CMMC Level 2

Control 3.4.8

Apply Deny-by-Exception Policy for Unauthorized Software

CMMC-RP Certified Team 24+ Years Experience CMMC-AB RPO #1449

Official Requirement

Apply deny-by-exception (blacklisting) policy to prevent the use of unauthorized software or deny-all, permit-by-exception (whitelisting) policy to allow the execution of authorized software.

What This Means in Plain English

You must have a policy that either blocks known bad software (blacklisting) or only allows known good software (whitelisting). Whitelisting is stronger because it blocks everything that has not been explicitly approved.

How Petronella Implements This Control

Petronella Technology Group implements this control through:

  • Sophos XDR application control using a deny-all, permit-by-exception (whitelisting) approach
  • Microsoft AppLocker policies enforcing executable and script whitelisting on workstations
  • Group Policy Software Restriction Policies as a secondary enforcement layer
  • ComplianceArmor maintaining the approved software list with version requirements
  • Quarterly review of the approved software list to add new requirements and remove obsolete entries

Assessment Guidance

Assessors will verify that application control is enforced (whitelisting or blacklisting), test that unauthorized applications are blocked from executing, review the approved/blocked software list, and check that the policy is consistently applied across all endpoints.

Common Implementation Gaps

  • No application control or software restriction policies
  • Blacklist only approach with an incomplete blocklist
  • Application control deployed but not enforced (audit mode only)
  • Approved software list not maintained or updated
  • Application control bypassed by running scripts or portable executables

Cross-Framework Mapping

FrameworkMapped Controls
NIST SP 800-53CM-7(4), CM-7(5)
CP
By Craig Petronella
Founder, Petronella Technology Group | CMMC-RP (RPO #1449) | DFE #604180 | MIT-Certified in AI and Blockchain
Craig has helped North Carolina defense contractors prepare for CMMC assessments since 2002 and authored the CMMC 2.0 Certification Guide. Read the LinkedIn profile or verify the RPO listing at the CyberAB Marketplace.

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