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Level 1 AC.L1-3.1.1

Limit system access to authorized users, processes acting on behalf of authorized users, and devices

📖 What This Means

This control means ensuring only the right people, automated processes, and devices can access your systems. Think of it like a bouncer at a club—only those on the list get in. For example, only your accounting team should access financial systems, and only company-issued laptops should connect to your network. This prevents unauthorized access that could lead to data leaks or system tampering. Another real-world example: A contractor's employee leaves the company, but their account isn't disabled. Without this control, they could still access sensitive files.

🎯 Why It Matters

Unrestricted access is a top cause of data breaches. In 2022, 80% of breaches involved compromised credentials (Verizon DBIR). A single unauthorized user or device can expose Controlled Unclassified Information (CUI), costing $180 per record in remediation (IBM). The DoD requires this because defense contractors are prime targets—foreign actors often exploit weak access controls to steal military designs. CMMC Level 1 makes this foundational: if you can't control who gets in, you can't protect CUI.

How to Implement

  1. 1. In AWS/Azure/GCP, enable Identity and Access Management (IAM) and create roles for each job function (e.g., 'Finance-ReadOnly').
  2. 2. Set up Multi-Factor Authentication (MFA) for all human users (use Google Authenticator or Duo).
  3. 3. Configure Conditional Access Policies (Azure) or IAM Policies (AWS) to block logins from non-company IPs.
  4. 4. Use Azure AD Device Compliance or AWS Managed Microsoft AD to allow only enrolled devices.
  5. 5. For automated processes, create service accounts with least privilege (e.g., 'CI-CD-Deployer').
  6. 6. Enable logging (AWS CloudTrail/Azure Monitor) and alert on unusual access patterns.
⏱️
Estimated Effort
Cloud: 8-16 hours (mid-level skill). On-prem: 20-40 hours (AD expertise needed).

📋 Evidence Examples

Access Control Policy

Format: PDF/DOCX
Frequency: Annual review, update when roles change.
Contents: Defines roles, approval process for access, and device requirements.
Collection: Export from SharePoint/Google Docs.

Screenshot of IAM Roles

Format: PNG/PDF
Frequency: Every 6 months or after changes.
Contents: AWS IAM console showing 'Finance-ReadOnly' permissions.
Collection: Use Snipping Tool, annotate with role purpose.

Active Directory Group List

Format: CSV
Frequency: Quarterly.
Contents: Export of AD groups with members (sanitize passwords).
Collection: PowerShell: Get-ADGroupMember 'HR_FullAccess'.

Failed Login Report

Format: XLSX
Frequency: Monthly.
Contents: Last 30 days of failed attempts with IP addresses.
Collection: Azure Sentinel query or Splunk report.

MFA Enrollment Report

Format: PDF
Frequency: Bi-weekly until 100%, then quarterly.
Contents: List of users with MFA status (e.g., 100% enforced).
Collection: Azure AD Portal > Security > MFA.

📝 SSP Guidance

Use this guidance when writing the System Security Plan (SSP) narrative for this control.

How to Write the SSP Narrative

For AC.L1-3.1.1 ("Limit system access to authorized users, processes acting on behalf of authorized users, and devices"), your SSP narrative should specifically describe: (1) the tools and technologies you use to implement this control, (2) the configuration or process that enforces it, (3) who is responsible for maintaining it, and (4) what evidence proves it's working. Describe how access to CUI systems is controlled, including the specific IAM tools, policies, and processes used. Reference your Access Control Policy and identify the systems in scope. Be specific -- name your actual products, settings, and responsible personnel.

Example SSP Narratives

Cloud (Azure/AWS)

"AC.L1-3.1.1 is implemented using cloud-native controls. [Organization] uses [specific cloud service/feature] to limit system access to authorized users, processes acting on behalf of authorize.... The configuration is managed through [Azure Policy/AWS Config/Terraform] and monitored via [SIEM tool]. Responsible party: [IT Security Manager]. Evidence: [specific artifact, e.g., 'Azure AD Conditional Access policy screenshot, CloudTrail logs']."

On-Premise

"AC.L1-3.1.1 is implemented through on-premise infrastructure controls. [Organization] uses [Active Directory/Group Policy/specific tool] to limit system access to authorized users, processes acting on behalf of authorize.... Configuration is documented in [location] and audited [frequency]. Responsible party: [System Administrator]. Evidence: [specific artifact, e.g., 'Group Policy export, Windows Event logs']."

Hybrid

"AC.L1-3.1.1 is implemented across both cloud and on-premise environments. [Organization] uses [Azure AD Connect/hybrid tool] to ensure consistent enforcement. Cloud resources are managed via [cloud tool] and on-premise systems via [on-prem tool]. Both environments report to [centralized SIEM]. Responsible party: [IT Director]. Evidence: [artifacts from both environments]."

System Boundary Considerations

  • Identify all access points to CUI systems (VPN, direct network, cloud portals)
  • Document which IAM system manages access (Azure AD, AWS IAM, on-prem AD)
  • Map user roles to system access levels
  • Ensure this control covers all systems within your defined CUI boundary where limit system access to authorized users, processes acting on behalf of authorized users, and devices applies
  • Document any systems where this control is not applicable and explain why

Key Documentation to Reference in SSP

  • 📄 Access Control Policy
  • 📄 IAM configuration documentation
  • 📄 Access request and approval records
  • 📄 Evidence artifacts specific to AC.L1-3.1.1
  • 📄 POA&M entry if control is not fully implemented

What the Assessor Looks For

The assessor will verify that access controls are implemented as described, test whether unauthorized users are blocked, and review access logs for evidence of enforcement.

💬 Self-Assessment Questions

Use these questions to assess your compliance. Each "NO" answer provides specific remediation guidance.

Question 1: Do you have a written policy defining who can access systems and how?

✅ YES → Proceed to Q2.
❌ NO → GAP: Draft a policy using NIST 800-171 template. Timeline: 2 weeks.
Remediation:
https://csrc.nist.gov/CSRC/media/Projects/Protecting-CUI/documents/Draft_NIST_SP_800-171_Revision_3.pdf

Question 2: Are all user accounts reviewed quarterly to remove inactive/unauthorized ones?

✅ YES → Proceed to Q3.
❌ NO → GAP: Run AD or IAM report, disable stale accounts. Timeline: 1 week.
Remediation:
PowerShell: Search-ADAccount -AccountInactive -TimeSpan 90.00:00:00

Question 3: Is MFA enabled for all cloud and VPN access?

✅ YES → Proceed to Q4.
❌ NO → GAP: Enforce MFA in Azure AD/AWS IAM. Timeline: 3 days.
Remediation:
Azure guide: https://learn.microsoft.com/en-us/azure/active-directory/authentication/tutorial-enable-azure-mfa

Question 4: Do you block personal devices from accessing CUI systems?

✅ YES → Proceed to Q5.
❌ NO → GAP: Implement MDM (Intune/JAMF) or MAC filtering. Timeline: 2 weeks.
Remediation:
Intune setup: https://learn.microsoft.com/en-us/mem/intune/fundamentals/what-is-intune

Question 5: Are service accounts (non-human) documented and restricted to least privilege?

✅ YES → COMPLIANT.
❌ NO → GAP: Inventory service accounts, restrict permissions. Timeline: 1 week.
Remediation:
AWS CLI: aws iam list-users --query 'Users[?starts_with(UserName,`svc-`)].UserName'

⚠️ Common Mistakes (What Auditors Flag)

1. Shared admin accounts (e.g., '[email protected]') with no individual tracking.

Why this happens: Legacy systems or convenience override security.
How to avoid: Create individual admin accounts (e.g., '[email protected]').

2. Missing MFA for cloud consoles (AWS/Azure).

Why this happens: Assumed password is enough.
How to avoid: Enable MFA enforcement in IAM settings; test with a test account.

3. No process to revoke access when employees leave.

Why this happens: HR-IT disconnect.
How to avoid: Automate offboarding with tools like Okta Workflows or MS Power Automate.

4. Personal devices allowed without security checks.

Why this happens: BYOD policies not updated for CUI.
How to avoid: Require Intune/JAMF enrollment for any device accessing CUI.

5. Service accounts with excessive permissions (e.g., full admin).

Why this happens: Set up quickly for automation without review.
How to avoid: Document each service account's purpose and scope permissions to that need.

📚 Parent Policy

This practice is governed by the Access Control Policy

View AC Policy →

📚 Related Controls