SA-9(8): Processing and Storage Location — U.S. Jurisdiction

SA-9(8): Processing and Storage Location — U.S. Jurisdiction requires you to restrict where covered information is processed and stored so it stays within facilities located inside the United States’ legal jurisdictional boundary. To operationalize it, you must (1) define which data/systems are in scope, (2) contractually require U.S.-only locations, and (3) technically enforce and continuously verify location controls across all third parties and cloud services.

Key takeaways:

• Scope first: you can’t enforce “U.S.-only” until you know which data flows and systems are covered.
• Contracts are necessary but not sufficient; you need technical controls and monitoring that prevent non-U.S. processing/storage.
• Evidence wins audits: keep configuration proof, data-flow maps, and third-party attestations tied to the control owner and cadence.

The sa-9(8): processing and storage location — u.s. jurisdiction requirement is a location-restriction control enhancement under NIST SP 800-53 Rev. 5 that becomes operationally hard the moment you use cloud services, distributed backups, support teams across borders, or global third parties. “U.S.-only” is not a slogan. It is a set of enforceable decisions about regions, replication, failover, logging destinations, managed support access, and even where systems perform processing (not just where the database sits).

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat SA-9(8) as a combined governance + architecture control: you set a clear scoping rule, push it into procurement and third-party due diligence, and then require your system owners to prove the cloud and vendor configurations match the rule. You should expect audit attention on two points: (1) whether “processing” includes transient operations like analytics, ticket attachments, and log aggregation; and (2) whether your contracts and technical settings actually prevent non-U.S. storage/processing, including disaster recovery and subprocessor chains.

This page gives requirement-level steps, evidence lists, common hangups, and a practical execution plan you can hand to control owners.

Regulatory text

Requirement (excerpt): “Restrict the geographic location of information processing and data storage to facilities located within in the legal jurisdictional boundary of the United States.” ¹

What the operator must do:
You must implement enforceable restrictions so that in-scope information is processed and stored only in facilities within the U.S. legal jurisdictional boundary. That means you need both:

1. Administrative controls (policy, contracting, third-party requirements), and
2. Technical controls (cloud region restrictions, replication controls, routing/egress controls, monitoring) that make non-U.S. processing/storage difficult or impossible.

Reference: NIST SP 800-53 Rev. 5 ²

Plain-English interpretation

SA-9(8) is a “data residency + jurisdiction” requirement: keep covered data and the compute that touches it inside the U.S. boundary. It applies to the full lifecycle:

• Primary storage (databases, object storage, file shares)
• Backups and snapshots
• Replication and failover targets
• Logs/telemetry that may contain the data
• Any service components that process the data (ETL jobs, AI/ML services, search indexing, scanning tools, DLP, ticketing system attachments)

A useful working rule for system owners: if a service can read the data, transform it, index it, or store it, then its region, subprocessor chain, and storage locations must also be U.S.-restricted.

Who it applies to

Entities

• Federal information systems implementing NIST SP 800-53 controls ².
• Contractor systems handling federal data, including cloud-hosted or third-party-operated environments where the contractor is responsible for meeting control requirements ².

Operational contexts where SA-9(8) shows up

• Cloud deployments with multi-region architectures or “global” services.
• Managed services where the provider performs operations (support, monitoring, SRE) from outside the U.S.
• Third parties and subprocessors that replicate data across borders for resiliency or analytics.
• Centralized logging/SIEM platforms that ingest production data and may be hosted elsewhere.

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

1) Set scope and decision rules (make it unambiguous)

1. Define “covered information” for your environment (for example: specific federal data types, contract-scoped data, or system boundary data). Tie this to your system security plan boundary if you have one.
2. Define “processing” vs. “storage” for your internal interpretation: include backups, logs, and derived datasets when they contain covered information.
3. Define the allowed geography as “facilities located within the U.S. legal jurisdictional boundary” per SA-9(8) ¹.
4. Document explicit exceptions (if any) with an approval path, compensating controls, and expiration. If you cannot permit exceptions, say that clearly.

Deliverable: a one-page “SA-9(8) scoping and interpretation memo” owned by the control owner.

2) Map data flows and storage locations (you can’t control what you can’t see)

1. Build a data-flow diagram per in-scope system: ingestion, processing steps, storage systems, backups, logs, analytics, and egress.
2. Create a location inventory for each component:
   • Cloud account/subscription/project
   • Region(s) and availability zones used
   • Backup vault locations
   • DR/failover region
   • Log sinks (SIEM, observability, APM)
   • Ticketing/collaboration tools where engineers may paste data
3. Identify hidden cross-border paths: CDN, email notifications, support uploads, crash dumps, and vendor “improvement” telemetry.

Deliverable: data map + location register that you can hand an auditor.

3) Put location requirements into third-party intake and contracting

For each third party that processes/stores covered information:

1. Add a contract clause requiring U.S.-only processing and storage, including backups, DR, and all subprocessors.
2. Require notice and approval before changing regions, adding subprocessors, or changing data center strategy.
3. Require the third party to provide evidence (see artifacts section) and to support audits/assessments.

Practical tip: procurement language must cover “processing” explicitly; many templates only address “storage.”

4) Technically enforce U.S.-only in your cloud and SaaS configurations

Implement controls aligned to your stack. Examples:

• Cloud region allowlisting: enforce policies that prevent creation of storage/compute resources outside approved U.S. regions.
• Replication and backup controls: confirm snapshots, backup vaults, and cross-region replication targets are U.S.-based.
• Data egress controls: restrict outbound network paths that could push data to non-U.S. endpoints; review managed connectors and integrations.
• Logging and analytics controls: ensure log aggregation, search indexing, and data warehouses are U.S.-restricted if logs include covered information.
• Access tooling controls: restrict where support tools store attachments, session recordings, and diagnostic bundles.

Deliverable: configuration baselines + screenshots/exports showing region restrictions.

5) Verify continuously (operate the control, don’t “set and forget”)

1. Schedule recurring checks that enumerate resource locations and flag drift.
2. Tie checks to change management: new services, new regions, new integrations trigger review.
3. Add SA-9(8) to third-party periodic review: confirm subprocessor lists and data center commitments have not changed.

If you use Daydream to manage third-party risk, treat SA-9(8) as a control requirement with a named owner, a repeatable test procedure, and a recurring evidence checklist. That removes the usual scramble when assessors ask for proof that restrictions are actively enforced.

Required evidence and artifacts to retain

Keep artifacts that prove three things: (1) scope, (2) contractual obligation, (3) technical enforcement and ongoing verification.

Governance and scope

• SA-9(8) control statement and internal interpretation memo ¹
• System boundary definition and in-scope data categories
• Data-flow diagrams and location register

Third-party management

• Contract language / DPA addendum with U.S.-only processing and storage commitments
• Subprocessor list and location commitments (and your approval record for changes)
• Third-party due diligence results tied to SA-9(8)

Technical enforcement

• Cloud policy exports (region restrictions) and change tickets approving them
• Configuration evidence for storage, backups, replication, DR regions
• Monitoring outputs: periodic location reports, alerts, and remediation records

Operational proof

• Exception register (even if empty) and approvals
• Change management records for new services/regions
• Latest periodic review sign-off by control owner

Common exam/audit questions and hangups

• “Show me where this data is processed, not just stored.” Auditors often ask about analytics jobs, indexing, or managed services that process data outside the primary database.
• “What about backups and DR?” Expect scrutiny on snapshot locations, cross-region replication, and vendor-managed resilience features.
• “How do you know your third party didn’t change locations?” You need a periodic verification mechanism plus contractual notice/approval rights.
• “Define ‘within U.S. jurisdictional boundary.’” Your policy should mirror the control language and then translate it into allowed cloud regions and vendor facility commitments ¹.
• “Prove enforcement.” A policy and a contract are not enforcement. Provide configuration evidence and drift detection.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating region selection as proof.
   Fix: add preventive policies (deny non-U.S. resource creation) and detective monitoring that alerts on drift.

2. Mistake: Ignoring derived data.
   Fix: classify logs, telemetry, indexes, and exports as in scope when they contain covered information. Route them to U.S.-restricted platforms.

3. Mistake: Missing subprocessor flow-down.
   Fix: require the third party to bind subprocessors to the same U.S.-only requirement and give you approval rights.

4. Mistake: Overlooking support operations.
   Fix: verify where the third party’s support teams access and store diagnostic artifacts; require U.S.-based handling for covered information.

5. Mistake: No named operator cadence.
   Fix: assign a control owner and define a repeatable evidence package. “We think it’s U.S.-only” fails audits.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should plan based on typical assessment expectations rather than case law. The operational risk is straightforward: if covered information crosses outside U.S. jurisdiction, you can trigger contractual noncompliance, heightened legal exposure, and an incident-level response if the movement is unauthorized. SA-9(8) exists to reduce those jurisdictional and access risks by constraining where data and processing can occur ².

Practical 30/60/90-day execution plan

First 30 days (stabilize scope and stop obvious drift)

• Name the SA-9(8) control owner and approve the internal interpretation memo ¹.
• Identify in-scope systems and the top third parties that process/store covered information.
• Inventory current regions for storage, backups, and logs for in-scope systems.
• Put a temporary procurement gate in place: no new third party may handle covered information without U.S.-only location confirmation.

By 60 days (contract + configuration enforcement)

• Update contract templates and third-party security schedules with U.S.-only processing and storage language.
• Implement cloud region restrictions and validate backup/DR configurations for in-scope systems.
• Build a location register and attach it to the system’s compliance package.
• Define a standard evidence set and collection workflow (Daydream can track owners, requests, and recurring artifacts without running the process in spreadsheets).

By 90 days (continuous verification and audit readiness)

• Operationalize recurring location checks and drift remediation runbooks.
• Complete third-party re-attestations for location and subprocessor commitments for critical providers.
• Run an internal “tabletop audit” of SA-9(8): pick one system, prove end-to-end U.S. location compliance with artifacts.
• Finalize exception workflow and ensure any exception has compensating controls and leadership sign-off.

Frequently Asked Questions

Does SA-9(8) require U.S.-only storage, or also U.S.-only processing?

It requires both: “information processing and data storage” must be restricted to facilities within the U.S. jurisdictional boundary ¹. Treat analytics, indexing, monitoring, and support tooling as “processing” if they handle covered data.

If my primary database is in a U.S. cloud region, am I compliant?

Not by itself. You must also validate backups, replication targets, logs, and any integrated services that process the data, plus prove controls prevent non-U.S. deployment or drift.

How should we handle third-party subprocessors?

Require flow-down: the third party must bind subprocessors to the same U.S.-only processing and storage commitments, and you need notice/approval rights before subprocessor changes.

What evidence do auditors usually accept for “U.S.-only”?

Auditors typically expect a combination of contract language, a data-flow/location register, and technical proof such as region restriction policies and configuration exports showing U.S.-only backups and replication.

Do we need to restrict where engineers access the system from?

SA-9(8) is about where processing and storage occur ¹. Remote access can still create cross-border processing if your tools capture data into non-U.S. systems (for example, ticket attachments or session recordings), so control the tooling pathways.

How do we operationalize this without slowing down procurement?

Standardize it: add a required “data location” section to third-party intake, pre-approve a short list of U.S.-only capable services, and track evidence and renewals in a system like Daydream so reviews don’t restart from scratch each cycle.

Footnotes

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

2. NIST SP 800-53 Rev. 5