Crucial Exams

ISC2 Governance, Risk and Compliance (CGRC) Practice Question

During RMF Step 5 you are advising an Authorizing Official on whether to accept residual risk for an agency's new payment portal that will store cardholder primary account numbers. The system owner proposes leaving the data unencrypted because the assessed likelihood of compromise is low and encryption will delay deployment. Which explanation best justifies rejecting this risk-acceptance request?

  • Storing unencrypted PAN violates PCI DSS, which requires cardholder data to be unreadable at rest, so the risk cannot be accepted regardless of cost or schedule pressures.

  • FIPS 199 still needs to be applied to categorize the system; without that step no residual risk decision can be made, so acceptance is premature rather than impermissible.

  • OMB Circular A-123 requires financial risks to be transferred through insurance or contractual clauses, so acceptance is not an available option.

  • NIST SP 800-37 expressly prohibits accepting any residual confidentiality risk that is rated moderate or higher, mandating additional mitigation.

ISC2 Governance, Risk and Compliance (CGRC)
System Compliance
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