CMMC Practice SC.L2-3.13.11 – CUI Encryption: Employ FIPS-validated cryptography when used to protect the confidentiality of CUI.
Links to Publicly Available Resources
Discussion [NIST SP 800-171 R2]
Cryptography can be employed to support many security solutions including the protection of controlled unclassified information, the provision of digital signatures, and the enforcement of information separation when authorized individuals have the necessary clearances for such information but lack the necessary formal access approvals. Cryptography can also be used to support random number generation and hash generation. Cryptographic standards include FIPS-validated cryptography and/or NSA-approved cryptography.
When CMMC requires cryptography, it is to protect the confidentiality of CUI. FIPS-validated cryptography means the cryptographic module has to have been tested and validated to meet FIPS 140-1 or-2 requirements. Simply using an approved algorithm is not sufficient –the module (software and/or hardware) used to implement the algorithm must be separately validated under FIPS 140. Accordingly, FIPS-validated cryptography is required to meet CMMC practices that protect CUI when transmitted or stored outside the protected environment of the covered contractor information system (including wireless/remote access). Encryption used for other purposes, such as within applications or devices within the protected environment of the covered contractor information system, would not need to be FIPS-validated.
This practice, SC.L2-3.13.11, complements AC.L2-3.1.19, MP.L2-3.8.6, SC.L2-3.13.8, and SC.L2-3.13.16 by specifying that FIPS-validated cryptography must be used.