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Level 2 AC.L2-3.1.7

Prevent non-privileged users from executing privileged functions

📖 What This Means

This practice ensures that only authorized users with elevated privileges can perform critical system operations, such as installing software, changing system settings, or accessing sensitive data. Non-privileged users, who have limited access rights, should not be able to execute these functions. This is essential to prevent accidental or intentional misuse of system privileges, which could lead to security breaches or data loss. For example, a regular employee should not be able to install unauthorized software on a company computer, as this could introduce malware. Similarly, a non-admin user should not be able to modify firewall settings, which could expose the network to external threats.

🎯 Why It Matters

Allowing non-privileged users to execute privileged functions can lead to significant security risks, such as unauthorized access to sensitive data, system compromise, or malware installation. For instance, in the 2017 Equifax breach, attackers exploited a vulnerability that allowed them to execute privileged commands, leading to the exposure of personal data of 147 million people. The Department of Defense (DoD) and CMMC emphasize this control to ensure that only trusted personnel can perform critical operations, reducing the risk of insider threats and external attacks. Failing to implement this control can result in costly data breaches, reputational damage, and non-compliance penalties.

How to Implement

  1. 1. Use Identity and Access Management (IAM) tools (e.g., AWS IAM, Azure AD) to define roles and permissions.
  2. 2. Assign privileged roles only to authorized administrators.
  3. 3. Enable Multi-Factor Authentication (MFA) for privileged accounts.
  4. 4. Use Policy as Code tools (e.g., Terraform, CloudFormation) to enforce least privilege.
  5. 5. Regularly audit permissions using cloud-native tools (e.g., AWS Config, Azure Security Center).
  6. 6. Implement Just-In-Time (JIT) access for privileged functions using tools like PAM (Privileged Access Management).
  7. 7. Monitor and log all privileged actions using cloud logging services (e.g., AWS CloudTrail, Azure Monitor).
⏱️
Estimated Effort
Implementation typically takes 2-3 days with intermediate IT skills. Ongoing maintenance requires 1-2 hours per week for audits and updates.

📋 Evidence Examples

IAM Role Configuration

Format: Screenshot/JSON
Frequency: Quarterly
Contents: Role definitions showing restricted privileges
Collection: Export from AWS IAM/Azure AD

Privileged Access Logs

Format: CSV/Log File
Frequency: Monthly
Contents: Logs of privileged actions (e.g., admin logins, command executions)
Collection: Export from SIEM/PAM tool

RBAC Policy Document

Format: PDF
Frequency: Annually
Contents: Policy detailing role-based access controls
Collection: Create/update policy document

Audit Report

Format: PDF
Frequency: Quarterly
Contents: Results of privileged access audits
Collection: Generate from audit tool

Training Records

Format: Spreadsheet
Frequency: Annually
Contents: List of trained personnel on privileged access management
Collection: Maintain training logs

📝 SSP Guidance

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

How to Write the SSP Narrative

For AC.L2-3.1.7 ("Prevent non-privileged users from executing privileged functions"), 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.L2-3.1.7 is implemented using cloud-native controls. [Organization] uses [specific cloud service/feature] to prevent non-privileged users from executing privileged functions. 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.L2-3.1.7 is implemented through on-premise infrastructure controls. [Organization] uses [Active Directory/Group Policy/specific tool] to prevent non-privileged users from executing privileged functions. 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.L2-3.1.7 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 prevent non-privileged users from executing privileged functions 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.L2-3.1.7
  • 📄 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: Are privileged roles restricted to authorized personnel?

✅ YES → Proceed to Q2
❌ NO → GAP: Review and assign privileged roles to authorized users immediately.
Remediation:
Update IAM/RBAC policies and conduct training within 1 week.

Question 2: Is Multi-Factor Authentication (MFA) enabled for privileged accounts?

✅ YES → Proceed to Q3
❌ NO → GAP: Implement MFA for all privileged accounts.
Remediation:
Enable MFA in IAM/Azure AD within 3 days.

Question 3: Are privileged actions logged and monitored?

✅ YES → Proceed to Q4
❌ NO → GAP: Enable logging and monitoring for privileged actions.
Remediation:
Configure SIEM/PAM tools within 1 week.

Question 4: Are privileged access policies reviewed quarterly?

✅ YES → Proceed to Q5
❌ NO → GAP: Schedule quarterly reviews of privileged access policies.
Remediation:
Set up a recurring calendar event and assign responsibility.

Question 5: Is training provided to personnel on privileged access management?

✅ YES → FULL COMPLIANCE
❌ NO → GAP: Conduct training sessions on privileged access management.
Remediation:
Schedule training within 2 weeks and maintain records.

⚠️ Common Mistakes (What Auditors Flag)

1. Over-assigning privileged roles

Why this happens: Lack of clear role definitions or oversight
How to avoid: Regularly audit and update role assignments

2. Not enabling MFA for privileged accounts

Why this happens: Perceived complexity or lack of awareness
How to avoid: Mandate MFA for all privileged accounts

3. Inadequate logging of privileged actions

Why this happens: Misconfiguration or resource constraints
How to avoid: Ensure proper configuration of logging tools

4. Outdated access policies

Why this happens: Lack of regular reviews
How to avoid: Schedule quarterly policy reviews

5. Missing training records

Why this happens: Failure to document training sessions
How to avoid: Maintain a centralized training log

📚 Parent Policy

This practice is governed by the Access Control Policy

View AC Policy →

📚 Related Controls