AC-2 (12)—Account Management | Account Monitoring for Atypical Usage

Moderate

High

>Control Description

(a) Monitor system accounts for ⚙organization-defined atypical usage; and (b) Report atypical usage of system accounts to ⚙organization-defined personnel or roles.

>FedRAMP Baseline Requirements

Parameter Values

Additional Requirements and Guidance

AC-2 (12) (a) Requirement: Required for privileged accounts. AC-2 (12) (b) Requirement: Required for privileged accounts.

>Discussion

Atypical usage includes accessing systems at certain times of the day or from locations that are not consistent with the normal usage patterns of individuals. Monitoring for atypical usage may reveal rogue behavior by individuals or an attack in progress. Account monitoring may inadvertently create privacy risks since data collected to identify atypical usage may reveal previously unknown information about the behavior of individuals.

Organizations assess and document privacy risks from monitoring accounts for atypical usage in their privacy impact assessment and make determinations that are in alignment with their privacy program plan.

>Assessment Interview Topics

Questions assessors commonly ask

Process & Governance:

•What formal policies and procedures govern the implementation of AC-2(12) (Account Monitoring For Atypical Usage)?
•Who are the designated roles responsible for implementing, maintaining, and monitoring AC-2(12)?
•How frequently is the AC-2(12) policy reviewed and updated, and what triggers policy changes?
•What training or awareness programs ensure personnel understand their responsibilities related to AC-2(12)?

Technical Implementation:

•Describe the specific technical mechanisms or controls used to enforce AC-2(12) requirements.
•What automated tools, systems, or technologies are deployed to implement AC-2(12)?
•How is AC-2(12) integrated into your system architecture and overall security posture?
•What configuration settings, parameters, or technical specifications enforce AC-2(12) requirements?

Evidence & Documentation:

•What documentation demonstrates the complete implementation of AC-2(12)?
•What audit logs, records, reports, or monitoring data validate AC-2(12) compliance?
•Can you provide evidence of periodic reviews, assessments, or testing of AC-2(12) effectiveness?
•What artifacts would you present during a FedRAMP assessment to demonstrate AC-2(12) compliance?

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