CUI (Controlled Unclassified Information) Program

The CUI Program, established by Executive Order 13556 (November 2010) and implemented through 32 CFR Part 2002 (effective September 2016), creates a government-wide taxonomy for sensitive unclassified information previously managed under ad-hoc agency labels such as FOUO, SBU, LES, and PCII. The National Archives and Records Administration (NARA) maintains the CUI Registry, which defines over 20 CUI categories and subcategories across domains including Defense, Law Enforcement, Financial, Health Information, Privacy, and Critical Infrastructure. Each category maps to a specific statute, regulation, or government-wide policy that provides the legal authority for the designation. Contractors who receive CUI from a federal agency are legally bound by 32 CFR Part 2002 and any agency-specific handling instructions in the contract.

Engineering systems that touch CUI must implement controls commensurate with the CUI category. "CUI Basic" requires NIST SP 800-171 as the baseline; "CUI Specified" may impose additional or more stringent requirements derived from the authorizing law (e.g., HIPAA-derived requirements for CUI//SP-HLTH, or IRS Publication 1075 requirements for CUI//SP-TAX). Marking is a technical obligation, not just a procedural one: automated data classification pipelines must apply correct CUI banner markings and portion markings to documents, and must strip or re-evaluate those markings before any data leaves the CUI boundary. Decontrolling CUI — removing the designation when the information no longer meets the criteria — requires a documented process and audit trail.

The most common engineering failure in CUI programs is inadequate data discovery. Organizations frequently cannot enumerate all systems that contain CUI because data has proliferated through email, cloud storage, endpoint file systems, and shadow IT tools. This creates uncontrolled CUI enclaves that are outside the System Security Plan boundary. NIST SP 800-188 (de-identification of CUI) provides guidance on reducing CUI exposure through anonymization techniques for analytics and testing workloads. CUI also intersects with cloud FedRAMP authorization: a CSP must hold FedRAMP Moderate authorization at minimum to host CUI, and some CUI Specified categories (e.g., ITAR-controlled technical data) require FedRAMP High or DoD IL4/IL5.

We deploy automated CUI discovery and classification tooling across file systems, object storage, databases, and collaboration platforms, generating an authoritative CUI inventory that feeds directly into System Security Plan boundary documentation. We then implement CUI-aware data loss prevention policies at the network and endpoint layer, and build decontrolling workflows with audit trails to prevent CUI over-designation that unnecessarily expands compliance scope.

Compliance-Native Architecture Guide

Design principles and a structured checklist for building software that is compliant by default — not compliant by retrofit. Covers data architecture, access controls, audit trails, and vendor due diligence.