CMMC Level 2
Control 3.8.6
Implement Cryptographic Mechanisms for CUI on Portable Storage
CMMC-RP Certified Team
24+ Years Experience
2,500+ Clients Served
Official Requirement
Implement cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport unless otherwise protected by alternative physical safeguards.
What This Means in Plain English
Any CUI stored on portable digital media (USB drives, external hard drives, laptops) must be encrypted. This ensures that if the media is lost or stolen during transport, the data remains protected.
How Petronella Implements This Control
Petronella Technology Group implements this control through:
- FIPS 140-2 validated encrypted USB drives as the only approved portable storage for CUI
- BitLocker To Go enforced on all removable media via Group Policy
- Sophos SafeGuard providing full-disk encryption for portable devices
- Encryption key management through Microsoft Entra with centralized recovery
- ComplianceArmor tracking encrypted media inventory and key custodians
Assessment Guidance
Assessors will verify that portable storage encryption is enforced, test that unencrypted media is blocked from use, check that encryption meets FIPS 140-2 requirements, and review the encrypted media inventory.
Common Implementation Gaps
- CUI transported on unencrypted USB drives
- No encryption requirement for portable media
- Non-FIPS validated encryption used for CUI
- Encryption keys not centrally managed or recoverable
- Users circumventing encryption requirements with personal devices
Cross-Framework Mapping
| Framework | Mapped Controls |
|---|---|
| NIST SP 800-53 | MP-5(4) |
| HIPAA | 164.312(a)(2)(iv) - Encryption and Decryption |
| PCI DSS | Req 3.4 - Render PAN unreadable |
Need Help Implementing 3.8.6?
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