SA-9(6)_organization-controlled-cryptographic-keys

SA-9(6) Organization-controlled Cryptographic Keys

Enhancement of: SA-9

High-Level Description

Family: System and Services Acquisition (SA) Framework: NIST SP 800-53 Rev 5

Maintaining exclusive control of cryptographic keys in an external system prevents decryption of organizational data by external system staff. Organizational control of cryptographic keys can be implemented by encrypting and decrypting data inside the organization as data is sent to and received from the external system or by employing a component that permits encryption and decryption functions to be local to the external system but allows exclusive organizational access to the encryption keys.

What to Check

• Verify SA-9(6) Organization-controlled Cryptographic Keys is documented in SSP
• Confirm control is operating effectively
• Review evidence of continuous monitoring for SA-9(6)
• Verify enhancement builds upon base control SA-9

How to Test

Step 1: Review Documentation

Examine the System Security Plan (SSP) and related artifacts for SA-9(6) implementation details. Verify the organization has documented how this control is satisfied.

Step 2: Validate Implementation

# For cloud environments, use cloud-audit-mcp tools
# For on-premises, review system configurations directly

# Example: Check if account management policies exist
grep -r "account.management\|access.control" /etc/security/ 2>/dev/null

Step 3: Test Operating Effectiveness

Verify the control is actively functioning, not just documented. Check logs, configurations, and operational evidence.

Tools

Remediation Guide

Control Statement

Maintain exclusive control of cryptographic keys for encrypted material stored or transmitted through an external system.

Implementation Guidance

Maintaining exclusive control of cryptographic keys in an external system prevents decryption of organizational data by external system staff. Organizational control of cryptographic keys can be implemented by encrypting and decrypting data inside the organization as data is sent to and received from the external system or by employing a component that permits encryption and decryption functions to be local to the external system but allows exclusive organizational access to the encryption keys.

Risk Assessment

CWE Categories

References

• NIST SP 800-53 Rev 5 - SA-9(6)
• NIST SP 800-53A Rev 5 (Assessment Procedures)
• NIST SP 800-53 Rev 5 Full Catalog

Checklist

• Control documented in SSP
• Implementation evidence collected
• Operating effectiveness validated
• Continuous monitoring in place
• Related controls (SC-12, SC-13, SI-4) reviewed