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3.1.13 — Encrypt Remote Sessions

Employ cryptographic mechanisms to protect the confidentiality of remote access sessions.

All remote connections must be encrypted: VPN, TLS, SSH, HTTPS. No unencrypted remote access to anything containing CUI.

The critical detail: FIPS 140 validation. It’s not enough to use an approved algorithm (like AES-256). The actual software or hardware module performing the encryption must have a FIPS 140 validation certificate. You need to be able to show that certificate to the assessor.

Check your VPN product, your TLS implementation, your SSH server. Do they have FIPS 140 validation? If not, you have a gap.


Your assessor needs a “yes” to every row:

#QuestionWhat “yes” looks like
1Are cryptographic mechanisms identified?You know what encryption you’re using for each remote access method
2Are they implemented?They’re configured, enforced, and FIPS 140 validated

Documents they’ll review: Access control policy, remote access procedures, system security plan, system config, cryptographic mechanism documentation, FIPS validation certificates, audit logs

People they’ll talk to: Sysadmins, information security staff, system developers

Live demos they’ll ask for: “Show me the FIPS validation certificate for your VPN solution. Show me the cipher suite configuration.”


These are the actual questions. Have answers ready.

  • “What cryptographic mechanisms are used for remote access sessions?”
  • “Are TLS and IPSec using FIPS-validated encryption?”
  • “Is the module implementing the algorithm FIPS 140 validated — not just the algorithm itself?”
  • “Can you show the FIPS validation certificate?”

Right algorithm, unvalidated module. Using AES-256 but the VPN software hasn’t been FIPS 140 validated. The algorithm isn’t what gets validated — the module is.

Split tunneling. Remote users sending CUI traffic outside the encrypted tunnel (see 3.13.7).

Legacy protocols. Still allowing SSLv3 or TLS 1.0/1.1. Disable them.



RequirementWhy it matters here
3.1.12 — Eyes on Remote AccessMonitoring the sessions this encrypts
3.13.8 — Encrypt in TransitEncrypting CUI in transit generally
3.13.11 — FIPS or It Doesn’t CountThe FIPS validation requirement

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CMMC Practice ID: AC.L2-3.1.13 | SPRS Weight: 5 points | POA&M Eligible: No