ISC2 Governance, Risk and Compliance (CGRC) Practice Question
While implementing controls for a new cloud-based financial reporting system (RMF Step 3), the team finds the hosting provider's hypervisor cannot support the mandated FIPS 140-3 validated encryption module. To keep the project on schedule and remain compliant, what is the MOST appropriate next action?
Suspend the implementation project entirely until the provider upgrades the platform to support the required FIPS-validated module.
Select and deploy a compensating control-such as establishing a host-based IPSec tunnel that uses a FIPS-validated module-and document the rationale in the system security plan and POA&M.
Request that the Authorizing Official grant a risk acceptance so the system can operate without any encryption control until hardware is replaced.
Proceed with deployment using the hypervisor's native (non-validated) encryption and note the issue for future consideration in the next upgrade cycle.
When a required baseline control cannot be implemented as specified, NIST RMF and SP 800-53 permit the organization to identify and employ a compensating control that provides an equivalent or comparable level of protection. The alternative must be formally documented in the system security plan and justified in terms of how it meets the security requirement; any residual gaps are recorded in the POA&M. Simply accepting the risk, proceeding without validated encryption, or halting the entire project are not aligned with the RMF's guidance for control implementation at Step 3.
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ISC2 Governance, Risk and Compliance (CGRC)
Implementation of Security and Privacy Controls
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