Meeting CMMC AC.L2-3.1.4 - Separation of Duties

As part of the Cybersecurity Maturity Model Certification (CMMC) Level 2 requirements, AC.L2-3.1.4 – Separation of Duties plays a critical role in strengthening your organization's security posture. While it may sound like a concept reserved for large enterprises, this requirement is just as important—and achievable—for small and medium-sized businesses handling Controlled Unclassified Information (CUI).

What Does AC.L2-3.1.4 Require?

Control Statement: “Separate the duties of individuals to reduce the risk of malevolent activity without collusion.”

This means your organization must divide responsibilities among different people in a way that prevents any single individual from having complete control over all aspects of a critical process, especially when that process involves access to sensitive systems or data.

Why Separation of Duties Matters

Separation of duties (SoD) is a foundational security principle that reduces risk by limiting the power any one person has within your IT environment. It helps prevent fraud or abuse (intentional or unintentional), increase oversight and accountability, and limit the damage from compromised accounts or insider threats

Practical Examples for Small Businesses

You don’t need a large staff to implement separation of duties effectively. Here are some practical ways small organizations can meet the requirement: Create a Roles and Responsibilities Matrix showing key duties and which employees or teams are responsible. Personnel who administer systems are not responsible for revieiwing security logs. Implement RBAC to ensure that users only have access to what they need for their job role. This helps enforce separation of duties through system design. Conduct regular reviews to ensure the separation is being maintained over time.

Final Thoughts

Meeting AC.L2-3.1.4 is about implementing thoughtful checks and balances. Even small organizations can—and must—adopt separation of duties to mitigate risks associated with unauthorized access or internal misuse. Start small, document clearly, and build a security culture where no one person has unchecked access to sensitive systems or data.