CMMC Level 2 Practice 3.14.7: Identify unauthorized use of organizational systems

CMMC Level 2 Practice 3.14.7 requires you to detect and identify unauthorized use of your organizational systems by implementing logging, monitoring, alerting, and response workflows that reliably surface suspicious activity. To operationalize it fast, define “unauthorized use,” turn on the right audit logs across your CUI environment, route events to a monitored queue, and retain evidence that detection and follow-up occur. ¹

Key takeaways:

• Define “unauthorized use” in concrete, testable terms tied to your access model and CUI boundary. ¹
• Centralize and monitor security-relevant logs, then prove you review and act on alerts. ¹
• Keep assessor-ready evidence: log sources, alert rules, review records, and incident tickets showing follow-through. ²

The target keyword here is cmmc level 2 practice 3.14.7: identify unauthorized use of organizational systems requirement, but the operational goal is simple: you need a dependable way to spot activity that should not be happening in your environment, especially inside the boundary where you process, store, or transmit CUI.

Assessors will look for two things. First, technical capability: are the right events being recorded and monitored, or are you blind where it matters? Second, operational proof: can you show that someone actually reviews what’s detected and that suspicious activity becomes a documented investigation or incident response action.

This practice is mapped to NIST SP 800-171 Rev. 2, which means you should treat it as a security operations control, not a policy-only requirement. If your logging exists only on paper, or alerts exist but nobody owns them, this practice usually fails in assessment. ^{1 2}

Regulatory text

Regulatory excerpt (as provided): “CMMC Level 2 practice mapped to NIST SP 800-171 Rev. 2 requirement 3.14.7 (Identify unauthorized use of organizational systems).” ^{1 2 3}

Operator interpretation: You must implement detective controls (logging + monitoring + review + escalation) that allow you to identify unauthorized use of organizational systems. “Identify” means more than “logs exist.” It means you can detect, triage, and document that you recognized activity as unauthorized and took appropriate follow-up action. ¹

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Plain-English interpretation (what this really requires)

Unauthorized use is any use that violates your approved access, authentication, or authorization rules. In practice, this includes:

• A legitimate account used at an unusual time or from an unusual location for that user.
• A disabled account successfully authenticating.
• Privilege escalation that was not approved.
• Attempts to access CUI repositories without permission.
• A third party remote session outside agreed methods (for example, a personal remote tool).

Your job: define which events indicate “unauthorized use,” ensure those events are logged across the CUI boundary, monitor them, and prove that alerts are reviewed and investigated. ¹

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Who it applies to (entity and operational context)

Who: Defense contractors and subcontractors that handle CUI and are pursuing or maintaining CMMC Level 2. ^{3 2}

Where: Systems in the assessed environment (your CUI boundary), including:

• Identity providers and directory services (accounts, groups, roles)
• Endpoints and servers that access or store CUI
• Cloud services in scope for CUI processing
• Network/security infrastructure that can observe or block activity (firewalls, VPN, EDR)
• Administrative tooling (remote management, privileged access paths)

Operational owners: Security operations, IT infrastructure, identity/access management, and incident response. Compliance/GRC owns the mapping, evidence plan, and assessment readiness. ²

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What you actually need to do (step-by-step)

1) Define “unauthorized use” for your environment

Create a short, assessor-readable definition and a list of trigger conditions. Make it testable.

Minimum set to define:

• Unauthorized authentication: impossible travel, brute force, logins from banned geographies (if applicable), logins to deprovisioned accounts.
• Unauthorized authorization: access denied events to CUI repositories, repeated permission failures, privilege escalation.
• Unauthorized administrative actions: creation of new admin accounts, changes to MFA, changes to logging settings, disabling endpoint protection.
• Unauthorized remote access: connections outside approved VPN/zero trust method; non-approved remote tools.

Artifact: “Unauthorized Use Detection Criteria” (1–2 pages) mapped to in-scope systems. ¹

2) Inventory log sources inside the CUI boundary

Build a log source register. If it isn’t listed, it will be missed during evidence collection.

Typical in-scope log sources:

• Identity: Entra ID/Azure AD, AD, Okta, Google Workspace
• Endpoints: EDR agent telemetry, Windows Event Logs, Linux auth logs
• Email and collaboration (if in scope): audit logs
• Network: VPN concentrator, firewall, DNS logs (if available)
• Cloud control plane: CloudTrail/Activity Logs equivalents

Artifacts: Log source register; data flow diagram showing log routing. ¹

3) Turn on audit logging and set retention aligned to investigation needs

Enable security auditing where you can answer: who did what, when, from where, to which asset, and what was the result.

Implementation notes:

• Ensure admin actions are logged (policy changes, account changes, logging configuration changes).
• Protect logs from tampering (restricted access, separate admin roles, write-once or immutable storage where feasible).
• Record time sync and normalization (NTP) so events correlate.

Artifacts: System configuration evidence (screenshots/exported configs), logging standards, retention configuration proof. ¹

4) Centralize and monitor logs (SIEM or equivalent)

You need a monitored pipeline that produces alerts someone owns.

Practical patterns that assess well:

• Send key logs to a SIEM (or managed detection service) with documented parsing.
• If no SIEM, use a centralized logging platform plus scheduled review and documented escalation. “We can search logs” without defined review typically fails in practice.

Artifacts: Architecture diagram, list of ingested sources, sample events showing ingestion, alert list/runbook. ¹

5) Create alert rules tied to your “unauthorized use” criteria

Build a small set of high-signal alerts first. Avoid hundreds of noisy detections you cannot triage.

Starter alert set (high yield):

• Multiple failed logins followed by success on privileged accounts
• New admin account created or privileged role assigned
• MFA disabled or authentication policy weakened
• Endpoint protection disabled
• Access to CUI share/repository from unmanaged device (if you can detect it)
• Log clearing events and audit policy changes

Artifacts: Alert catalog with severity, owner, and response steps. ¹

6) Establish an operational review and escalation workflow

Assessors expect that alerts move through a process with ownership.

Minimum workflow:

1. Alert generated and lands in a monitored queue.
2. Analyst reviews, classifies (benign, suspicious, confirmed incident).
3. Ticket created for suspicious/confirmed cases with timestamps.
4. Evidence collected (logs, affected assets, user identity context).
5. Containment/eradication steps tracked where needed.
6. Closure with rationale and lessons learned if applicable.

Artifacts: SOC runbook, ticket templates, sample closed tickets, on-call or monitoring schedule, escalation matrix. ²

7) Prove the control works (tabletop + detection test)

Run a controlled test and retain evidence.

• Trigger a failed login burst to a test account.
• Create and remove a test admin role assignment.
• Attempt access to a restricted CUI folder and capture denied events.

Artifacts: Test plan, test results, screenshots/log extracts, resulting ticket. ¹

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Required evidence and artifacts to retain (assessor-ready)

Keep evidence in a single “3.14.7 Evidence Pack” folder with timestamps and system scope labels.

Evidence item	What it proves	Good format
Unauthorized Use Detection Criteria	Clear definition and triggers	1–2 page document mapped to sources
Log source register + CUI boundary mapping	Coverage of in-scope systems	Spreadsheet + boundary diagram
Logging configurations	Audit enabled on key systems	Exports/screenshots/config baselines
Centralized log ingestion proof	Logs flow to monitoring point	SIEM ingestion status + sample raw events
Alert catalog + runbooks	You detect and know what to do	Alert list, severities, playbooks
Review records	Humans review alerts	Tickets, weekly review notes, queue snapshots
Investigation/incident tickets	Follow-through and escalation	Closed cases with artifacts attached
Access controls for logs	Logs are protected	RBAC screenshots, role assignments

^{1 2}

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Common exam/audit questions and hangups

Questions you should be ready for:

• “Show me how you detect unauthorized use in the CUI boundary.” Expect to walk through log sources → SIEM → alert → ticket. ²
• “Which events do you treat as unauthorized use?” If you answer with generalities, the assessor may press for specific triggers. ¹
• “Who reviews alerts, and how do you prove it?” Have named roles and records. ¹
• “How do you prevent log tampering?” Show restricted access and administrative separation. ¹

Typical hangups:

• Logging exists, but isn’t monitored.
• Monitoring exists, but is out of scope systems only (misses CUI boundary).
• Alerts exist, but no triage records exist.

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Frequent implementation mistakes (and how to avoid them)

1. Mistake: treating 3.14.7 as a policy statement.
   Fix: show operational outputs (alerts, tickets, investigations) tied to defined unauthorized-use scenarios. ¹

2. Mistake: too many alerts, no signal.
   Fix: start with a small alert set; tune and expand after you can consistently triage. ¹

3. Mistake: log gaps on identity and admin actions.
   Fix: prioritize identity provider logs, privileged changes, MFA changes, and logging configuration changes. ¹

4. Mistake: evidence scattered across teams.
   Fix: create a recurring evidence capture routine. Daydream is a practical place to map 3.14.7 to control steps and schedule recurring evidence pulls so you have assessment-ready artifacts without a scramble. ²

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Enforcement context and risk implications (practical)

CMMC is implemented through DoD program requirements and rulemaking, and CMMC Level 2 aligns to NIST SP 800-171 controls for protecting CUI. Your risk is failing an assessment because you cannot show detection and response evidence, even if you have security tools deployed. That failure can delay eligibility for contracts that require Level 2 certification. ^{3 2}

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A practical 30/60/90-day execution plan

First 30 days (stabilize scope and visibility)

• Confirm the CUI boundary and in-scope systems list. ²
• Draft “Unauthorized Use Detection Criteria” and get sign-off from security and IT. ¹
• Build the log source register; identify missing telemetry (identity, endpoints, VPN, admin actions). ¹
• Turn on or validate audit logging for the highest-risk sources (identity + privileged actions). ¹

Days 31–60 (operational monitoring and response)

• Centralize logs and confirm ingestion health with sample events. ¹
• Implement the starter alert set tied directly to your criteria. ¹
• Write a short triage runbook and define escalation to incident response. ²
• Start generating tickets for alerts; hold weekly review with documented notes. ¹

Days 61–90 (prove it works, then harden)

• Run detection tests and retain evidence (screenshots, logs, tickets). ¹
• Tune alerts to reduce false positives and document changes. ¹
• Lock down log access (RBAC) and verify admin separation for logging platforms. ¹
• Package evidence for assessment: one folder, clear labels, cross-reference to 3.14.7. Daydream can keep this mapping current and automate recurring evidence collection reminders across owners. ²

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Frequently Asked Questions

What counts as “unauthorized use” if the user had valid credentials?

If the activity violates your authorization rules or expected access conditions (for example, privilege escalation without approval or access to restricted CUI locations), treat it as unauthorized use and investigate. Document your triggers in your detection criteria. ¹

Do we need a SIEM to meet CMMC Level 2 Practice 3.14.7?

The requirement is to identify unauthorized use; a SIEM is a common way to centralize and alert, but not the only way. If you use another logging platform, you still need monitored alerts, documented review, and retained investigation evidence. ¹

How do we prove “identification” to an assessor?

Show the chain: log source enabled → event ingested → alert fired → ticket created → triage notes and closure. A written procedure without records usually will not be persuasive. ²

Are managed service providers allowed to perform monitoring for 3.14.7?

Yes, a third party can monitor, but you still need clear scope, roles, escalation paths, and evidence you can produce during assessment. Keep contracts/SOWs and sample tickets as artifacts. ²

What if we have multiple enclaves and only one handles CUI?

Apply 3.14.7 to the assessed environment where CUI is processed, stored, or transmitted, and document boundary controls to show why other enclaves are out of scope. Your log source register should align to that boundary. ²

How often should alerts be reviewed?

Set a review cadence that matches your risk and alert volume, then document it and retain records showing it happens. Assessors care more about consistency and evidence than a specific schedule. ¹

Footnotes

1. NIST SP 800-171 Rev. 2

2. DoD CMMC Program Guidance

3. 32 CFR Part 170