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NIST SP 800-171 Rev 3 Control Guide

Who implements each NIST SP 800-171 Rev 3 requirement in a tiCrypt deployment, how tiCrypt meets it, and what the university still owns. CMMC Level 2 guide

tiCrypt53Shared18University2671 of 97 active requirements met by tiCrypt alone or shared

Every NIST SP 800-171 Rev 3 identifier. Answers for requirements carried from Rev 2 come from their CMMC practices; the 18 new in Rev 3 have proposed assignments. Select a row to read it in full.

Rev 3 IDTitleResponsibilityRequirementHow tiCrypt addresses itUniversity actionCMMC L2 practicesOriginSSP control card (800-53)Learn more
Account Management
tiCrypt
Define the types of system accounts allowed and prohibited. Create, enable, modify, disable, and remove system accounts in accordance with policy, procedures, prerequisites, and criteria. Specify authorized users of the system, group and role membership, and access authorizations (i.e., privileges) for each account. Authorize access to the system based on a valid access authorization and intended system usage. Monitor the use of system accounts. Disable system accounts when the accounts have expired, have been inactive for [organization-defined time period], … (abridged)
AC.L2-3.1.1Every user authenticates with a unique RSA-2048 key pair plus password (signed challenge-response); there is no backdoor or shared access path. A user can open a resource only if its AES key has been re-encrypted to that user's public key.IA.L2-3.5.6Inactive accounts are disabled after a configurable period, and users removed from all teams are deactivated.SC.L2-3.13.3User work runs in Secure VMs, separate from the security layer and management services; administrators never see plaintext user data.
AC.L2-3.1.1Run the account lifecycle: approve new accounts, assign teams and permission profiles, and remove users who no longer need access.IA.L2-3.5.6Set the account-inactivity period.
Carried from Rev 2
Access Enforcement
tiCrypt
Enforce approved authorizations for logical access to CUI and system resources in accordance with applicable access control policies.
AC.L2-3.1.2Permission profiles limit which actions each user can perform, with per-user overrides by administrators. Access is enforced cryptographically, so the server cannot extend access on an owner's behalf.SC.L2-3.13.3User work runs in Secure VMs, separate from the security layer and management services; administrators never see plaintext user data.
Define permission profiles and assign them to users and teams.
Carried from Rev 2
Information Flow Enforcement
tiCrypt
Enforce approved authorizations for controlling the flow of CUI within the system and between connected systems.
AC.L2-3.1.3CUI moves only through tiCrypt's encrypted, audited channels (Vault transfers in encrypted chunks, managed tunnels). SFTP into the enclave is upload-only, and exports out of a project require explicit, logged authorization.SC.L2-3.13.3User work runs in Secure VMs, separate from the security layer and management services; administrators never see plaintext user data.
Designate who may approve exports out of a project.
Carried from Rev 2
Separation of Duties
tiCrypt
Identify the duties of individuals requiring separation. Define system access authorizations to support separation of duties.
AC.L2-3.1.4Tiered administrative roles (sub-admin, admin, super admin, infrastructure root) separate duties, and every admin tier is cryptographically excluded from reading user data.SC.L2-3.13.3User work runs in Secure VMs, separate from the security layer and management services; administrators never see plaintext user data.
Decide which staff hold each admin tier and document the profile assignments.
Carried from Rev 2
Least Privilege
tiCrypt
Allow only authorized system access for users (or processes acting on behalf of users) that is necessary to accomplish assigned organizational tasks. Authorize access to [organization-defined security functions] and [organization-defined security-relevant information]. Review the privileges assigned to roles or classes of users [organization-defined frequency] to validate the need for such privileges. Reassign or remove privileges, as necessary.
AC.L2-3.1.5Profiles grant only the actions a user needs, and data access is limited to resources whose keys were shared with the user. Users removed from all teams are automatically deactivated.CM.L2-3.4.9Users can install software only where no admin privilege is needed, and those installs are discarded at shutdown; only admin-approved base-image software persists.SC.L2-3.13.3User work runs in Secure VMs, separate from the security layer and management services; administrators never see plaintext user data.
AC.L2-3.1.5Define least-privilege profiles and review privilege assignments periodically.CM.L2-3.4.9Approve software added to base images.
Carried from Rev 2
Least Privilege – Privileged Accounts
tiCrypt
Restrict privileged accounts on the system to [organization-defined personnel or roles]. Require that users (or roles) with privileged accounts use non-privileged accounts when accessing non-security functions or non-security information.
AC.L2-3.1.6Administrative functions require explicit role elevation. Administrators use separate non-privileged identities for ordinary user work.SC.L2-3.13.3User work runs in Secure VMs, separate from the security layer and management services; administrators never see plaintext user data.
Ensure admins use their non-privileged account for day-to-day research work.
Carried from Rev 2
Least Privilege – Privileged Functions
tiCrypt
Prevent non-privileged users from executing privileged functions. Log the execution of privileged functions.
AC.L2-3.1.7Privileged functions are restricted to authorized admin tiers, and every privileged operation is recorded with the user's identity in the tamper-evident audit trail.SC.L2-3.13.3User work runs in Secure VMs, separate from the security layer and management services; administrators never see plaintext user data.
None, provided by tiCrypt
Carried from Rev 2
Unsuccessful Logon Attempts
tiCrypt
Enforce a limit of [organization-defined number] consecutive invalid logon attempts by a user during a [organization-defined time period]. Automatically lock the account or node, delay the next logon prompt, notify the system administrator, or take other action when the maximum number of unsuccessful attempts is exceeded.
Accounts lock after a configurable number of failed private-key decryption attempts (default 5) and stay locked until an administrator releases them.
Set the lockout threshold (default 5).
Carried from Rev 2
System Use Notification
tiCrypt
Display a system use notification message with privacy and security notices consistent with applicable CUI rules before granting access to the system.
A configurable system-use banner with privacy and security notices is displayed before login.
Provide the banner text approved by your institution.
Carried from Rev 2
Device Lock
tiCrypt
Prevent access to the system by initiating a device lock after [organization-defined time period] of inactivity and/or requiring the user to initiate a device lock before leaving the system unattended. Retain the device lock until the user reestablishes access using established identification and authentication procedures. Conceal, via the device lock, information previously visible on the display with a publicly viewable image.
Idle sessions lock after a configurable interval (default 15 minutes), hide the display, and purge keys client-side; the user must re-authenticate.
Set the idle-lock interval (default 15 minutes).
Carried from Rev 2
Session Termination
tiCrypt
Terminate a user session automatically after [organization-defined conditions or trigger events requiring session disconnect].
Command sessions end automatically after inactivity, graphical sessions lock and require re-authentication, and keys are purged on logout.
Set session-termination thresholds.
Carried from Rev 2
Remote Access
tiCrypt
Establish usage restrictions, configuration requirements, and connection requirements for each type of allowable remote system access. Authorize each type of remote system access prior to establishing such connections. Route remote access to the system through authorized and managed access control points. Authorize the remote execution of privileged commands and remote access to security-relevant information.
AC.L2-3.1.12All remote access goes through the Connect client and the authenticated proxy; there is no direct SSH, RDP, or console access to VMs. Every session is logged.AC.L2-3.1.14The Connect client and backend proxy are the single managed entry point; only ports 22 and 443 accept inbound traffic.AC.L2-3.1.15Remote privileged commands are limited to authorized admins, authenticated through the same proxy, and logged.SC.L2-3.13.7Remote devices reach the system only through the managed, authenticated tunnel; there is no direct external network path to VMs.
Document which remote privileged commands are authorized.
Carried from Rev 2
Wireless Access
University
Establish usage restrictions, configuration requirements, and connection requirements for each type of wireless access to the system. Authorize each type of wireless access to the system prior to establishing such connections. Disable, when not intended for use, wireless networking capabilities prior to issuance and deployment. Protect wireless access to the system using authentication and encryption.
University control
Carried from Rev 2
Access Control for Mobile Devices
University
Establish usage restrictions, configuration requirements, and connection requirements for mobile devices. Authorize the connection of mobile devices to the system. Implement full-device or container-based encryption to protect the confidentiality of CUI on mobile devices.
University control
Carried from Rev 2
Use of External Systems
Shared
Prohibit the use of external systems unless the systems are specifically authorized. Establish the following security requirements to be satisfied on external systems prior to allowing use of or access to those systems by authorized individuals: [organization-defined security requirements]. Permit authorized individuals to use external systems to access the organizational system or to process, store, or transmit CUI only after verifying that the security requirements on the external systems have been satisfied … Restrict the use of organization-controlled portable storage devices by authorized individuals on external systems. (abridged)
External systems cannot connect directly. VMs deny all outbound traffic by default, and any external endpoint (e.g., a license server) requires an explicit allowlist rule approved by a SuperAdmin.
Define the policy for permitted external connections and exports.
Carried from Rev 2
Publicly Accessible Content
Shared
Train authorized individuals to ensure that publicly accessible information does not contain CUI. Review the content on publicly accessible systems for CUI and remove such information, if discovered.
The platform exposes no publicly accessible content.
Designate who may post information publicly and review public postings to confirm no CUI is released.
Carried from Rev 2
Literacy Training and Awareness
University
Provide security literacy training to system users as part of initial training for new users and [organization-defined frequency] thereafter, when required by system changes or following [organization-defined events], and on recognizing and reporting indicators of insider threat, social engineering, and social mining. Update security literacy training content [organization-defined frequency] and following [organization-defined events].
University control
Carried from Rev 2
Role-Based Training
University
Provide role-based security training to organizational personnel before authorizing access to the system or CUI, before performing assigned duties, and [organization-defined frequency] thereafter, and when required by system changes or following [organization-defined events]. Update role-based training content [organization-defined frequency] and following [organization-defined events].
University control
Carried from Rev 2
Event Logging
Shared
Specify the following event types selected for logging within the system: [organization-defined event types]. Review and update the event types selected for logging [organization-defined frequency].
AU.L2-3.3.1Audit logging is always on and cannot be disabled or bypassed. 150+ event types are recorded (authentication, files, sharing, VMs, keys, admin actions), and records are kept for the life of the deployment by default on your own audit server.AU.L2-3.3.3tiCrypt supplies the audit data, query tools, and real-time alerting; the logged event set is defined by the product.
AU.L2-3.3.1Confirm the retention period meets your records policy (default: retained indefinitely) and back up the audit server.AU.L2-3.3.3Set a review cadence, assign reviewers, investigate alerts, and periodically confirm the logged events still meet your needs.
Carried from Rev 2
Audit Record Content
tiCrypt
Include the following content in audit records: what type of event occurred, when the event occurred, where the event occurred, source of the event, outcome of the event, and identity of the individuals, subjects, objects, or entities associated with the event. Provide additional information for audit records as needed.
Every action is tied to an authenticated user, session, and source IP, with millisecond UTC timestamps and a hash-chain position.
None, provided by tiCrypt
Carried from Rev 2
Audit Record Generation
tiCrypt
Generate audit records for the selected event types and audit record content specified in 03.03.01 and 03.03.02. Retain audit records for a time period consistent with the records retention policy.
Audit logging is always on and cannot be disabled or bypassed. 150+ event types are recorded (authentication, files, sharing, VMs, keys, admin actions), and records are kept for the life of the deployment by default on your own audit server.
Confirm the retention period meets your records policy (default: retained indefinitely) and back up the audit server.
Carried from Rev 2
Response to Audit Logging Process Failures
tiCrypt
Alert organizational personnel or roles within [organization-defined time period] in the event of an audit logging process failure. Take the following additional actions: [organization-defined additional actions].
The logging path is fail-closed: capacity alerts fire and key issuance halts at 90% log-storage use. Real-time alerts at five severity levels flag failures such as hash-chain breaks.
Route alerts to the right staff (email, Splunk, or another SIEM).
Carried from Rev 2
Audit Record Review, Analysis, and Reporting
tiCrypt
Review and analyze system audit records [organization-defined frequency] for indications and the potential impact of inappropriate or unusual activity. Report findings to organizational personnel or roles. Analyze and correlate audit records across different repositories to gain organization-wide situational awareness.
The separate audit system (ClickHouse) correlates events across users, resources, event types, and time ranges, and can forward alerts to Splunk, email, or other SIEMs.
Use the audit tools in your review process; set review cadence and alert routing.
Carried from Rev 2
Audit Record Reduction and Report Generation
tiCrypt
Implement an audit record reduction and report generation capability that supports audit record review, analysis, reporting requirements, and after-the-fact investigations of incidents. Preserve the original content and time ordering of audit records.
A query builder, predefined compliance reports, direct SQL access, and Excel export support reduction and reporting without altering original records.
None, provided by tiCrypt
Carried from Rev 2
Time Stamps
tiCrypt
Use internal system clocks to generate time stamps for audit records. Record time stamps for audit records that meet [organization-defined granularity of time measurement] and that use Coordinated Universal Time (UTC), have a fixed local time offset from UTC, or include the local time offset as part of the time stamp.
All components record UTC timestamps with millisecond precision.
Synchronize host clocks to an authoritative NTP source.
Carried from Rev 2
Protection of Audit Information
tiCrypt
Protect audit information and audit logging tools from unauthorized access, modification, and deletion. Authorize access to management of audit logging functionality to only a subset of privileged users or roles.
AU.L2-3.3.8Audit records are SHA-256 hash-chained, so any change, insertion, or deletion is detectable. The backend pushes logs one way to a separate audit server with no return path.AU.L2-3.3.9Only a limited group of authorized infrastructure administrators can access audit logs, and records cannot be modified or deleted through the application.
Limit audit-server access to designated administrators.
Carried from Rev 2
Baseline Configuration
University
Develop and maintain under configuration control, a current baseline configuration of the system. Review and update the baseline configuration of the system [organization-defined frequency] and when system components are installed or modified.
University control
Carried from Rev 2
Configuration Settings
tiCrypt
Establish, document, and implement the following configuration settings for the system that reflect the most restrictive mode consistent with operational requirements: [organization-defined configuration settings]. Identify, document, and approve any deviations from established configuration settings.
CM.L2-3.4.2Core security settings are architectural rather than optional. Automated configuration management reconciles components against the baseline, and system settings have full change tracking.SC.L2-3.13.7Remote devices reach the system only through the managed, authenticated tunnel; there is no direct external network path to VMs.
Set organization-defined values and approve any deviations.
Carried from Rev 2
Configuration Change Control
tiCrypt
Define the types of changes to the system that are configuration-controlled. Review proposed configuration-controlled changes to the system, and approve or disapprove such changes with explicit consideration for security impacts. Implement and document approved configuration-controlled changes to the system. Monitor and review activities associated with configuration-controlled changes to the system.
Settings history records the previous value, new value, timestamp, and administrator. Platform releases are staged before production.
Run your change-control process (review and approve changes).
Carried from Rev 2
Impact Analyses
tiCrypt
Analyze changes to the system to determine potential security impacts prior to change implementation. Verify that the security requirements for the system continue to be satisfied after the system changes have been implemented.
Changes to profiles, quotas, and project access go through audited Management Console controls, and Tera Insights evaluates platform changes before release.
Perform and record security impact analyses for changes in your environment.
Carried from Rev 2
Access Restrictions for Change
tiCrypt
Define, document, approve, and enforce physical and logical access restrictions associated with changes to the system.
Configuration changes are restricted to designated admins and audited. Software and VM images are signed, and boot images reset on every boot to prevent tampering.
Designate who may make changes and run change approval.
Carried from Rev 2
Least Functionality
tiCrypt
Configure the system to provide only mission-essential capabilities. Prohibit or restrict use of the following functions, ports, protocols, connections, and services: [organization-defined functions, ports, protocols, connections, and services]. Review the system [organization-defined frequency] to identify unnecessary or nonsecure functions, ports, protocols, connections, and services. Disable or remove functions, ports, protocols, connections, and services that are unnecessary or nonsecure.
CM.L2-3.4.6Services are deny-by-default with only ports 22 and 443 open. VMs boot from immutable images containing only pre-approved software, with no persistent state.CM.L2-3.4.7Images include only the OS and VM installer; extra software must be added by admins in a new image. Software can be blocked per project, and stack execution is disallowed.SC.L2-3.13.7Remote devices reach the system only through the managed, authenticated tunnel; there is no direct external network path to VMs.
Define any per-project software blocklists.
Carried from Rev 2
Authorized Software – Allow by Exception
tiCrypt
Identify software programs authorized to execute on the system. Implement a deny-all, allow-by-exception policy for the execution of authorized software programs on the system. Review and update the list of authorized software programs [organization-defined frequency].
CM.L2-3.4.7Images include only the OS and VM installer; extra software must be added by admins in a new image. Software can be blocked per project, and stack execution is disallowed.CM.L2-3.4.8Per-project allowlists and blocklists are supported. The VM Controller governs execution, and users cannot modify boot images.CM.L2-3.4.9Users can install software only where no admin privilege is needed, and those installs are discarded at shutdown; only admin-approved base-image software persists.
CM.L2-3.4.7Define any per-project software blocklists.CM.L2-3.4.8Define per-project allow/deny lists.CM.L2-3.4.9Approve software added to base images.
Carried from Rev 2
System Component Inventory
University
Develop and document an inventory of system components. Review and update the system component inventory [organization-defined frequency]. Update the system component inventory as part of installations, removals, and system updates.
University control
Carried from Rev 2
Information Location
tiCrypt
Identify and document the location of CUI and the system components on which the information is processed and stored. Document changes to the system or system component location where CUI is processed and stored.
Each project's data is segregated into its own encrypted VMs, drives, and Vault storage, and tiCrypt is deployed on-premises, so CUI stays on university-controlled infrastructure.
Document CUI storage locations (storage pools, hosts) in your SSP.
None, new in Rev 3
New in Rev 3
System and Component Configuration for High-Risk Areas
University
Issue systems or system components with the following configurations to individuals traveling to high-risk locations: [organization-defined system configurations]. Apply the following security requirements to the systems or components when the individuals return from travel: [organization-defined security requirements].
University control
None, new in Rev 3
New in Rev 3
User Identification and Authentication
tiCrypt
Uniquely identify and authenticate system users, and associate that unique identification with processes acting on behalf of those users. Re-authenticate users when [organization-defined circumstances or situations requiring re-authentication].
IA.L2-3.5.1Each user has a unique RSA-2048 identity; processes and VMs are identified by UUIDs and digital signatures.IA.L2-3.5.2Users authenticate by signing a server challenge with their private key, no password is sent. Endpoints and VMs are authenticated by key material before any connection is established.
None, provided by tiCrypt
Carried from Rev 2
Device Identification and Authentication
tiCrypt
Uniquely identify and authenticate [organization-defined devices or types of devices] before establishing a system connection.
Users authenticate by signing a server challenge with their private key, no password is sent. Endpoints and VMs are authenticated by key material before any connection is established.
None, provided by tiCrypt
Carried from Rev 2
Multi-Factor Authentication
tiCrypt
Implement multi-factor authentication for access to privileged and non-privileged accounts.
MFA through Duo or Shibboleth is layered on top of the private-key signature. The MFA assertion is signed and verified independently, and its identity must match the key holder or the session is denied.
Enable MFA and set its scope (off until enabled). Provide MFA for host-level admin access outside tiCrypt.
Carried from Rev 2
Replay-Resistant Authentication
tiCrypt
Implement replay-resistant authentication mechanisms for access to privileged and non-privileged accounts.
Each login challenge uses a random single-use nonce, so a captured response cannot be replayed.
None, provided by tiCrypt
Carried from Rev 2
Identifier Management
tiCrypt
Receive authorization from organizational personnel or roles to assign an individual, group, role, service, or device identifier. Select and assign an identifier that identifies an individual, group, role, service, or device. Prevent the reuse of identifiers for [organization-defined time period]. Manage individual identifiers by uniquely identifying each individual as [organization-defined characteristic identifying individual status].
User identifiers and UUIDs are unique and never reused, even after deletion.
None, provided by tiCrypt
Carried from Rev 2
Password Management
tiCrypt
Maintain a list of commonly-used, expected, or compromised passwords, and update the list [organization-defined frequency] and when organizational passwords are suspected to have been compromised. Verify that passwords are not found on that list when users create or update passwords. Transmit passwords only over cryptographically protected channels. Store passwords in a cryptographically protected form. Select a new password upon first use after account recovery. Enforce the following composition and complexity rules for passwords: [organization-defined rules]. (abridged)
IA.L2-3.5.7Configurable password-strength rules apply at registration and on change, and passwords are screened against weak or compromised lists. The password only protects the user's local private key.IA.L2-3.5.10Passwords are never sent to or stored on the server. The private key is AES-256 encrypted client-side, and with MFA enabled the IV and salt are held on the server behind MFA, so neither side can recover the key alone.
Define password composition rules.
Carried from Rev 2
Authentication Feedback
tiCrypt
Obscure feedback of authentication information during the authentication process.
Password entry is obscured, and login errors are generic, they do not reveal whether a username exists or which credential failed.
None, provided by tiCrypt
Carried from Rev 2
Authenticator Management
tiCrypt
Verify the identity of the individual, group, role, service, or device receiving the authenticator as part of the initial authenticator distribution. Establish initial authenticator content for any authenticators issued by the organization. Establish and implement administrative procedures for initial authenticator distribution; for lost, compromised, or damaged authenticators; and for revoking authenticators. Change default authenticators at first use. Change or refresh authenticators [organization-defined frequency] or when defined events occur. Protect authenticator content from unauthorized disclosure and modification. (abridged)
The authenticator is the user's client-encrypted private key, created at one-time registration and validated against a site-key chain of trust. Lockout limits guessing, password changes invalidate older key files, and escrow supports recovery of lost keys.
Verify each person's identity before approving registration, and define procedures for lost or compromised key files.
None, new in Rev 3
New in Rev 3
Incident Handling
University
Implement an incident-handling capability that is consistent with the incident response plan and includes preparation, detection and analysis, containment, eradication, and recovery.
University control
Carried from Rev 2
Incident Monitoring, Reporting, and Response Assistance
Shared
Track and document system security incidents. Report suspected incidents to the organizational incident response capability within [organization-defined time period]. Report incident information to [organization-defined authorities]. Provide an incident response support resource that offers advice and assistance to system users on handling and reporting incidents.
Audit logs and real-time, severity-tiered alerts provide detection data and forensic evidence for investigations.
Track, document, and report incidents to designated officials and authorities, including DoD's 72-hour reporting window.
Carried from Rev 2
Incident Response Testing
University
Test the effectiveness of the incident response capability [organization-defined frequency].
University control
Carried from Rev 2
Incident Response Training
University
Provide incident response training to system users consistent with assigned roles and responsibilities within [organization-defined time period] of assuming an incident response role or responsibility or acquiring system access, when required by system changes, and [organization-defined frequency] thereafter. Review and update incident response training content [organization-defined frequency] and following [organization-defined events].
University control
None, new in Rev 3
New in Rev 3
Incident Response Plan
University
Develop an incident response plan that provides a roadmap for implementing the incident response capability, describes its structure and organization, defines reportable incidents, addresses the sharing of incident information, and designates responsibilities. Distribute copies of the plan to designated incident response personnel; update the plan to address system and organizational changes or problems encountered during implementation, execution, or testing; and protect the plan from unauthorized disclosure. (abridged)
University control
None, new in Rev 3
New in Rev 3
Maintenance Tools
Shared
Approve, control, and monitor the use of system maintenance tools. Check media with diagnostic and test programs for malicious code before it is used in the system. Prevent the removal of system maintenance equipment containing CUI by verifying that there is no CUI on the equipment, sanitizing or destroying the equipment, or retaining the equipment within the facility.
The management interface is the only maintenance tool for the platform, and all maintenance runs over authenticated, encrypted, audited channels.
Approve and inspect any maintenance tools used on host infrastructure.
Carried from Rev 2
Nonlocal Maintenance
tiCrypt
Approve and monitor nonlocal maintenance and diagnostic activities. Implement multi-factor authentication and replay resistance in the establishment of nonlocal maintenance and diagnostic sessions. Terminate session and network connections when nonlocal maintenance is completed.
Remote maintenance uses the same RSA challenge-response authentication, with MFA where required; sessions are encrypted and closed when finished.
Pre-approve and supervise vendor remote access; enable MFA.
Carried from Rev 2
Maintenance Personnel
University
Establish a process for maintenance personnel authorization. Maintain a list of authorized maintenance organizations or personnel. Verify that non-escorted personnel who perform maintenance on the system possess the required access authorizations. Designate organizational personnel with required access authorizations and technical competence to supervise the maintenance activities of personnel who do not possess the required access authorizations.
The management interface is the only maintenance tool for the platform, and all maintenance runs over authenticated, encrypted, audited channels.
Approve and inspect any maintenance tools used on host infrastructure.
Carried from Rev 2
Media Storage
Shared
Physically control and securely store system media that contain CUI.
All data is AES-256 encrypted before it reaches any media, and decryption keys are never stored on the infrastructure, so media holds only ciphertext.
Physically control and securely store the media (disks, backups) that hold the ciphertext.
Carried from Rev 2
Media Access
Shared
Restrict access to CUI on system media to authorized personnel or roles.
Reading CUI requires tiCrypt authentication and the owner's key, regardless of who can touch the media.
Control physical access to the media.
Carried from Rev 2
Media Sanitization
Shared
Sanitize system media that contain CUI prior to disposal, release out of organizational control, or release for reuse.
Cryptographic erasure: destroying a resource's per-file or per-drive key makes the remaining ciphertext unrecoverable.
Sanitize physical media and the unencrypted metadata database per NIST SP 800-88 before disposal or reuse, and make sure escrowed and backup key copies are destroyed.
Carried from Rev 2
Media Marking
Shared
Mark system media that contain CUI to indicate distribution limitations, handling caveats, and applicable CUI markings.
tiCrypt's interfaces support configurable CUI markings and labels.
Apply physical markings, distribution limits, and handling caveats to media.
Carried from Rev 2
Media Transport
Shared
Protect and control system media that contain CUI during transport outside of controlled areas. Maintain accountability of system media that contain CUI during transport outside of controlled areas. Document activities associated with the transport of system media that contain CUI.
All transfers are logged, and data in transit is encrypted end to end.
Keep custody, accountability, and handling records for physical media transported outside controlled areas.
Carried from Rev 2
Media Use
tiCrypt
Restrict or prohibit the use of [organization-defined types of system media]. Prohibit the use of removable system media without an identifiable owner.
MP.L2-3.8.7VMs have no USB passthrough by default. Removable-media access is limited to privileged users and requires admin hardware configuration and approval.MP.L2-3.8.8Every drive, file, and VM in tiCrypt has an explicit owner, and ownership transfers require an authenticated action.
MP.L2-3.8.7Set the removable-media approval policy.MP.L2-3.8.8Enforce the owner rule for portable devices outside the platform.
Carried from Rev 2
System Backup – Cryptographic Protection
tiCrypt
Protect the confidentiality of backup information. Implement cryptographic mechanisms to prevent the unauthorized disclosure of CUI at backup storage locations.
Backups contain only ciphertext because no decryption keys are stored on the infrastructure.
None, provided by tiCrypt
Carried from Rev 2
Personnel Screening
University
Screen individuals prior to authorizing access to the system. Rescreen individuals in accordance with [organization-defined conditions requiring rescreening].
University control
Carried from Rev 2
Personnel Termination and Transfer
University
When individual employment is terminated: disable system access within [organization-defined time period], terminate or revoke authenticators and credentials associated with the individual, and retrieve security-related system property. When individuals are reassigned or transferred: review and confirm the ongoing operational need for current logical and physical access authorizations, and modify access authorization to correspond with any changes in operational need.
University control
Carried from Rev 2
Physical Access Authorizations
University
Develop, approve, and maintain a list of individuals with authorized access to the facility where the system resides. Issue authorization credentials for facility access. Review the facility access list [organization-defined frequency]. Remove individuals from the facility access list when access is no longer required.
University control
Carried from Rev 2
Monitoring Physical Access
University
Monitor physical access to the facility where the system resides to detect and respond to physical security incidents. Review physical access logs [organization-defined frequency] and upon occurrence of [organization-defined events or potential indications of events].
University control
Carried from Rev 2
Alternate Work Site
University
Determine alternate work sites allowed for use by employees. Employ the following security requirements at alternate work sites: [organization-defined security requirements].
University control
Carried from Rev 2
Physical Access Control
University
Enforce physical access authorizations at entry and exit points to the facility where the system resides by verifying individual physical access authorizations before granting access and controlling ingress and egress with physical access control systems, devices, or guards. Maintain physical access audit logs for entry or exit points. Escort visitors, and control visitor activity. Secure keys, combinations, and other physical access devices. Control physical access to output devices to prevent unauthorized individuals from obtaining access to CUI.
University control
Carried from Rev 2
Access Control for Transmission
University
Control physical access to system distribution and transmission lines within organizational facilities.
University control
None, new in Rev 3
New in Rev 3
Risk Assessment
University
Assess the risk (including supply chain risk) of unauthorized disclosure resulting from the processing, storage, or transmission of CUI. Update risk assessments [organization-defined frequency].
University control
Carried from Rev 2
Vulnerability Monitoring and Scanning
Shared
Monitor and scan the system for vulnerabilities [organization-defined frequency] and when new vulnerabilities affecting the system are identified. Remediate system vulnerabilities within [organization-defined response times]. Update system vulnerabilities to be scanned [organization-defined frequency] and when new vulnerabilities are identified and reported.
RA.L2-3.11.2Tera Insights scans tiCrypt's own components, issues advisories, and coordinates authenticated access for your scans.RA.L2-3.11.3Tera Insights identifies, patches, and releases fixes for platform components on a regular cadence, with critical fixes released out of band.
RA.L2-3.11.2Scan host operating systems, network infrastructure, and non-tiCrypt software in the CUI boundary, and remediate findings.RA.L2-3.11.3Schedule and apply platform updates; remediate host-level findings.
Carried from Rev 2
Risk Response
Shared
Respond to findings from security assessments, monitoring, and audits.
Tera Insights remediates platform vulnerabilities on a regular cadence, with critical fixes out of band, and the audit system supplies monitoring evidence.
Respond to findings from security assessments, monitoring, and audits across the full CUI boundary.
None, new in Rev 3
New in Rev 3
Security Assessment
Shared
Assess the security requirements for the system and its environment of operation [organization-defined frequency] to determine if the requirements have been satisfied.
Tera Insights supplies SSP templates, assessment evidence packages, and direct support during C3PAO assessments.
Coordinate the C3PAO engagement, provide evidence for university controls, and make sure the assessment covers the full CUI boundary.
Carried from Rev 2
Plan of Action and Milestones
Shared
Develop a plan of action and milestones for the system to document the planned remediation actions to correct weaknesses or deficiencies noted during security assessments and to reduce or eliminate known system vulnerabilities. Update the existing plan of action and milestones based on the findings from security assessments, audits or reviews, and continuous monitoring activities.
Tera Insights helps draft POA&M items for platform controls, provides templated workflows, and handles platform-side remediation.
Own and track the POA&M and report milestones to the C3PAO.
Carried from Rev 2
Continuous Monitoring
tiCrypt
Develop and implement a system-level continuous monitoring strategy that includes ongoing monitoring and security assessments.
CM.L2-3.4.9Users can install software only where no admin privilege is needed, and those installs are discarded at shutdown; only admin-approved base-image software persists.CA.L2-3.12.3The audit system continuously records user actions and security events and raises real-time alerts, providing telemetry for ongoing monitoring.
CM.L2-3.4.9Approve software added to base images.CA.L2-3.12.3Run your continuous-monitoring program using tiCrypt telemetry, including server health (CPU, memory, disk), which tiCrypt does not monitor.
Carried from Rev 2
Information Exchange
Shared
Approve and manage the exchange of CUI between the system and other systems using interconnection security agreements, information exchange security agreements, memoranda of understanding or agreement, service-level agreements, user agreements, non-disclosure agreements, or other types of agreements. Document interface characteristics, security requirements, and responsibilities for each system as part of the exchange agreements. Review and update the exchange agreements [organization-defined frequency].
CUI enters only through logged ingress paths (Vault upload, Inboxes, SFTP), SFTP is upload-only, and data leaves only through an explicit, logged export approval, so exchange terms can be enforced technically.
Establish and manage exchange agreements (ISAs, DUAs, MOUs) and document interface responsibilities.
None, new in Rev 3
New in Rev 3
Boundary Protection
tiCrypt
Monitor and control communications at external managed interfaces to the system and key internal managed interfaces within the system. Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks. Connect to external systems only through managed interfaces that consist of boundary protection devices arranged in accordance with an organizational security architecture.
SC.L2-3.13.1The backend is the single enforcement point. Only ports 22 and 443 accept inbound traffic, VMs run on isolated networks with deny-all outbound, and storage only ever receives ciphertext.SC.L2-3.13.5The public-facing frontend is separated from CUI processing in isolated VM networks, and ingress services sit in a DMZ-like zone with only a one-way path to the backend.
None, provided by tiCrypt
Carried from Rev 2
Information in Shared System Resources
tiCrypt
Prevent unauthorized and unintended information transfer via shared system resources.
VMs reset to immutable images on every boot, and each service has its own database. SFTP into VMs is write-only, and transfers go through the audited Vault.
None, provided by tiCrypt
Carried from Rev 2
Network Communications – Deny by Default – Allow by Exception
tiCrypt
Deny network communications traffic by default, and allow network communications traffic by exception.
Inbound and outbound traffic is denied by default. Every outbound exception requires a firewall/allowlist rule created with SuperAdmin privilege.
Approve any outbound exceptions (e.g., license servers).
Carried from Rev 2
Transmission and Storage Confidentiality
tiCrypt
Implement cryptographic mechanisms to prevent the unauthorized disclosure of CUI during transmission and while in storage.
AC.L2-3.1.13Remote sessions are double-encrypted: TLS plus a per-session Diffie-Hellman layer between client and VM, using FIPS-validated AES-256, RSA-2048, and SHA-256.MP.L2-3.8.6Data is ciphertext from the moment it is created (AES-256), so media, replicas, and backups are protected in transport without the owner's key; network transport adds TLS plus Diffie-Hellman.SC.L2-3.13.8Data in transit is double-encrypted (TLS 1.2+ plus Diffie-Hellman session keys) with FIPS-validated algorithms, and SHA-256 verifies integrity.SC.L2-3.13.16CUI is AES-256 encrypted at rest: Vault files in 8 MB chunks with per-file keys, and VM drives with LUKS or BitLocker. Metadata such as file names is not encrypted at rest.
Protect the metadata database as part of the CUI boundary.
Carried from Rev 2
Network Disconnect
tiCrypt
Terminate the network connection associated with a communications session at the end of the session or after [organization-defined time period] of inactivity.
Tunnels close at session end and idle sessions disconnect; client keys are purged on termination.
Set the idle-disconnect interval.
Carried from Rev 2
Cryptographic Key Establishment and Management
tiCrypt
Establish and manage cryptographic keys in the system in accordance with the following key management requirements: [organization-defined requirements for key generation, distribution, storage, access, and destruction].
Keys are generated client-side (AES-256 per file and drive, RSA-2048 per user) and never stored unwrapped on the server. Key recovery uses escrow split across at least three independent holders.
Define escrow groups (minimum three) and their membership.
Carried from Rev 2
Cryptographic Protection
tiCrypt
Implement the following types of cryptography when used to protect the confidentiality of CUI: [organization-defined types of cryptography].
All cryptography runs through the FIPS-validated OpenSSL 3.1.2 FIPS provider (CMVP #4985) in approved mode, no custom cryptography. FIPS mode is also enabled in secure VMs.
None, provided by tiCrypt
Carried from Rev 2
Collaborative Computing Devices and Applications
tiCrypt
Prohibit the remote activation of collaborative computing devices and applications with the following exceptions: [organization-defined exceptions where remote activation is to be allowed]. Provide an explicit indication of use to users physically present at the devices.
Not applicable by design: collaborative computing devices (cameras, microphones) are not supported in the environment, so remote activation cannot occur.
None, provided by tiCrypt
Carried from Rev 2
Mobile Code
tiCrypt
Define acceptable mobile code and mobile code technologies. Authorize, monitor, and control the use of mobile code.
The frontend bundles all its dependencies and references no external code; it runs in the controlled Connect app, and software is signed. VMs have no browser-based code paths to external networks.
None, provided by tiCrypt
Carried from Rev 2
Session Authenticity
tiCrypt
Protect the authenticity of communications sessions.
Sessions are authenticated by RSA challenge-response over mutually authenticated channels (TLS plus Diffie-Hellman), preventing hijacking and replay.
None, provided by tiCrypt
Carried from Rev 2
Flaw Remediation
tiCrypt
Identify, report, and correct system flaws. Install security-relevant software and firmware updates within [organization-defined time period] of the release of the updates.
Tera Insights maintains the software lifecycle, identifies flaws, and releases signed updates; VM images are rebuilt with current patches.
Apply updates on your schedule.
Carried from Rev 2
Malicious Code Protection
tiCrypt
Implement malicious code protection mechanisms at system entry and exit points to detect and eradicate malicious code. Update malicious code protection mechanisms as new releases are available in accordance with configuration management policies and procedures. Configure malicious code protection mechanisms to perform scans of the system [organization-defined frequency] and real-time scans of files from external sources as the files are downloaded, opened, or executed, and to block, quarantine, or take other action on malicious code. (abridged)
SI.L2-3.14.2Anti-virus scanning is integrated on data import and access. Immutable VM images reset on boot (removing persistent malware), and deny-all networking blocks command-and-control traffic.SI.L2-3.14.4The controller server delivers the latest VM images and VM Controller at every boot, with current patches.SI.L2-3.14.5Files are scanned on import and access, boot resets restore a known-good state each session, and chunk-level encryption blocks file injection.
SI.L2-3.14.2Supply the anti-virus product and schedule scans.SI.L2-3.14.4Keep anti-virus signatures current.SI.L2-3.14.5Schedule periodic scans.
Carried from Rev 2
Security Alerts, Advisories, and Directives
tiCrypt
Receive system security alerts, advisories, and directives from external organizations on an ongoing basis. Generate and disseminate internal system security alerts, advisories, and directives, as necessary.
Real-time alerts at five severity levels cover authentication failures, access attempts, and anomalies, and Tera Insights relays relevant security advisories.
Act on advisories and alerts.
Carried from Rev 2
System Monitoring
tiCrypt
Monitor the system to detect attacks and indicators of potential attacks and unauthorized connections. Identify unauthorized use of the system. Monitor inbound and outbound communications traffic to detect unusual or unauthorized activities or conditions.
SI.L2-3.14.6All VM traffic passes through the logged backend proxy; unauthorized attempts are blocked and recorded. The audit system provides alerting (e.g., impossible-travel logins, lockouts) and forensic queries.SI.L2-3.14.7The audit system detects and alerts on unauthorized access, failed authentication, and privilege escalation.
SI.L2-3.14.6Run the monitoring program and route alerts to your SOC/SIEM.SI.L2-3.14.7Investigate alerts as part of your monitoring program.
Carried from Rev 2
Information Management and Retention
Shared
Manage and retain CUI within the system and CUI output from the system in accordance with applicable laws, Executive Orders, directives, regulations, policies, standards, guidelines, and operational requirements.
Closing a project destroys its encryption keys, making the data permanently unrecoverable, and the event is logged as the destruction record. Audit records are retained for the life of the deployment by default.
Define retention and destruction requirements from laws, contracts, and DUAs, and trigger project closure when they are met.
None, new in Rev 3
New in Rev 3
Policy and Procedures
University
Develop, document, and disseminate to organizational personnel or roles the policies and procedures needed to satisfy the security requirements for the protection of CUI. Review and update policies and procedures [organization-defined frequency].
University control
None, new in Rev 3
New in Rev 3
System Security Plan
University
Develop a system security plan that defines the constituent system components; identifies the information types processed, stored, and transmitted; describes specific threats of concern; describes the operational environment and any dependencies on or connections to other systems; provides an overview of the security requirements; describes the safeguards in place or planned; and identifies individuals that fulfill system roles and responsibilities. Review and update the plan [organization-defined frequency] and protect it from unauthorized disclosure. (abridged)
University control
New in Rev 3
Rules of Behavior
University
Establish rules that describe the responsibilities and expected behavior for system usage and protecting CUI. Provide rules to individuals who require access to the system. Receive a documented acknowledgement from individuals indicating that they have read, understand, and agree to abide by the rules of behavior before authorizing access to CUI and the system. Review and update the rules of behavior [organization-defined frequency].
University control
None, new in Rev 3
New in Rev 3
Security Engineering Principles
tiCrypt
Apply the following systems security engineering principles to the development or modification of the system and system components: [organization-defined systems security engineering principles].
The platform is engineered with layered security, end-to-end encryption, least privilege, and microservice isolation (zero-knowledge design).
None, provided by tiCrypt
None, new in Rev 3
New in Rev 3
Unsupported System Components
Shared
Replace system components when support for the components is no longer available from the developer, vendor, or manufacturer. Provide options for risk mitigation or alternative sources for continued support for unsupported components that cannot be replaced.
Tera Insights maintains supported releases and patches for all tiCrypt software components.
Replace unsupported host operating systems, hypervisors, and hardware in the CUI boundary.
None, new in Rev 3
New in Rev 3
External System Services
University
Require the providers of external system services used for the processing, storage, or transmission of CUI to comply with the following security requirements: [organization-defined security requirements]. Define and document user roles and responsibilities with regard to external system services, including shared responsibilities with external service providers. Implement processes, methods, and techniques to monitor security requirement compliance by external service providers on an ongoing basis.
University control
None, new in Rev 3
New in Rev 3
Supply Chain Risk Management Plan
University
Develop a plan for managing supply chain risks associated with the research and development, design, manufacturing, acquisition, delivery, integration, operations, maintenance, and disposal of the system, system components, or system services. Review and update the supply chain risk management plan [organization-defined frequency]. Protect the supply chain risk management plan from unauthorized disclosure.
University control
None, new in Rev 3
New in Rev 3
Acquisition Strategies, Tools, and Methods
University
Develop and implement acquisition strategies, contract tools, and procurement methods to identify, protect against, and mitigate supply chain risks.
University control
None, new in Rev 3
New in Rev 3
Supply Chain Requirements and Processes
Shared
Establish a process for identifying and addressing weaknesses or deficiencies in the supply chain elements and processes. Enforce the following security requirements to protect against supply chain risks to the system, system components, or system services and to limit the harm or consequences from supply chain-related events: [organization-defined security requirements].
tiCrypt software and certificates are signed and verified before deployment, development is under configuration management, and builds are security-tested in staging before release.
Establish your supply chain risk process and the security requirements you place on suppliers.
None, new in Rev 3
New in Rev 3

This guide summarizes Tera Insights' published shared-responsibility model for tiCrypt. Each institution's System Security Plan defines its own boundary and implementation, and the final determination of compliance rests with the institution and its C3PAO. Release baseline (ticrypt.com/releases, October 21, 2026): Frontend 2.18.1 · Backend 3.15.0 · Host Controller 1.3.2 · Audit 1.10.1 · SFTP 1.5.1