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Requirements / System and Communications Protection (SC)

SC.L2-3.13.1

Boundary Protection

Official Source Material

Monitor, control, and protect organizational communications (i.e., information transmitted or received by organizational information systems) at the external boundaries and key internal boundaries of the information systems.

Determine if:

  1. [a] the external system boundary is defined;
  2. [b] key internal system boundaries are defined;
  3. [c] communications are monitored at the external system boundary;
  4. [d] communications are monitored at key internal boundaries;
  5. [e] communications are controlled at the external system boundary;
  6. [f] communications are controlled at key internal boundaries;
  7. [g] communications are protected at the external system boundary; and
  8. [h] communications are protected at key internal boundaries.

Source: CMMC Assessment Guide - Level 2, Version 2.13, September 2024

Practitioner Guidance

How to meet it

Define the boundaries before you defend them.

Objectives [a] and [b] ask for definitions, not equipment. Draw the external boundary where your system meets the internet and anything else you do not control. Then name the components that sit on it: the firewall, the VPN (virtual private network) gateway, and the cloud services where your traffic lands. Then decide whether any key internal boundaries exist. A network diagram that names these boundaries answers [a] and [b] and gives the other six objectives something to attach to.

A small, deliberate boundary makes the rest of this family cheaper.

Every boundary you define must then be monitored, controlled, and protected. An enclave isolates the systems touching CUI (Controlled Unclassified Information) behind one firewall and one set of rules. That gives you two boundaries to defend instead of a sprawling network's dozen. The segmentation that carves the enclave out of the rest of your network is itself a key internal boundary under [b], so monitor and control it like the perimeter.

Having no key internal boundaries is an acceptable answer when it is true.

A small flat network with nothing separating one part of the system from another has no key internal boundaries to name. Write that determination down under [b] and the internal halves of [d], [f], and [h] follow it. What fails is silence: an assessor who finds a segmented development network or a separate WiFi you never declared will ask why your definition missed it.

Cover three verbs at each boundary: monitor, control, protect.

Objectives [c] through [h] pair monitoring, control, and protection with each boundary class. Monitoring means the traffic is logged, reviewable, and alerting on the suspicious [c, d]. Control means connections are denied by default and allowed by exception [e, f], which SC.L2-3.13.6 sharpens into its own requirement. Protection means encryption or tunneling where the traffic warrants it [g, h]. Walk each named boundary through all three verbs. Record the mechanism in your system security plan, the document that describes how your system meets each requirement.

A cloud-first company still has boundaries to declare.

When your CUI lives in a cloud tenant and your staff work from anywhere, the external boundary changes shape. It becomes the host-based firewall on each managed endpoint plus the cloud service's own managed perimeter. Declare both, show the endpoint firewall denying unsolicited inbound traffic, and point at the provider's boundary responsibilities in its shared responsibility documentation.

What falls short

  • File and folder permissions offered as boundary protection. Access control lists govern who reads data, not the boundary-crossing communications [c] through [h] cover, so you still need a firewall, even if it is the one on each endpoint.
  • A firewall whose logs nobody can produce. Rules alone show control under [e], and monitoring under [c] needs the logging turned on and reviewable.
  • Badge readers and locked doors. Physical protections belong to the Physical Protection family and say nothing about network traffic.

Edge cases

  • Guest WiFi separated from the CUI environment so it cannot carry CUI or FCI (Federal Contract Information) sits outside the boundary, so document the separation that makes that true. WiFi inside the CUI environment is a key internal boundary, because wireless presents a different attack surface than the wired segment it joins.
  • Remote workers do not force a VPN. A VPN is one way to control the out-of-office connection, and an endpoint firewall plus TLS to your cloud services is another. Whichever you choose, account for the remote connection explicitly in your boundary definition.

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