Security requirement
Verify that individuals accessing a system that processes, stores, or transmits CUI meet [Organization-defined: organization-defined citizenship requirements].
Discussion
Organizations may determine that individuals who need access to CUI associated with a high value asset or critical program require U.S. citizenship status. This requirement enhances SP 800-171 requirement 03.09.01.
Tailoring decisions required
Resolve these values through the governing organization’s approved tailoring and risk-management process before declaring the requirement implemented.
Protection strategies supported
These classifications are carried from the official SP 800-172 OSCAL record and help explain the enhanced requirement’s defensive purpose.
Implementation perspective
Treat Citizenship Requirements 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 personnel risk, screening, agreements, transfer, termination, and timely access consequences.
- 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.
- Resolve every organization-defined parameter through an approved governance and tailoring process.
- Map each clause of the requirement to an accountable owner, implementation mechanism, and evidence source.
- Verify that inherited and shared implementations are supported by current provider evidence and responsibility boundaries.
- 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
- screening and suitability records
- access agreements
- transfer and termination checklists
- role-change and offboarding evidence
Common failure patterns
- access persisting after transfer or separation
- contractor lifecycle outside normal controls
- sensitive roles not screened based on risk
- termination actions that cannot be shown to occur promptly
Assessment objectives and methods
Assessment objectives (1)
individuals accessing a system processing, storing, or transmitting CUI meet [Organization-defined: organization-defined citizenship requirements].
Examine
- Personnel security policy
- access control policy, procedures addressing personnel screening
- records of screened personnel
- screening criteria
- records of access authorizations
- system security plan
- other relevant documents or records
Interview
- Personnel with personnel security responsibilities
- personnel with information security responsibilities
Test
- Processes for ensuring valid access authorizations for accessing CUI and systems requiring citizenship
- processes for additional personnel screening
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.
Authoritative sources
- NIST SP 800-172 Revision 3 official publication ↗
- NIST SP 800-172A Revision 3 official publication ↗
- NIST OSCAL Content release used for this import ↗
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.