CM-2(7): Configure Systems and Components for High-risk Areas

CM-2(7): configure systems and components for high-risk areas requirement sits at the intersection of configuration management and travel risk. The control is straightforward, but teams fail it for one reason: they treat it as a policy statement instead of an operational issuance program with technical baselines and traceable records. The requirement text focuses on issuing defined items with defined configurations to individuals traveling to locations you consider significantly risky ¹.

For a CCO, GRC lead, or security compliance owner, the fastest path is to turn CM-2(7) into a “travel to high-risk areas” standard that is triggered by HR/travel intake and executed by IT/security with a known-good device build. That standard should answer: which locations are “high risk,” which roles are in scope, what device and account restrictions apply, and what must happen on return.

This page gives requirement-level implementation guidance you can hand to IT and internal audit: applicability, step-by-step execution, evidence to retain, common auditor questions, and a practical 30/60/90-day plan that avoids the usual documentation-only trap.

Regulatory text

Control excerpt (verbatim): “Issue {{ insert: param, cm-02.07_odp.01 }} with {{ insert: param, cm-02.07_odp.02 }} to individuals traveling to locations that the organization deems to be of significant risk; and” ¹

What the operator must do with this text

Because the excerpt uses organization-defined parameters, you must supply the missing specifics in your internal standard and then implement them consistently:

• Define what you will issue (for example: a clean loaner laptop, a travel phone, a virtual desktop environment token, a cellular hotspot).
• Define the required configuration of those systems/components (for example: restricted admin rights, full-disk encryption, hardened browser profile, MFA-only access, blocked local data storage, limited SaaS access).
• Define which travel triggers the requirement (locations you deem “significant risk”) and how travelers are identified.
• Implement an issuance workflow so travelers actually receive the configured items before travel, and you can prove it later.

This is configuration management applied to a high-risk context: you are intentionally reducing exposure by controlling what technology enters higher-threat environments ².

Plain-English interpretation

If someone is traveling to a high-risk location, you do not let them take their everyday workstation with broad access and accumulated data. You issue a pre-approved, hardened setup that limits what can be accessed, stored, and executed, and you treat the device as potentially compromised after the trip. The compliance test is simple: can you show (1) a definition of high-risk areas, (2) a travel-device configuration baseline, and (3) records proving the right people received the right configuration for the relevant trips ¹?

Who it applies to

Entities:

• Federal information systems and programs using NIST SP 800-53 as the control baseline ².
• Contractors handling federal data where NIST SP 800-53 controls are contractually required or inherited through an authorization boundary ².

Operational context (real-world triggers):

• Employees, contractors, or privileged administrators traveling internationally or domestically to locations your organization designates as significant risk.
• Executives and deal teams with sensitive communications, M&A materials, or regulated datasets.
• Engineers and admins who can reach production systems or secrets repositories from endpoints.
• Staff attending conferences or visiting third parties in regions where device seizure, hotel Wi‑Fi interception, or targeted phishing is plausible.

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

1) Define “high-risk areas” and the trigger logic

Create a short standard owned by Security/GRC and approved by leadership that includes:

• Designation method: who decides the list (Security, Legal, Travel Risk) and how exceptions work.
• Trigger: what counts as “travel” (business trips, conferences, personal travel with corporate devices, remote work from a high-risk location).
• In-scope population: all personnel, or specific roles (privileged access, sensitive data access).

Output: “High-Risk Travel Technology Standard” mapped to CM-2(7) ¹.

2) Specify what you issue (systems/components)

Decide your issuance model and document it clearly:

• Loaner endpoint model: pre-imaged laptop/phone issued for the trip.
• Ephemeral access model: no local endpoint access to sensitive resources; require VDI or browser isolation from a managed endpoint.
• Hybrid: loaner phone plus VDI from a hardened laptop.

Be explicit about components too: tokens, MFA keys, VPN profiles, certificates, eSIMs, managed browsers. CM-2(7) is satisfied when you can show the “what” and “to whom” were controlled ¹.

3) Build and approve a hardened configuration baseline

Create a travel baseline in your endpoint management stack (MDM/UEM) and in your configuration management documentation:

• Identity: phishing-resistant MFA where possible; conditional access limited to necessary apps.
• Endpoint: no local admin, full-disk encryption, device firewall on, logging enabled.
• Data: block local storage of regulated datasets; restrict sync clients; disable removable media if feasible.
• Network: require VPN for corporate access; block risky networks if your tooling supports it.
• Apps: only allow a minimal set; restrict developer tooling and remote admin tools unless required.
• Recovery: remote wipe capability; documented procedure if a device is lost or seized.

Tie each setting to your “high-risk travel” baseline and keep version history. This is where audits often focus: a baseline that exists but is not enforced does not pass a serious assessment ².

4) Operationalize issuance and return as a controlled workflow

Implement a workflow that produces a record trail:

• Request intake: travel booking, manager request, or traveler self-report.
• Eligibility check: destination is on the “high-risk” list; traveler role is in scope.
• Issuance: IT assigns a specific asset to a named individual, for specific dates.
• Pre-travel validation: confirm baseline applied (MDM compliance report or configuration attestation).
• Return and post-travel actions: collect the device; perform sanitation steps (reimage, key rotation, token reset) according to your standard.

If you can’t reliably collect devices after travel, document and enforce an alternative containment model (for example: disable access until the endpoint is revalidated). Keep the process tight and auditable ¹.

5) Map ownership and recurring evidence (make it assessable)

Assign a control owner and establish a recurring evidence cadence:

• Owner: Endpoint Engineering or Security Operations; GRC as oversight.
• Evidence collection: automated where possible (UEM compliance exports, access policy snapshots).
• Sampling: define what an internal assessor should sample (travel cases per quarter, high-risk destinations, privileged travelers).

Daydream can help here by turning CM-2(7) into a control record with named owners, a written procedure, and a recurring evidence checklist so you are not rebuilding proof during every audit.

Required evidence and artifacts to retain

Keep artifacts that prove design and operation:

Evidence item	What it proves	Practical example
High-risk area definition + approval	You defined “significant risk” and a trigger	Approved standard or policy excerpt
Travel device baseline documentation	You defined the required configuration	Baseline settings document + version history
UEM/MDM compliance reports	The configuration was actually applied	Device compliance export showing baseline profile
Issuance/asset assignment logs	Devices/components were issued to the right individuals	Asset management ticket + serial number assignment
Access control policy snapshots	Travelers had restricted access	Conditional access policy export or screenshots
Post-travel sanitization record	You treated devices as potentially exposed	Reimage ticket, remote wipe record, key/token reset ticket
Exception records	Deviations were approved and tracked	Risk acceptance with compensating controls

The audit failure mode for CM-2(7) is “policy exists, but no issuance proof.” Treat evidence as part of the control, not a byproduct ¹.

Common exam/audit questions and hangups

Expect these questions, and pre-answer them in your procedure and evidence pack:

• How do you define “high-risk areas,” and who approves updates?
• Show me examples of travelers to high-risk locations and the devices issued to them.
• How do you ensure the hardened configuration is enforced (not optional)?
• What happens if the traveler refuses the loaner device or travels unexpectedly?
• What is your post-travel process (reimage, credential resets, log review)?
• Do contractors and third parties traveling on your behalf follow the same rule?

Auditors also ask for “complete population” reconciliation: your travel roster vs. issuance records. Build that reconciliation into the workflow early.

Frequent implementation mistakes (and how to avoid them)

1. Vague “high-risk” definition. Fix: maintain a controlled list with an owner and change log.
2. Baseline documented but not enforced. Fix: require MDM compliance to access corporate resources.
3. Issuance done informally. Fix: require a ticket/asset assignment record for every high-risk trip.
4. No post-travel sanitation. Fix: make return steps mandatory before the device goes back into inventory.
5. Exceptions become the norm. Fix: time-box exceptions and require compensating controls (VDI-only, reduced entitlements).

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific enhancement. Practically, CM-2(7) reduces the likelihood that travel exposure becomes credential theft, sensitive data loss, or unauthorized access into federal or regulated environments. In assessments, weak operation typically shows up as a configuration management gap and an access control gap, because travel endpoints are a common path around standard hardening ².

A practical 30/60/90-day execution plan

First 30 days (stand up the minimum viable program)

• Publish the “high-risk areas” definition, owner, and trigger criteria.
• Decide issuance model (loaner, VDI, hybrid) and document the “what you issue.”
• Create the first travel baseline in MDM/UEM and test it on a small set of devices.
• Add a required ticket type for high-risk travel issuance and returns.

Next 60 days (make it enforceable and auditable)

• Integrate travel intake with IT workflow (travel desk, HR, or self-service form).
• Implement conditional access rules tied to device compliance for travelers.
• Train IT service desk and security on issuance/return steps and exception handling.
• Start a monthly evidence pull: issuance list, compliance report, and completed return steps.

By 90 days (stabilize operations and reduce exceptions)

• Expand coverage to all in-scope roles and contractors handling federal data.
• Add post-travel sanitation automation (standard reimage, credential/token resets).
• Run an internal mini-audit: sample trips, trace end-to-end evidence, fix gaps.
• In Daydream, map CM-2(7) to the control owner, procedure, and recurring evidence artifacts so the program stays assessable as staff and tooling change.

Frequently Asked Questions

What counts as a “high-risk area” for CM-2(7)?

CM-2(7) leaves the definition to your organization, so you must document which locations are “significant risk” and who approves the list ¹. Auditors mainly care that the definition exists, is consistently applied, and produces a repeatable travel workflow.

Do I need dedicated “travel-only” devices, or can I harden standard laptops temporarily?

Either can work if you can prove the required configuration was applied before travel and removed or sanitized after return ¹. Dedicated loaners tend to produce cleaner evidence and fewer residual-risk arguments.

What evidence is usually missing during audits?

Issuance proof. Teams can show a baseline, but cannot show that a specific traveler received a specific configured device for a specific trip ¹.

How should we handle last-minute travel with no time to issue a loaner?

Define an exception path with required compensating controls (for example: restrict access to only essential apps, require VDI-only access, reduce entitlements) and document approval. Treat exceptions as time-limited and review them after the trip.

Are contractors and other third parties in scope?

If they access your federal system boundary or handle federal data under your program, treat them as in scope for the travel workflow or require equivalent controls contractually ². Document how you enforce that requirement.

What should happen to a device after returning from a high-risk trip?

Your standard should require a defined post-travel action, typically sanitation steps like reimaging and credential/token resets, with a ticket record. The goal is to avoid reintegrating a potentially exposed endpoint into normal operations ².

Footnotes

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

2. NIST SP 800-53 Rev. 5