February 23rd was a huge day for Microsoft and the Defense Industrial Base (DIB). In a series of posts on the public sector blog, it was announced that Microsoft would now support DFARS 202.204-7012 in Azure Commercial and GCC. This is remarkable as it eases the barrier to entry for defense contractors who need to handle controlled unclassified information (CUI) in the cloud. Previously, GCC High was the only environment that met the requirements in paragraphs c-g of DFARS 7012, requiring that environment for ANY organization that needed to meet those requirements in their defense contracts. These new announcements are sure to confuse contractors looking at what cloud environment is needed to meet their requirements under DFARS, NIST 800-171, and CMMC. When making this decision it is important to look closely at your contractual needs and the types of CUI you need to manage to determine if you can use GCC for protecting CUI.
Protecting FCI In Microsoft 365
Federal Contract Information (FCI) remans controlled by the Federal Acquisition Regulation (FAR) and CMMC levels 1 and 2. FCI can be protected across all of the cloud solutions, including commercial.
Protecting CUI in Microsoft 365
Unspecified CUI
Controlled Unclassified Information comes in over 130 types in 20 categories and depending on the types of CUI an organization handles, you may nor not may require data sovereignty. It is important to not only look at your existing contracts, but to consider where you plan for your business to grow in the future. Incorrectly assuming that you will not need data sovereignty can cost you future opportunities if contracts to specify requirements. GCC DOES NOT offer data sovereignty and cannot meet the requirements of CUI types that require it.
Specified CUI and ITAR
CUI categories like export control, defense, and nuclear will obviously require GCC High, alongside ITAR, and any CUI with NOFORN or REL TO USA limited dissemination controls. GCC High and Azure Gov are the only cloud solutions available with the sovereignty requirements to meet the contractual obligations for defending these types of CUI.
Do I need GCC High or GCC for Protecting CUI?
GCC – Acceptable for:
- Unspecified CUI without dissemination controls
- Specified CUI with no reasonable expectation of data sovereignty or export control requirements
GCC High – Required for:
- International Traffic in Arms Regulations (ITAR) information
- Specified CUI with dissemination controls including
- NOFORN
- REL TO USA
- Specified CUI types including
- Controlled Technical Information
- DOD Critical Infrastructure Security Information
- Naval Nuclear Propulsion Information
- Unclassified Controlled Nuclear Information (UCNI)
- Export Controlled
- Export Controlled Research
- Specified CUI with export control or related dissemination regulations included in the safeguarding and/or dissemination authority or (See our Guide to CUI for links to the national archives documentation.)
Still not sure if you need GCC or GCC High to meet CMMC?
Agile IT is a CMMC-AB Registered Provider Organization, and a Microsoft AOS-G partner capable of licensing, managing, migrating and securing all of the Microsoft cloud environments including Commercial, GCC, GCC High, Azure and Azure Government. If you would like our help determining what environment your CUI requires, let us know below.
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