The National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 deadline has come and gone, but can your organization guarantee compliance? If not, the consequences for non-compliance will alarm you.

The Defense Federal Acquisition Regulation Supplement (DFARS) made NIST 800-171 mandatory for defense contractors who have the DFARS 252.204-7012 clause in any contract. NIST 800-171 was designed specifically for the protection of Controlled Unclassified Information residing in non-federal information systems- those in use to support private enterprises.

The requirements are mapped out across fourteen security control families, many of which were adopted from NIST 800-53. Each category highlights how an assessor could examine, interview, or test each particular control at issue.


                  NIST 800-171 Security Control Families
AC Access Control MP Media Protection
AU Audit and Accountability PP Physical Protection
AT Awareness and Training PS Personnel Security
CM Configuration Management RA Risk Assessment
IA Identification & Authentication SA Security Assessment
IR Incident Response SC System & Communications Protection
MA Maintenance SI System & Information Integrity


The deadline to comply was December 31, 2017, but what if you’re not in compliance? To start, there’s currently no fine or penalty for noncompliance, nor is there any certification required to prove compliance. With that being said, there are consequences for non-compliance.

As with other provisions in a federal contract, if the contract contains an applicable regulation, the contractor has agreed that it is in compliance with all contract terms when signing the contract. If not compliant and without having submitted variance requests or plans of action to fix noncompliance, then a contractor could be in breach of contract, resulting in monetary damages or other possible adverse consequences.

Additionally, if the solicitation identified compliance with NIST 800-171 as an evaluation factor, then noncompliance, if discovered, could result in grounds for protest. Another possible consequence includes criminal fraud; if a company claims to be in compliance knowing they are not, that misrepresentation of facts is seen as a criminal act. The other possibility is contract termination due to failure to uphold contract agreements. This could cost organizations millions in lost revenue with the federal government.  

Late last month NIST released its updated final public draft, NIST SP 800-171A, Assessing Security Requirements for Controlled Unclassified Information. NIST also released two additional resources to help contractors in their compliance initiative; templates for contractor system security plans (SSPs) and plans for actions and milestones (POAMs). Under the basic security requirements of NIST 800-171, these documents are a requirement as part of a contractor’s system security assessment.


NNT’s Change Tracker™ product maps directly to 9 of the 14 security control families. To better understand what those controls are and where an organization might effectively start, see below for a detailed breakdown of how NNT solutions can help you address each requirement.


Requirement 3.1: Access Control

NIST 800-171

Key Security Controls Security Control Highlights Supplemental Guidance Precis How does NNT Change Tracker Gen 7™ satisfy the requirement?

3.1.1 Limit access to authorized users, processes acting on behalf of authorized users, or devices
3.1.2 Limit access to the types of transactions and functions that authorized users are permitted to execute

3.1.6 Use non-privileged accounts or roles when accessing nonsecurity functions
3.1.7 Prevent non-privileged users from executing privileged functions, audit the execution of such functions
3.1.8 Limit unsuccessful logon attempts
3.1.11 Terminate (automatically) a user session after a defined condition

Principle of Least Privilege is a fundamental Security Best Practice and the need to log all successful and unsuccessful attempts essential

AC-7 Enforces a limit of consecutive invalid logon attempts by a user during a defined time period and automatically locks the account/node for a defined time period when the maximum number of unsuccessful attempts is exceeded AC-12 This control addresses the termination of user-initiated logical sessions

Contemporary Operating System platforms provide support for detailed security policy settings covering Password and Account Lockout Policies but these must all be set correctly and enforced. NNT is a Certified CIS Vendor and as such, accurately delivers the industry-standard configuration hardening guidance form the CIS Benchmarks. This means you are assured of always having the latest expert configuration settings to minimize your organizations attack surface.

Requirement 3.3: Audit and Accountability

NIST 800-171

Key Security Controls Security Control Highlights Supplemental Guidance Precis How does NNT Change Tracker Gen 7™ satisfy the requirement?


3.3.1 Create, protect, and retain information system audit records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful, unauthorized, or inappropriate information system activity.

Audit events can include, for example, password changes, failed logons, or failed accesses related to information systems, administrative privilege usage, PIV credential usage, or third-party credential usage

Configuration of a comprehensive audit policy is key - get it right and you will capture a forensic audit-trail of user activities suitable for pre-empting an attack and for reconstructive forensic analysis post-breach. Get it wrong and you will miss crucial events and likely be swamped with spurious log data. NNT provide Configuration Remediation Kits to automatically set a NIST Auditor-class audit policy on all platforms, backed with Certified CIS reports to continuously validate and enforce adherence. Note: NNT Log Tracker™ can also be employed to analyze and backup logs.

Requirement 3.4: Configuration Management

NIST 800-171

Key Security Controls Security Control Highlights Supplemental Guidance Precis How does NNT Change Tracker Gen 7™ satisfy the requirement?


"3.4.1 Establish and maintain baseline configurations of organizational information systems (including hardware, software, firmware, and documentation) 
3.4.2 Establish and enforce security configuration settings for information technology products "

Baseline configurations serve as a basis for future builds, releases, and changes to information systems. Baseline configurations include information about information system components (e.g., software packages installed; current version numbers/patch information on operating systems/applications & configuration settings/parameters). Maintaining baseline configurations requires creating new baselines as organizational information systems change over time.

"As well as the pre-built NIST compliance reports, any device being monitored can have its configured state captured as a dynamically-generated Baseline Report, providing a Point-in-Time record to compare with other devices or future points in time.

For Change Control, Change Tracker™ utilizes a unique control systems known as 'Closed Loop Intelligent Change Control', literally learning which changes within your environment are normal, applying threat-based logic to the automation of change approvals."

Requirement 3.6: Incident Response

NIST 800-171

Key Security Controls Security Control Highlights Supplemental Guidance Precis How does NNT Change Tracker Gen 7™ satisfy the requirement?


3.6.1 Establish an operational incident-handling capability for organizational information systems

The organization employs automated mechanisms to support the incident handling process. The organization correlates incident information and individual incident responses to achieve an organization-wide perspective on incident awareness and response.

"Change Tracker™ cuts out the 'alert fatigue' and 'change noise' associated with traditional integrity monitoring systems like Tripwire®. By leveraging NNT FAST™ (File Approved-Safe technology) Cloud, file changes are automatically validated using an authoritative file whitelist. This radically reduces the incident response process by highlighting only genuinely suspicious activities.

In addition, because Change Tracker™ identifies Who Made the Change, investigation tasks are greatly simplified."

Requirement 3.7: Maintenance

NIST 800-171

Key Security Controls Security Control Highlights Supplemental Guidance Precis How does NNT Change Tracker Gen 7™ satisfy the requirement?


3.7.1 Perform maintenance on organizational information systems
3.7.2 Provide effective controls on the tools, techniques, mechanisms, and personnel used to conduct information system maintenance

The organization: (a) Employs automated mechanisms to schedule, conduct, and document maintenance and repairs; and (b) Produces up-to date, accurate, and complete records of all maintenance and repair actions requested, scheduled, in process, and completed.

"All changes are captured and presented clearly for review and approval.

Change Tracker™ integrates with change management systems such as ServiceNow® to automate the flow of approved planned changes, reconciling what actually changed with the expected approved-change profile"

Requirement 3.8: Media Protection

NIST 800-171

Key Security Controls Security Control Highlights Supplemental Guidance Precis How does NNT Change Tracker Gen 7™ satisfy the requirement?


3.8.1 Protect information system media containing CUI, both paper and digital
3.8.2 Limit access to CUI on information system media to authorized users
3.8.3 Sanitize or destroy information system media containing CUI before disposal/reuse

"Information system media includes digital media. Restricting access to digital media includes limiting access to design specifications stored on compact disks in the media library to the project leader and the individuals on the development team.

Cryptographic mechanisms can provide confidentiality and integrity protections depending upon the mechanisms used."

User-permissions and network segregation all rely on secure configuration settings and tightly governed change control. Change Tracker™ NIST Compliance Reports will show if user rights are incorrectly set and any configuration 'drift' will be clearly exposed to allow review and remediation. Encryption services and settings, such as MS BitLocker, can similarly be automatically reviewed and benchmarked for security.

Requirement 3.11: Risk Assessment

NIST 800-171

Key Security Controls Security Control Highlights Supplemental Guidance Precis How does NNT Change Tracker Gen 7™ satisfy the requirement?


3.11.1 Periodically assess the risk to organizational operations, organizational assets, and individuals, resulting from the operation of organizational information systems and the associated processing, storage, or transmission of CUI

Vulnerability scanning includes, scanning for patch levels, scanning for functions, ports, protocols, and services that should not be accessible to users or devices; and scanning for improperly configured or incorrectly operating information flow control mechanisms.

NNT provide regularly updated CIS-based NIST compliance reports to identify vulnerabilities on a huge range of platforms, applications and network appliances. Open ports can be tracked using both external and internal scans, and using the Baseline Report, a clear hardened-build state recorded for any device/device type. Change Tracker™ provides continuous configuration monitoring and any drift from the organizational build-standard will be clearly highlighted. Similarly, installed software and updates can be baselined, including the installed version.

Requirement 3.13: System and Communications Protection

NIST 800-171

Key Security Controls Security Control Highlights Supplemental Guidance Precis How does NNT Change Tracker Gen 7™ satisfy the requirement?


3.13.1 Monitor, control, and protect organizational communications at the external boundaries and key internal boundaries of the information systems

"Restricting interfaces within organizational information systems includes, restricting external web traffic to designated web servers within managed interfaces and prohibiting external traffic that appears to be spoofing internal addresses.

Cryptographic mechanisms implemented to protect information integrity include cryptographic hash functions."

"Managing firewall rules and settings is an essential task in order to safeguard boundary protection - Change Tracker™ will provide visibility of any changes made, with a complete step-by-step audit trail of interim changes. At each stage a full baseline of settings is also retained for review and different devices and/or points in time can be compared to the Gold Build Standard.

For end-points, session security, authenticity and disconnect settings can be expertly assessed against industry-best practice using CIS Secure Configuration Guidance, and any shortcomings will be highlighted for remediation."

Requirement 3.14: System and Information Security

NIST 800-171

Key Security Controls Security Control Highlights Supplemental Guidance Precis How does NNT Change Tracker Gen 7™ satisfy the requirement?


3.14.1 Identify, report, and correct information and information system flaws
3.14.2 Provide protection from malicious code at appropriate locations within organizational information systems
3.14.3 Monitor information system security alerts and advisories

Unauthorized changes to software, firmware, and information can occur due to errors or malicious activity. Software includes operating systems, including kernels and drivers, middleware, and applications. Firmware includes the BIOS. Information includes metadata such as security attributes associated with information. State-of-the-practice integrity-checking mechanisms e.g. cryptographic hashes and associated tools can automatically monitor the integrity of information systems and applications.

"Change Tracker™ provides instant, real-time detection of file integrity changes, using SHA-2 or higher hash validation, for all system files and configuration settings, for all devices and platforms

Working in conjunction with NNT FAST™ Cloud, as changes are detected, files can be assessed against a 'known good' whitelist of proven-safe files in order to reduce change noise and more clearly expose zero day malware that would otherwise evade traditional anti-virus technology."



 Read the article on the National Law Review


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