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NIST SP 800-172 Enhanced CUI Protection Center

03.03.03E — Dual Authorization for Audit Information and Actions

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.

2Parameters
1Source controls
1Assessment objectives
3Assessment methods

03.03 — Audit and Accountability · NIST SP 800-172 Revision 3

Active
Official NIST requirement content

Security requirement

Enforce dual authorization for [Organization-defined: SELECTED PARAMETER VALUE(S)] of [Organization-defined: audit information].

Official NIST discussion

Discussion

Dual authorization is also known as two-person control since it requires the approval of two authorized individuals to reduce the risk related to insider threat when executing audit functions. Dual authorization reduces risks related to insider threats, including adversaries who have obtained credentials. Organizations may choose different selection options for different types of audit information. To reduce the risk of collusion, organizations consider rotating dual authorization duties to other individuals. Organizations consider the risk associated with implementing dual authorization when immediate responses are necessary to ensure public and environmental safety. This requirement enhances SP 800-171 requirement 03.03.08. It is also related to requirement 03.01.01E.

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.

SELECTED PARAMETER VALUE(S)
audit informationorganization-defined audit informationaudit information for which dual authorization is to be enforced is 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
PS-PRAPenetration-Resistant Architecture
Bare Metal Cyber interpretation

Implementation perspective

Treat Dual Authorization for Audit Information and Actions 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 event selection, trustworthy logging, review, retention, and support for CUI investigations.

  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

  • logging standards and event-selection decisions
  • sample audit records and retention settings
  • time synchronization evidence
  • alert review and investigation records

Common failure patterns

  • collecting logs without defined use cases
  • critical CUI events absent from the audit trail
  • retention shorter than investigative needs
  • logs modifiable by the same administrators being monitored
Official NIST SP 800-172A content

Assessment objectives and methods

Assessment objectives (1)
  1. dual authorization is enforced for the [Organization-defined: SELECTED PARAMETER VALUE(S)] of [Organization-defined: audit information].

Examine

  • Audit and accountability policy
  • system security plan
  • access control policy and procedures
  • procedures addressing protection of audit information
  • system design documentation
  • system configuration settings and associated documentation
  • access authorizations
  • system audit records
  • other relevant documents or records

Interview

  • Personnel with audit and accountability responsibilities
  • personnel with information security responsibilities
  • system/network administrators

Test

  • Mechanisms implementing the enforcement of dual authorization
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 record

Authoritative sources