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AC-5—Separation of Duties

IL4 Mod
IL4 High
IL5
IL6

>Control Description

a

Identify and document ⚙organization-defined duties of individuals requiring separation; and

b

Define system access authorizations to support separation of duties.

>DoD Impact Level Requirements

Additional Requirements and Guidance

AC-5 Guidance: CSPs have the option to provide a separation of duties matrix as an attachment to the SSP.

>Discussion

Separation of duties addresses the potential for abuse of authorized privileges and helps to reduce the risk of malevolent activity without collusion. Separation of duties includes dividing mission or business functions and support functions among different individuals or roles, conducting system support functions with different individuals, and ensuring that security personnel who administer access control functions do not also administer audit functions. Because separation of duty violations can span systems and application domains, organizations consider the entirety of systems and system components when developing policy on separation of duties.

Separation of duties is enforced through the account management activities in AC-2, access control mechanisms in AC-3, and identity management activities in IA-2, IA-4, and IA-12.

>Programmatic Queries

Beta

Related Services

IAM
AWS Organizations
Service Control Policies

CLI Commands

List IAM users with admin access
aws iam list-entities-for-policy --policy-arn arn:aws:iam::aws:policy/AdministratorAccess
Check for users with multiple privileged roles
aws iam list-attached-user-policies --user-name USERNAME
List Service Control Policies
aws organizations list-policies --filter SERVICE_CONTROL_POLICY
Check permission boundaries
aws iam list-users --query 'Users[?PermissionsBoundary]'
Open AWS ConsoleDocumentation

>Related Controls

AC-2
AC-3
AC-6
AU-9
CM-5
CM-11
CP-9
IA-2
IA-4
IA-5
IA-12
MA-3
MA-5
PS-2
SA-8
SA-17

>Assessment Interview Topics

Questions assessors commonly ask

Process & Governance:

  • •What formal policies and procedures govern the implementation of AC-5 (Separation Of Duties)?
  • •Who are the designated roles responsible for implementing, maintaining, and monitoring AC-5?
  • •How frequently is the AC-5 policy reviewed and updated, and what triggers policy changes?
  • •What training or awareness programs ensure personnel understand their responsibilities related to AC-5?

Technical Implementation:

  • •Describe the specific technical mechanisms or controls used to enforce AC-5 requirements.
  • •What automated tools, systems, or technologies are deployed to implement AC-5?
  • •How is AC-5 integrated into your system architecture and overall security posture?
  • •What configuration settings, parameters, or technical specifications enforce AC-5 requirements?

Evidence & Documentation:

  • •What documentation demonstrates the complete implementation of AC-5?
  • •What audit logs, records, reports, or monitoring data validate AC-5 compliance?
  • •Can you provide evidence of periodic reviews, assessments, or testing of AC-5 effectiveness?
  • •What artifacts would you present during a FedRAMP assessment to demonstrate AC-5 compliance?

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