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NIST SP 800-172 Enhanced CUI Protection Center

03.02.04E — Anti-Counterfeit Training

Read the official CUI requirement and assessment content, then use the separately labeled Bare Metal Cyber perspective to connect it to implementation, evidence, and sustained operation.

1Parameters
1Source controls
1Assessment objectives
3Assessment methods

03.02 — Awareness and Training · NIST SP 800-172 Revision 3

Active
Official NIST requirement content

Security requirement

Train [Organization-defined: personnel or roles] to detect counterfeit system components.

Official NIST discussion

Discussion

System components include hardware, software, and firmware components as well as the documentation for those components. This requirement is sourced to a control tailored out of the SP 800-53B .13 moderate baseline in SP 800-171.

Official organization-defined parameters

Tailoring decisions required

Resolve these values through the governing organization’s approved tailoring and risk-management process before declaring the requirement implemented.

personnel or rolesorganization-defined personnel or rolespersonnel or roles requiring training to detect counterfeit system components are defined.
Official protection strategy classifications

Protection strategies supported

These classifications are carried from the official SP 800-172 OSCAL record and help explain the enhanced requirement’s defensive purpose.

PS-DLODamage-Limiting Operations
Bare Metal Cyber interpretation

Implementation perspective

Treat Anti-Counterfeit Training as an enhanced CUI protection outcome for elevated threat conditions that must be reflected in the system boundary, documented implementation, operational behavior, and assessment evidence. Pay particular attention to role-based CUI handling knowledge, awareness, and evidence that personnel understand their responsibilities.

  1. Confirm the federal agency selected this enhanced requirement for the critical program or high-value asset and identify the CUI system components, services, users, and external connections in scope.
  2. Resolve every organization-defined parameter through an approved governance and tailoring process.
  3. Map each clause of the requirement to an accountable owner, implementation mechanism, and evidence source.
  4. Verify that inherited and shared implementations are supported by current provider evidence and responsibility boundaries.
  5. Collect evidence during normal operation and review changes, exceptions, and deficiencies on a risk-based cadence.

Questions to ask

  • Which critical-program or high-value-asset CUI, data flows, users, and services are protected by this enhanced requirement?
  • Which portions are implemented locally, inherited, shared, or not applicable, and what evidence supports that determination?
  • Do the system security plan, deployed configuration, operating process, and assessment evidence tell the same story?
  • What change, incident, or threshold should trigger reassessment?

Evidence and validation

  • training plans and role assignments
  • completion and attendance records
  • exercise or simulation results
  • content review and approval records

Common failure patterns

  • generic annual training with no CUI context
  • completion treated as proof of competence
  • contractors or privileged users omitted
  • training not updated after incidents or policy changes
Official NIST SP 800-172A content

Assessment objectives and methods

Assessment objectives (1)

  1. [Organization-defined: personnel or roles] are trained to detect counterfeit system components.

Examine

  • Supply chain risk management policy and procedures
  • supply chain risk management plan
  • system and services acquisition policy
  • anti-counterfeit plan
  • anti-counterfeit policy and procedures
  • media disposal policy
  • media protection policy
  • incident response policy
  • training materials addressing counterfeit system components
  • training records on the detection and prevention of counterfeit components entering the system
  • system security plan
  • other relevant documents or records

Interview

  • Personnel with information security responsibilities
  • personnel with supply chain risk management responsibilities
  • personnel with contract management responsibilities
  • personnel with personnel with responsibilities for anti-counterfeit policies, procedures, and training

Test

  • Processes for anti-counterfeit training
Official source-control relationships

Source NIST SP 800-53 controls

These controls are referenced by the official SP 800-172 Rev. 3 OSCAL record. Open the corresponding control pages for complete control text, enhancements, D3FEND mappings, and related learning.

Source controlSR-11(1)Open SP 800-53 control →
Source record

Authoritative sources

Bare Metal Cyber is an independent educational publisher and is not affiliated with or endorsed by NIST. The official publications, the responsible federal agency, and the governing contract or agreement determine applicability, tailoring, assessment depth, and required implementation.