- 4ISSO shall update the System Security Plan (SSP) to remove Dropbox Transfer from the authorization boundary and document compensating controls for any identified gaps.
- 5Legal counsel must assess potential disclosure obligations under DFARS 252.204-7012 if CUI was confirmed to have been processed through unauthorized cloud services.
- 6System administrators shall deploy approved FedRAMP authorized alternatives such as Microsoft 365 GCC High or AWS GovCloud for large file transfer requirements.
- 7ISSO must create POA&M entries documenting timeline for complete remediation and ongoing monitoring of unauthorized cloud service usage.
- 8Training coordinator shall implement mandatory CUI handling refresher training for all personnel with previous Dropbox Transfer access within 30 days.
- 9System administrators must implement data loss prevention (DLP) controls to prevent future uploads of CUI to unauthorized cloud services including commercial Dropbox variants.
- 10ISSO shall coordinate with DCMA or DIBCAC point of contact to self-report any confirmed CUI exposure incidents as required under contract compliance obligations.
NIST 800-171 Violations
Using Dropbox Transfer 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 Dropbox Transfer FedRAMP authorized?
No. Dropbox Transfer and its parent Dropbox platform are not FedRAMP authorized.
Can I use Dropbox Transfer with CUI?
No. Dropbox Transfer does not meet FedRAMP or NIST 800-171 requirements for secure CUI file transfers.
What is a compliant alternative to Dropbox Transfer?
SharePoint GCC High and Box for Government are FedRAMP authorized file sharing platforms for defense contractors.
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