CMMC readiness · NIST 800-171 alignment · DFARS support Mon–Fri · 0800–1800 ET
Controls / Access Control / 3.1.4
3.1.4
AC.L2-3.1.4 · Level 2

Separate the duties of individuals to reduce the risk of malevolent activity without collusion.

NIST SP 800-171 Rev 2 · §3.1.4

Separate the duties of individuals to reduce the risk of malevolent activity without collusion.

Assessment objectives

From NIST SP 800-171A · 3 objectives must be met to satisfy this control
3.1.4[a] the duties of individuals requiring separation to reduce the risk of malevolent activity are defined.
Examine
[SELECT FROM: Access control policy; procedures addressing divisions of responsibility and separation of duties; security plan; system configuration settings and associated documentation; list of divisions of responsibility and separation of duties; system access authorizations; system audit logs and records; other relevant documents or records].
Interview
[SELECT FROM: Personnel with responsibilities for defining divisions of responsibility and separation of duties; personnel with information security responsibilities; system or network administrators].
Test
[SELECT FROM: Mechanisms implementing separation of duties policy].
3.1.4[b] organization-defined duties of individuals requiring separation are separated.
Examine
[SELECT FROM: Access control policy; procedures addressing divisions of responsibility and separation of duties; security plan; system configuration settings and associated documentation; list of divisions of responsibility and separation of duties; system access authorizations; system audit logs and records; other relevant documents or records].
Interview
[SELECT FROM: Personnel with responsibilities for defining divisions of responsibility and separation of duties; personnel with information security responsibilities; system or network administrators].
Test
[SELECT FROM: Mechanisms implementing separation of duties policy].
3.1.4[c] separate accounts for individuals whose duties and accesses must be separated to reduce the risk of malevolent activity or collusion are established
Examine
[SELECT FROM: Access control policy; procedures addressing divisions of responsibility and separation of duties; security plan; system configuration settings and associated documentation; list of divisions of responsibility and separation of duties; system access authorizations; system audit logs and records; other relevant documents or records].
Interview
[SELECT FROM: Personnel with responsibilities for defining divisions of responsibility and separation of duties; personnel with information security responsibilities; system or network administrators].
Test
[SELECT FROM: Mechanisms implementing separation of duties policy].

What we look for in practice

The following are placeholder notes that should be refined based on practice experience.

What assessors look for in practice. Documented evidence that this control is implemented across all CUI-handling systems within scope. Specific artifacts vary, but expect requests for written procedures, system configurations, and operational records demonstrating the control is active.

Common failure patterns. Typical issues include incomplete documentation, inconsistent implementation across systems, and missing periodic review records. Refine this section as your practice accumulates direct assessment experience.

Strong evidence looks like. Formal policy referencing this control, technical configurations demonstrating enforcement, periodic review logs with sign-off, and procedures for handling exceptions.

Scoring and POA&M context. 1-point control under the DoD Assessment Methodology. Lower scoring impact, but still required for full compliance. POA&M-eligible — deferral up to 180 days is allowed under conditional certification per 32 CFR 170.21.