AI Governance Policy for Defense Contractors
A three-tier AI governance model for defense contractors: prohibited, restricted, and permitted AI tools, mapped to the CMMC Level 2 controls that AI usage touches.
Tier 1 - Prohibited
AI tools that process, store, or transmit CUI/FCI. No exceptions without ATO.
- Any AI tool that sends CUI to external servers
- Consumer-grade AI assistants (ChatGPT, Claude) for CUI-related work
- AI-powered translation services processing controlled documents
- Cloud-based OCR/transcription on CUI documents
Tier 2 - Restricted
AI tools that operate in CUI environments but do not directly process CUI. Requires approval and monitoring.
- AI-powered endpoint security tools in CUI enclaves
- Code assistants used on projects adjacent to CUI systems
- AI-driven SIEM/log analysis in GCC High environments
- Automated vulnerability scanning with AI prioritization
Tier 3 - Permitted
AI tools operating entirely outside CUI boundaries on non-sensitive work.
- AI writing assistants for marketing content
- Code generation for non-CUI projects
- AI-powered scheduling, HR, or finance tools
- Training and education AI tools
| Control | Name | Why AI usage touches it |
|---|---|---|
| AC.L2-3.1.1 | Authorized Access Control | Governs who can access AI tools in CUI environments |
| AC.L2-3.1.2 | Transaction & Function Control | Limits what AI tools can do with controlled data |
| AT.L2-3.2.1 | Role-Based Training | Requires AI-specific security training for CUI personnel |
| AU.L2-3.3.1 | System Auditing | Audit logs must capture AI tool interactions in scope |
| CM.L2-3.4.1 | System Baselines | Approved AI tools become part of the system baseline |
| CM.L2-3.4.2 | Security Config Enforcement | AI tool configurations must meet security requirements |
| MP.L2-3.8.1 | Media Protection | AI-generated outputs containing CUI require marking and protection |
| SC.L2-3.13.1 | Boundary Protection | Network boundaries must account for AI tool data flows |
| SI.L2-3.14.1 | Flaw Remediation | AI tool vulnerabilities must be tracked and patched |
For where the obligation itself comes from, the clause chain and the CSP fork are walked in can you use AI in a CUI environment.