AC-17(1): Monitoring and Control

AC-17(1): Monitoring and Control requires you to use automated technical mechanisms to monitor and control every remote access method your organization allows (for example VPN, ZTNA, remote admin tools, cloud consoles). Operationally, that means centralized logging, enforced access paths, real-time control points, and documented evidence that monitoring and blocking actions actually occur. ¹

Key takeaways:

• You need automated controls that both observe remote access activity and restrict remote access methods to approved, governed paths. ¹
• Auditors will look for proof of centralized monitoring, control enforcement, and recurring review of remote access methods, not just a policy. ²
• The fastest path is: inventory remote access methods, force them through managed gateways, log to a SIEM, alert on misuse, and retain evidence on a defined cadence. ¹

Remote access is rarely “one system.” It is a set of entry points: corporate VPN, ZTNA, bastions, jump boxes, cloud provider consoles, managed service provider tooling, endpoint remote support agents, and emergency break-glass paths. AC-17(1) exists because remote access is high-leverage for attackers and high-risk for compliance: one uncontrolled method can bypass your identity controls, segmentation, and monitoring stack.

For a Compliance Officer, CCO, or GRC lead, the practical problem is not writing a remote access policy. The practical problem is proving that remote access methods are (1) known, (2) routed through approved control points, and (3) automatically monitored with the ability to stop or constrain access when something looks wrong. The requirement text is short, but implementation touches IAM, endpoint management, network/security engineering, and SOC operations.

This page turns the ac-17(1): monitoring and control requirement into an execution checklist: who owns what, what to configure, what evidence to save, and what auditors usually challenge.

Regulatory text

Requirement (excerpt): “Employ automated mechanisms to monitor and control remote access methods.” ¹

Operator meaning: You must implement technical controls (not manual processes) that:

1. Monitor remote access methods (collect and correlate logs/telemetry), and
2. Control remote access methods (enforce allowed tools, paths, and conditions; block or constrain unapproved use). ¹

A “remote access method” is any mechanism that enables access to organizational systems from outside a managed boundary or from a non-local context. Treat “method” broadly: network-level access (VPN), app-level access (SSO to SaaS admin), management-plane access (cloud consoles), and remote administration tools.

Plain-English interpretation (what AC-17(1) demands)

AC-17(1) expects you to run remote access through managed, logged, enforceable channels. If remote access happens outside your telemetry or outside your ability to stop it, you are not meeting the intent of monitoring and control. ¹

A simple way to test your posture:

• If a user (or third party) connects remotely, can you see it centrally without asking an admin to “go check a server log”?
• Can you prevent remote access from happening through unapproved tools (for example, consumer remote desktop apps) or unapproved paths (for example, direct SSH from the internet)?
• Can you respond automatically (session termination, step-up auth, device quarantine, conditional access) when risk conditions trigger?

Who it applies to

Entity scope

• Federal information systems and contractor systems handling federal data commonly map to NIST SP 800-53 controls and inherit AC-17(1) expectations in assessments. ²

Operational scope AC-17(1) applies wherever remote connectivity exists, including:

• Workforce remote access to internal apps and admin interfaces
• Privileged remote administration (systems, network devices, databases)
• Cloud management-plane access (IaaS/PaaS consoles and APIs)
• Third-party remote access (MSPs, incident response firms, software support)
• Non-human remote paths (automation accounts, CI/CD runners reaching internal endpoints)

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

Use this as a build sheet you can hand to control owners.

1) Assign ownership and define “remote access methods” for your environment

• Name a control owner (typically Security Engineering or IAM) and supporting owners (Network, Endpoint, SOC).
• Define a remote access methods list category set: user remote, privileged remote, third-party remote, cloud admin, break-glass.
• Set an approval rule: “If it is not on the list, it is not allowed.”

Deliverable: Remote Access Methods Inventory (living register) with owner, purpose, user groups, and enforcement point.

2) Force remote access through managed control points

Your goal is to reduce remote access paths to a small set of enforceable gates.

• Centralize entry through approved solutions (for example VPN/ZWNA/bastion) and disable direct inbound management where possible.
• Require remote admin to occur through hardened jump hosts or bastions with session logging.
• For SaaS/admin consoles, enforce SSO/IdP policies and prohibit local accounts where feasible.

Control evidence you want later: architecture diagram, configuration exports/screenshots showing allowed access paths and blocked/unroutable paths.

3) Turn on automated monitoring (central logging + correlation)

Monitoring under AC-17(1) needs automation.

• Send remote access logs to a central platform (SIEM/log analytics): VPN auth, ZTNA, bastion sessions, privileged access tools, IdP sign-ins, cloud audit logs, endpoint remote tool events.
• Normalize key fields: user, device, source IP/geo, MFA status, session start/stop, target system, privilege level.
• Implement detections/alerts tied to remote access misuse (examples below).

Minimum detection set (practical):

• Remote access from unexpected countries/regions for a user
• Impossible travel or anomalous source networks
• Repeated failures followed by a success
• Privileged session started outside approved tool (or without ticket/change reference)
• New remote access tool/process observed on endpoints
• Third-party account used outside approved window or without step-up authentication

4) Implement automated control actions (not just alerting)

“Control” means the system can constrain behavior.

• Conditional access: block high-risk sign-ins, require MFA, require compliant device.
• Network controls: only allow remote admin protocols from bastion subnets; deny from internet.
• PAM controls: session recording, command controls, time-bound elevation.
• Endpoint controls: block unauthorized remote support tools; quarantine device on detection.
• Session termination: terminate VPN/ZWNA/bastion sessions when detections fire (where your stack supports it).

Document which control actions are automated, and which require SOC intervention.

5) Build an operations routine that produces assessment-ready evidence

AC-17(1) commonly fails in audits due to “it exists, but we can’t prove it runs.”

• Define review cadences for: remote access inventory accuracy, alert tuning, access method exceptions, third-party access windows.
• Require tickets/records for: adding a remote access method, granting third-party access, break-glass usage, alert triage.
• Retain evidence in a consistent location (GRC system or controlled repository).

If you use Daydream, map AC-17(1) to a control owner, an implementation procedure, and recurring evidence artifacts so assessment evidence is generated as part of operations rather than assembled at the last minute. ¹

Required evidence and artifacts to retain

Keep artifacts that prove (a) completeness of coverage, and (b) ongoing operation.

Design / configuration evidence

• Remote Access Methods Inventory (register)
• Network diagrams and remote access architecture
• IdP conditional access policies (export or screenshots)
• VPN/ZWNA configuration showing authentication requirements and logging enabled
• Bastion/jump host configuration and session logging settings
• Endpoint control policies blocking unauthorized remote tools (where applicable)

Operational evidence

• Central logging proof: SIEM data sources list; sample logs for remote access events
• Alert catalog for remote access detections and routing (SOC queue configuration)
• Sample incident/ticket showing alert triage and disposition
• Third-party remote access approvals and time-bound access records
• Break-glass usage logs and post-event review records

Governance evidence

• Remote access standard/policy that references monitoring and automated control expectations
• Exception register for any allowed non-standard remote access method, with compensating controls and approval

Common exam/audit questions and hangups

Auditors and assessors tend to push on these points:

1. “List all remote access methods.” If your list is incomplete, monitoring is likely incomplete.
2. “Show me how you block unapproved remote access.” A policy statement is not a control mechanism.
3. “Prove monitoring is automated.” They will ask where logs go and how alerts trigger. ¹
4. “Show remote privileged access oversight.” They often expect higher scrutiny for admin paths than for general user VPN.
5. “How do you govern third-party remote access?” Expect scrutiny of shared accounts, standing access, and missing session logs.

Frequent implementation mistakes (and how to avoid them)

Mistake: Logging exists, but it is siloed.
Fix: Route all remote access logs to a central system and document data sources with owners.

Mistake: You monitor VPN, but miss cloud admin access.
Fix: Treat cloud consoles and APIs as remote access methods. Turn on and ingest cloud audit logging.

Mistake: “Control” is manual (SOC gets an email).
Fix: Add automated control actions where feasible: conditional access blocks, session termination, endpoint blocklists.

Mistake: Third parties get “temporary” access that never expires.
Fix: Implement time-bound access with re-approval requirements and a dedicated third-party access process.

Mistake: No evidence trail.
Fix: Predefine evidence artifacts and a recurring export/snapshot routine. Daydream-style evidence mapping helps keep this consistent across quarters. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this guidance focuses on assessment expectations and operational risk. ²

Risk-wise, weak AC-17(1) implementation commonly correlates with:

• Reduced detection of account takeover through remote sign-in
• Uncontrolled remote admin paths that bypass standard governance
• Third-party access that becomes an unmanaged foothold

Treat AC-17(1) as a control that narrows your “unknown remote entry points” and increases incident response speed because remote activity becomes observable and constrainable.

Practical execution plan (30/60/90-day)

You asked for quick operationalization. Use this plan as an execution spine. Adjust scope based on your system boundary and assessment timeline.

First 30 days (stabilize scope + prove visibility)

• Build the Remote Access Methods Inventory and get engineering sign-off.
• Identify your control points (VPN/ZWNA, bastion, IdP, cloud audit, PAM).
• Turn on logging for each method and route to your central log platform.
• Produce an evidence bundle with: inventory, log source list, sample remote access events.

By 60 days (enforce controls + reduce pathways)

• Remove or block unapproved remote access tools and direct inbound management paths.
• Implement conditional access rules for remote sign-ins and admin consoles.
• Stand up a baseline alert set for remote access misuse and document triage steps.
• Add third-party access governance: named accounts, approvals, access windows, and logging.

By 90 days (operationalize + make it audit-repeatable)

• Add automated response actions for high-confidence detections where feasible.
• Implement recurring reviews: inventory reconciliation, exception review, and alert tuning.
• Run a tabletop or controlled test: simulate an anomalous remote login and show alert-to-response workflow.
• Store recurring evidence in a consistent location; map AC-17(1) to the owner, procedure, and artifacts in Daydream (or your GRC system) so evidence collection becomes routine. ¹

Frequently Asked Questions

Does AC-17(1) require a SIEM?

The requirement calls for “automated mechanisms” to monitor and control remote access methods. ¹ A SIEM is a common way to centralize and automate monitoring, but any platform that provides centralized ingestion, alerting, and retention can meet the intent if it is documented and operating.

What counts as a “remote access method” in practice?

Include any path used to access systems from outside the local trusted context: VPN/ZWNA, bastions, remote admin tools, cloud admin consoles, and third-party support access. If you cannot centrally monitor and constrain it, treat it as out of scope only with a documented exception and compensating controls.

How do I show “control,” not just monitoring?

Provide evidence that remote access is restricted to approved paths and conditions: conditional access policies, network ACLs, PAM session controls, and endpoint blocks for unauthorized tools. “Control” should include the ability to block or constrain remote access method use. ¹

What will an auditor ask me to demonstrate live?

Expect requests to (1) list remote access methods, (2) show centralized logs for a sample remote session, and (3) show an alert or control that triggers from remote access activity. Be ready to walk through one end-to-end example from sign-in to logging to SOC visibility.

How should we handle third-party remote access under AC-17(1)?

Treat third-party access as its own remote access method class with named accounts, approvals, time bounds, and session logging. Route third-party remote activity into the same monitoring pipeline, and enforce access through the same approved gateways.

We have emergency break-glass accounts. Do they fall under AC-17(1)?

Yes if break-glass enables remote access to the environment. Put monitoring on every break-glass use, restrict where it can be used from, and require post-use review records so you can show control and oversight.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5