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Level 2 SC.L2-3.13.12

Prohibit remote activation of collaborative computing devices

📖 What This Means

This control requires organizations to disable the ability for collaborative computing devices (like video conferencing systems, smart whiteboards, or audio systems) to be turned on remotely. This means no one outside the physical location should be able to activate these devices, reducing the risk of unauthorized access or eavesdropping. For example, a hacker shouldn't be able to turn on your conference room camera without someone in the room pressing the power button. Another example: a Zoom Room system should not accept 'wake-on-LAN' commands from outside the network.

🎯 Why It Matters

Remote activation of collaborative devices creates a stealthy eavesdropping risk. Attackers could turn on cameras/microphones to spy on sensitive discussions (including CUI). In 2019, a US defense contractor had their conference room compromised via an unsecured VoIP system, leaking discussions about a classified project. The average cost of a corporate espionage incident exceeds $1 million. The DoD specifically calls out this control because collaborative devices are common in defense contractor facilities and often overlooked in security configurations.

How to Implement

  1. 1. For cloud-managed devices (e.g., Microsoft Teams Rooms), disable 'remote wake' features in admin portals
  2. 2. In AWS/Azure/GCP, configure NACLs to block Wake-on-LAN (WoL) packets (UDP ports 7, 9, or vendor-specific)
  3. 3. Use Conditional Access policies (Azure AD) to block remote management of device power states
  4. 4. Enable device-specific controls (e.g., Cisco Webex Devices → disable 'Remote Power On' in settings)
  5. 5. Log all power state changes in cloud SIEM (e.g., Azure Sentinel alerts for unexpected activations)
⏱️
Estimated Effort
2-4 hours for technical implementation (mid-level network admin), plus 1 hour for policy updates. Critical devices may require physical changes (30 mins/device).

📋 Evidence Examples

Network Switch Configuration

Format: CLI dump or config backup
Frequency: Annually or after network changes
Contents: Commands showing WoL blocking (e.g., 'show running-config | include wake-on')
Collection: Export from switch admin interface

Collaborative Device Policy

Format: PDF/DOCX
Frequency: Annual review
Contents: Explicit prohibition of remote activation with device-specific examples
Collection: Export from document management system

SIEM Alert Logs

Format: CSV/PDF report
Frequency: Quarterly
Contents: 30-day sample showing no unauthorized activation attempts
Collection: Export from SIEM console

Physical Inspection Photos

Format: JPG/PNG
Frequency: Initial implementation
Contents: Device power cables showing no WoL connections
Collection: On-site photos with timestamps

📝 SSP Guidance

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

How to Write the SSP Narrative

For SC.L2-3.13.12 ("Prohibit remote activation of collaborative computing 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 your network security architecture, including segmentation, encryption standards, VPN configuration, session management, key management, and monitoring capabilities. Be specific -- name your actual products, settings, and responsible personnel.

Example SSP Narratives

Cloud (Azure/AWS)

"SC.L2-3.13.12 is implemented using cloud-native controls. [Organization] uses [specific cloud service/feature] to prohibit remote activation of collaborative computing devices. 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

"SC.L2-3.13.12 is implemented through on-premise infrastructure controls. [Organization] uses [Active Directory/Group Policy/specific tool] to prohibit remote activation of collaborative computing devices. Configuration is documented in [location] and audited [frequency]. Responsible party: [System Administrator]. Evidence: [specific artifact, e.g., 'Group Policy export, Windows Event logs']."

Hybrid

"SC.L2-3.13.12 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

  • Document network architecture with CUI boundary clearly marked
  • Identify all encryption mechanisms (at rest and in transit)
  • Specify network monitoring and IDS/IPS deployment
  • Ensure this control covers all systems within your defined CUI boundary where prohibit remote activation of collaborative computing devices applies
  • Document any systems where this control is not applicable and explain why

Key Documentation to Reference in SSP

  • 📄 System and Communications Protection Policy
  • 📄 Network architecture diagram
  • 📄 Firewall rule documentation
  • 📄 Encryption configuration documentation
  • 📄 Evidence artifacts specific to SC.L2-3.13.12
  • 📄 POA&M entry if control is not fully implemented

What the Assessor Looks For

The assessor will review network diagrams for proper segmentation, test encryption settings, verify VPN split tunneling is disabled, and check FIPS 140-2 validation of cryptographic modules.

💬 Self-Assessment Questions

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

Question 1: Do all collaborative computing devices have physical/network controls preventing remote activation?

✅ YES → Proceed to Q2
❌ NO → GAP: Inventory all devices and implement switch port security or physical disconnection within 14 days
Remediation:
Use nmap -sU -p 7,9 [subnet] to find WoL-enabled devices

Question 2: Is there a written policy explicitly prohibiting remote activation?

✅ YES → Proceed to Q3
❌ NO → GAP: Draft policy using NIST SP 800-171 template Appendix F within 7 days
Remediation:
Include make/model examples like 'Poly Studio X50 must have Wake-on-LAN disabled'

Question 3: Are logs reviewed quarterly for unauthorized activation attempts?

✅ YES → Proceed to Q4
❌ NO → GAP: Configure SIEM alerts for WoL packets and schedule reviews within 30 days
Remediation:
Splunk query: 'udp.port==7 OR udp.port==9 | stats count by src_ip'

Question 4: Have all relevant staff been trained on this requirement?

✅ YES → COMPLIANT
❌ NO → GAP: Schedule training using CMMC Level 2 Awareness materials within 60 days
Remediation:
Include hands-on demo of how to verify physical WoL disconnection

⚠️ Common Mistakes (What Auditors Flag)

1. Assuming 'off' means disabled

Why this happens: Many devices enter low-power mode but remain network-accessible
How to avoid: Physically unplug or verify complete power cycle disconnects network

2. Missing secondary control channels

Why this happens: Overlooking vendor-specific apps that can power devices (e.g., Crestron App)
How to avoid: Test all vendor management apps during implementation

3. No monitoring for bypass attempts

Why this happens: Focusing only on prevention without detection
How to avoid: Configure IDS rules for WoL packets (Snort rule: 'alert udp any any -> any 7 (msg:"WoL attempt";)'

4. Incomplete documentation

Why this happens: Only capturing network settings without physical evidence
How to avoid: Create checklist with photos of both switch configs and device back panels

📚 Parent Policy

This practice is governed by the System and Communications Protection Policy

View SC Policy →

📚 Related Controls