How to Meet the CMMC Audit and Accountability Requirement: Best Practices for CMMC Compliance

The Cybersecurity Maturity Model Certification (CMMC) 2.0 framework represents the latest evolution in the Department of Defense’s (DoD) efforts to secure the defense industrial base (DIB) from cyber threats. CMMC 2.0 is essential for defense contractors seeking to handle controlled unclassified information (CUI) and federal contract information (FCI).

The CMMC 2.0 framework contains 17 domains, one of which is Audit and Accountability (AU). The CMMC Audit and Accountability requirement deals with the transfer and access of CUI and FCI. It requires defense contractors to maintain detailed logs that track who accesses this sensitive information, when it is accessed, and what specific actions are taken with it. By maintaining comprehensive audit trails, defense contractors can ensure that they are adhering to CMMC security policies, identify any unauthorized access or anomalies, and facilitate timely responses to potential breaches or incidents.

In this guide, we’ll provide several best practices and actionable strategies to help you align with the CMMC audit and accountability requirement, that will not only prepare you for CMMC compliance but also enhance your overall security posture.

The CMMC certification process is arduous but our CMMC 2.0 compliance roadmap can help.

The CMMC 2.0 Framework and its 14 Domains

The CMMC framework comprises 14 domains, each containing a set of practices and processes that organizations must implement to achieve a specific maturity level. These domains include Access Control, Awareness and Training, Audit and Accountability, Configuration Management, Identification and Authentication, Incident Response, Maintenance, Media Protection, Personnel Security, Physical Protection, Risk Assessment, Security Assessment, System and Communications Protection, and System and Information Integrity.

The Audit and Accountability domain is crucial for tracking and monitoring activities that could impact CUI and FCI. Understanding how to meet these requirements is vital for defense contractors aiming for CMMC compliance.

CMMC Audit and Accountability Requirement Overview

The CMMC Audit and Accountability domain focuses on creating a robust system for recording and monitoring activities on systems handling CUI and FCI. This involves: logging user actions, maintaining audit logs, and implementing measures to ensure logs are protected and reviewed regularly. Key elements include:

• Logging all access to CUI: Defense contractors must maintain a comprehensive log of all access to CUI as it’s essential for ensuring the security and privacy of sensitive data. This process involves systematically recording detailed information about every instance when CUI is accessed, viewed, modified, or transmitted.

  The log entries should include specifics such as the date and time of access, the identity of the user or system that accessed the information, the nature of the access (e.g., read, write, delete), and the specific data or files that were involved.

  Implementing these CMMC logging practices helps defense contractors monitor and audit data usage, detect unauthorized access, enhance accountability, and support compliance with regulatory and policy requirements governing the protection of CUI.

• Establishing audit log retention policies: Creating guidelines and procedures for how long different types of audit logs should be kept and how they should be managed is essential for maintaining the security and integrity of organizational data. Determine the different categories of audit logs that are generated within the organization, e.g., logs related to user activity, system access, security events, application usage, etc.

  Each category may have different requirements based on the sensitivity of the data and the potential impact of any incidents that might occur. Next, assess the legal and regulatory landscape that applies to the organization. In our case, that’s CMMC 2.0 but can (and often does) include other regulatory compliance frameworks such as NIST CSF, ITAR, ISO 27001, HIPAA, and GDPR.

  Retention policies should also consider other factors, like the likelihood of needing the logs for investigative purposes, the storage costs, and the potential risks of data breaches. Good practice also involves ensuring the integrity and confidentiality of the logs during their retention period, using encryption and access controls to protect the data. Lastly, it is crucial to regularly review and update the retention policies to reflect changes in the regulatory environment, your operations, and emerging security threats.

• Analyzing logs to detect unusual activity: Systematically examine the records generated by various computer systems, applications, and network devices. These logs contain detailed information about events such as user logins, file access, system errors, and network traffic. By scrutinizing these entries, you can identify patterns and anomalies that may indicate security threats, operational issues, or policy violations.

  The process begins with the collection of log data from disparate sources, which are aggregated into a centralized logging system or a security information and event management (SIEM) platform. This central repository allows security analysts to perform comprehensive searches and correlations across all logs.

  Once the log data is collected, it undergoes normalization to ensure consistency and structure, enabling more straightforward analysis. Analysts then apply statistical analysis, machine learning algorithms, and predefined rules to identify deviations from expected behavior. Advanced log analysis tools can automate much of this process, providing real-time alerts and visualizations that help analysts quickly pinpoint and investigate suspicious activities.

Need to comply with CMMC? Here is your complete CMMC compliance checklist.

Achieving compliance with the CMMC Audit and Accountability requirement is far from a “check the box” activity; it involves integrating these practices into daily operations to ensure continuous monitoring, accountability, and CMMC compliance. Proper adherence to the Audit and Accountability requirement helps identify security incidents, supports forensic analysis in the event of a breach, and ensures transparency in the handling of sensitive information.

Best Practices for Meeting the CMMC Audit and Accountability Requirement

The CMMC audit and accountability requirement is critical for defense contractors aiming to secure their data and achieve CMMC compliance. Follow these best practices to ensure adherence to the CMMC audit and accountability requirement, while fostering a culture of accountability and proactive security within your organization.

1. Implement Comprehensive Logging Mechanisms

Log all access to systems, applications, and data handling CUI and FCI comprehensively. This rigorous logging should encompass every successful and unsuccessful login attempt, tracking each effort to access these sensitive systems. Additionally, it is essential to monitor and log file access activities, noting who accessed what files and when. This helps in detecting any unauthorized attempts to view or modify sensitive data. Furthermore, any changes to system settings, which could indicate potential security risks or attempted breaches, must also be meticulously recorded.

Using advanced tools like security information and event management (SIEM), organizations can automate and significantly enhance their CMMC logging activities. SIEM systems not only collect and analyze log data from various sources to provide real-time insights, they can also correlate events from different systems to identify suspicious patterns, triggering alerts for potential security incidents.

2. Regularly Review and Analyze Logs

Create a structured schedule for the consistent review and analysis of audit logs. This routine is vital for the early detection of unusual or suspicious activities within your network or systems, enabling quick and effective responses to potential security threats. By examining these logs regularly, you can identify patterns and anomalies that may indicate malicious behavior or system vulnerabilities.

To enhance the efficiency of this process, integrate automated tools that can monitor audit logs continuously and flag any irregularities or deviations from the norm. These tools use algorithms and machine learning to detect unusual patterns that might be missed during manual reviews. Once an anomaly is detected, it can be prioritized for immediate investigation, allowing your security team to address potential issues before they escalate. Incorporating both regular manual reviews and automated monitoring provides a comprehensive approach to maintaining the integrity and security of your systems, ensuring that any threats are identified and mitigated swiftly.

3. Protect Audit Logs from Unauthorized Access

Storing audit logs securely is crucial for maintaining the integrity and reliability of system monitoring. It is essential to protect these logs from unauthorized access or tampering to ensure that they faithfully represent system activity and can be relied upon for audits, troubleshooting, and forensic investigations. Encrypt these logs to ensure the data inside is unreadable to anyone who does not possess the appropriate decryption keys.

Access controls are another fundamental measure. By setting up robust access controls, you restrict log access to authorized personnel only. This involves defining user roles and permissions, ensuring that only those with a legitimate need can view or manipulate the logs. Implementing measures such as multi-factor authentication (MFA) further enhances security by requiring multiple forms of verification before granting access.

Regular backups are also vital in maintaining the integrity and availability of audit logs. Backups protect against data loss resulting from accidental deletions, hardware failures, or other unforeseen issues. These backups should be stored securely, preferably in multiple locations, to ensure that they are available when needed for recovery purposes.

4. Retain Audit Logs for an Appropriate Duration

Create and implement a comprehensive policy for retaining audit logs. This policy should outline the duration for which various types of logs will be stored. NIST 800-171 Rev. 2, the foundation for CMMC, does not specify an exact retention period for audit logs. CMMC practices generally align, however, with broader cybersecurity best practices, which suggest retaining audit logs for a minimum of one year. This duration allows organizations to detect and respond to security incidents that may only be discovered long after they have occurred.

The retention period may be influenced by contract requirements, organizational policies, and the criticality of the information being protected. And while CMMC compliance should be the primary consideration for determining log retention duration, defense contractors should also factor in anticipated events like security investigations and audits. Otherwise, defense contractors should refer to specific contracts for any stipulated retention requirements, consult internal policies on data retention, and follow industry best practices for cybersecurity log retention.

Contractors may also seek guidance from the DoD or a certified CMMC third party assessor organization (C3PAO) to confirm that their retention practices meet all necessary requirements.

5. Train Personnel on Logging and Accountability Practices

Staff training on the importance of logging and accountability should emphasize how essential these practices are for maintaining the integrity and security of an organization’s systems. Employees should understand that accountability means every action on the system can be traced back to a specific user or entity. This discourages malicious behavior and ensures that users are held responsible for their actions, promoting a culture of transparency and trust.

Training sessions should cover how to recognize signs of suspicious activities such as unauthorized access attempts, anomalies in user behavior, unexpected data transfers, and irregular software or system modifications. Clear scenarios and examples should be provided to help staff identify potential security threats. Additionally, employees must be instructed on the correct procedures for reporting these activities. This includes who to contact, the information to include in the report, and any tools or systems they should use for reporting.

Finally, the training should cover the procedures for handling and protecting audit logs. Staff should be taught the importance of securely storing logs and regularly reviewing and analyzing logs to detect and respond to issues promptly. By the end of the training, employees should have a clear understanding of their roles and responsibilities in maintaining robust logging practices and ensuring accountability within the organization.

6. Establish Incident Response Protocols

Integrating audit log reviews into incident response protocols is essential for enhancing an organization’s ability to manage and mitigate security incidents effectively. When a security breach occurs, the immediate analysis of audit logs can yield vital information about how the breach happened, what systems and data were affected, and the extent of the damage. These logs typically contain detailed records of user activities, system events, and network traffic, making them invaluable for identifying the origin and timeline of the attack.

During an incident, teams responsible for cybersecurity can scrutinize these logs to uncover indicators of compromise (IOCs) such as unusual login attempts, unauthorized access to sensitive data, or anomalies in network traffic. This information not only helps in understanding the breach but also in taking swift actions to contain it.

The insights gained from audit log reviews also enable response teams to develop a more effective remediation plan. By understanding the attackers’ methods and the vulnerabilities exploited, security teams can patch those vulnerabilities and implement stronger security measures to prevent future incidents. Additionally, these reviews can inform long-term improvements to security policies, ensuring that similar breaches are less likely to occur in the future.

7. Perform Regular Audits and Compliance Checks

Conducting regular internal audits and compliance checks play a critical role in assessing how well your current audit log practices adhere to established protocols. By carrying out these audits, you can pinpoint specific gaps in your procedures and identify areas that require enhancement. This proactive approach not only helps in mitigating risks but also ensures that any deviations from the standards are promptly addressed. Ongoing compliance checks serve as a continuous improvement mechanism, enabling your organization to maintain a robust security posture and meet regulatory obligations effectively.

Technology and Tools for CMMC Audit and Accountability Compliance

Selecting the right technology tools is critical for meeting the CMMC 2.0 audit and accountability requirement. Advanced logging tools can automate the collection and analysis of audit logs, providing real-time insights into system activities. These tools should offer features like log aggregation, anomaly detection, and alerting to promptly identify potential security issues.

In addition to logging tools, implementing encryption and access control solutions ensures that audit logs remain secure. Encryption protects the data from being read by unauthorized users, while access controls restrict who can view and modify audit logs. Regular backups and redundant storage solutions ensure that audit logs are not lost in the event of a system failure.

Challenges and Solutions for CMMC Audit and Accountability

Meeting the CMMC 2.0 audit and accountability requirements can present several challenges, including the complexity of managing large volumes of audit logs and ensuring compliance across diverse systems and environments. Organizations often struggle with the resources needed to implement and maintain robust logging practices.

One solution is to leverage managed security service providers (MSSPs) who specialize in CMMC compliance. MSSPs can offer expertise in setting up and maintaining logging mechanisms, conducting regular audits, and ensuring adherence to CMMC standards. Outsourcing these tasks allows defense contractors to focus on their core operations while ensuring compliance and security.

Kiteworks Helps Defense Contractors Adhere to the CMMC Audit and Accountability With a Private Content Network

The audit and accountability domain of CMMC 2.0 plays a critical role in safeguarding the sensitive information defense contractors manage. By implementing comprehensive logging mechanisms, regularly reviewing and protecting logs, retaining logs appropriately, training personnel, and integrating audit practices into incident response protocols, contractors can meet these stringent requirements. Regular audits and compliance checks further ensure continuous adherence to the standards. These practices not only help achieve CMMC compliance but also enhance the overall security posture, enabling defense contractors to protect the critical data they handle.

The Kiteworks Private Content Network, a FIPS 140-2 Level validated secure file sharing and file transfer platform, consolidates email, file sharing, web forms, SFTP, managed file transfer, and next-generation digital rights management solution so organizations control, protect, and track every file as it enters and exits the organization.

Kiteworks supports nearly 90% of CMMC 2.0 Level 2 requirements out of the box. As a result, DoD contractors and subcontractors can accelerate their CMMC 2.0 Level 2 accreditation process by ensuring they have the right sensitive content communications platform in place.

With Kiteworks, DoD contractors and subcontractors unify their sensitive content communications into a dedicated Private Content Network, leveraging automated policy controls and tracking and cybersecurity protocols that align with CMMC 2.0 practices.

Kiteworks enables rapid CMMC 2.0 compliance with core capabilities and features including:

• Certification with key U.S. government compliance standards and requirements, including SSAE-16/SOC 2, NIST SP 800-171, and NIST SP 800-172
• FIPS 140-2 Level 1 validation
• FedRAMP Authorized for Moderate Impact Level CUI
• AES 256-bit encryption for data at rest, TLS 1.2 for data in transit, and sole encryption key ownership

Kiteworks deployment options include on-premises, hosted, private, hybrid, and FedRAMP virtual private cloud. With Kiteworks: control access to sensitive content; protect it when it’s shared externally using automated end-to-end encryption, multi-factor authentication, and security infrastructure integrations; see, track, and report all file activity, namely who sends what to whom, when, and how. Finally demonstrate compliance with regulations and standards like GDPR, HIPAA, CMMC, Cyber Essentials Plus, IRAP, and many more.

To learn more about Kiteworks, schedule a custom demo today.

Additional Resources

• Blog Post CMMC Compliance for Small Businesses: Challenges and Solutions
• Blog Post If You Need to Comply With CMMC 2.0, Here Is Your Complete CMMC Compliance Checklist
• Blog Post CMMC Audit Requirements: What Assessors Need to See When Gauging Your CMMC Readiness
• Guide  CMMC 2.0 Compliance Mapping for Sensitive Content Communications
• Blog Post 12 Things Defense Industrial Base Suppliers Need to Know When Preparing for CMMC 2.0 Compliance