NIST 800-171 Controls · Access Control
AC.2.003 — Control CUI Flow per Authorizations
Control the flow of CUI in accordance with approved authorizations.
What AC.2.003 means in plain English
Know exactly where your government contract information (called CUI — Controlled Unclassified Information) lives and travels. Don't let it drift to personal email, personal cloud storage, or unauthorized thumb drives. If you receive a drawing marked "CUI" from a prime contractor, it should only live in your approved, secure folder — not in a Gmail inbox or on a personal USB stick.
The assessment question
“Do you have controls in place to prevent CUI from flowing to unauthorized locations — such as blocking CUI from being emailed to personal accounts, uploaded to unapproved cloud services like personal Google Drive, or copied to unauthorized USB drives?”
How to implement AC.2.003
- Designate a specific, protected folder or SharePoint site as the only approved location for CUI. Label it clearly (e.g., "CUI - Controlled Documents") and restrict access as described in AC.1.002.
- In Microsoft 365 GCC, enable Microsoft Purview Information Protection (formerly AIP) sensitivity labels to tag CUI documents and prevent forwarding or downloading to unmanaged devices.
- Configure Exchange Online mail flow rules in Microsoft 365 GCC admin center to block outbound emails with CUI labels going to personal email domains (gmail.com, yahoo.com, etc.).
- Use Windows Group Policy to disable AutoRun on USB drives and consider blocking unknown USB storage devices via Device Control settings in Microsoft Defender for Business.
- Train employees to recognize CUI markings and document the training so you have a record. A 30-minute lunch-and-learn with a sign-in sheet satisfies this evidence requirement.
Evidence your assessor will ask for
- Data flow diagram or written description showing where CUI enters, is stored, processed, and exits your environment
- Screenshot of SharePoint/OneDrive CUI folder with restricted permissions
- Mail flow rule configurations in Microsoft 365 admin center
- Sensitivity label policy configuration screenshots
- USB device control policy or written procedure
- Employee training records on CUI handling
Does AI prompt monitoring help with this control? Yes — directly.
AC.2.003 is one of the requirements a local AI prompt firewall concretely evidences. When employees send prompts to ChatGPT, Copilot, or Claude, that traffic crosses your external boundary — HoundShield inspects it on your own infrastructure (self-hosted Docker, Mode B), blocks CUI patterns before transmission, and writes every allowed/blocked event to a SHA-256 hash-chained log attributable to the user. Architecture diagram, active pattern set, and a log sample are the evidence an assessor tests this against for the AI data path.
Full mapping: which 800-171 controls AI prompt monitoring evidences →
More Access Control controls
Limit System Access to Authorized Users
AC.1.002Limit System Access to Authorized Transaction Types
AC.2.004Separate Duties to Reduce Risk
AC.2.005Employ Least Privilege
AC.2.006Use Non-Privileged Accounts for Non-Security Functions
AC.2.007Prevent Non-Privileged Users from Executing Privileged Functions
Score yourself against all 110 controls
The free ShieldReady assessment walks every NIST 800-171 requirement, computes your SPRS score, and shows exactly which gaps cost the most points.