Foreign National Administrator Access to the USMC Information Systems
This MARADMIN establishes Marine Corps policy regarding foreign national (FN) personnel serving in Information Assurance (IA) management and administrator roles on unclassified information systems. It clarifies that while FNs are prohibited from serving as Information Assurance Managers (IAMs) and cannot be newly hired as Information Assurance Officers (IAOs), current FN IAOs and system administrators may continue in their roles under specific conditions including written DAA approval, U.S. citizen supervision, and required security investigations.
Issued: June 25, 2004
1. PURPOSE. THIS MESSAGE PROMULAGATES MARINE CORPS POLICY REGARDING FOREIGN NATIONAL (FN) PERSONNEL OCCUPYING IA MANAGEMENT AND ADMINSITRATOR ROLES ON UNCLASSIFIED INFORMATION SYSTEMS. THIS MESSAGE IDENTIFIES RESTRICTIONS AND CONDITIONS THAT LOCAL DESIGNATED APPROVAL AUTHORITIES (DAA) ARE RESPONSIBLE TO MEET PRIOR TO DESIGNATING NEW FN PERSONNEL AS ADMINSTRATORS AND FOR THE CONTINUED USE OF CURRENT FN PERSONNEL AS INFORMATION ASSURANCE OFFICERS (IAO) AND ADMINSITRATORS ON UNCLASSIFIED MARINE CORPS NETWORKS. FN ACCESS TO CLASSIFIED NETWORKS AND/OR SYSTEMS REQUIRES ADDITIONAL STEPS DELINEATED WITHIN THE DOD PERSONNEL SECURITY PROGRAM (DODD 5200.2-R). 2. ISSUE. REFS A AND B HAVE BEEN INTERPRETED BY SOME APPLICABLE PERSONNEL AS BARRING FNS FROM ALL IA ADMINSTRATOR & PRIVILEGED USER FUNCTIONS. USMC POLICY DOES NOT SUPPORT THIS INTERPRETATION AND THIS MARADMIN SPECIFIES THE CONDITIONS AND RESPONSIBILITIES UNDER WHICH THE MARINE CORPS WILL CONTINUE TO USE FNS WITHIN USMC INFORMATION SYSTEMS IAW DOD POLICY. 3. POLICY. A. REFS C AND D IDENTIFY IA FUNCTIONAL ROLES AND RESPONSIBILITIES. BOTH NOTE THE CHANGE OF TERMS INFORMATION SYSTEM SECURITY MANAGER (ISSM) TO INFORMATION ASSURANCE MANAGER (IAM), AND INFORMATION SYSTEM SECURITY OFFICER (ISSO) TO IAO. REFS C AND D ALSO CLASSIFY SYSTEM ADMINISTRATORS AS PRIVILEGED USERS WITH IA CONFIGURATION ABILITIES. REF C CHARGES SYSTEM ADMINISTRATORS WITH ASSISTING THE IAO IN KEEPING SYSTEMS SECURE. B. IAW REF B, PARA 5.8.3, ALL IAMS WILL BE U.S. CITIZENS. REF B MAKES NO EXCEPTIONS ON THIS RULE. ASSIGNMENT TO A PRIVILEDGED USER ROLE, IAM, WITH IA MANAGEMENT ACCESS IS NOT ALLOWED FOR FNS. IAW PARA 2.8 REF E, A GOVERNMENT CIVILIAN OR MILITARY MEMBER MUST BE DESIGNATED AS THE IAM. CONTRACTOR PERSONNEL ARE NOT ALLOWED TO SERVE AS AN IAM. C. IAW REF B, PARA 5.9.5 ALL NEWLY APPOINTED IAOS SHALL BE U.S. CITIZENS. FOREIGN NATIONALS WHO ARE DIRECT OR INDIRECT HIRES AND ARE CURRENTLY APPOINTED AS IAOS ARE PERMITTED TO CONTINUE IN THEIR ROLES PROVIDED THEY RECEIVE THE WRITTEN APPROVAL OF THE DAA, SERVE UNDER THE IMMEDIATE SUPERVISION OF A US CITIZEN IAM, HAVE NO SUPERVISORY DUTIES AND UNDERGO A NACLC OR EQUIVALENT INVESTIGATION IAW PARA 4.8 OF REF A. D. FNS CAN NO LONGER BE HIRED, DIRECTLY OR INDIRECTLY, TO PERFORM IN AN IAO CAPACITY; NOR CAN A FN BE PROMOTED OR ELEVATED INTO AN IAO POSITION. AS FN IAOS LEAVE THE MARINE CORPS OR CURRENT IAO DUTIES, US CITIZENS WILL REPLACE THEM. E. IAW REF B, ENCLOSURE 3, FNS ARE PERMITTED TO RETAIN PRIVILEGED USER/SYSTEM ADMINISTRATOR POSITIONS, INCLUDING IA CONFIGURATION CAPABILITY OF RELEVANT COMPONENTS PROVIDED THEY RECEIVE THE WRITTEN APPROVAL OF THE DAA, SERVE UNDER THE IMMEDIATE SUPERVISION OF A US CITIZEN, HAVE NO SUPERVISORY DUTIES AND UNDERGO A NACLC OR EQUIVALENT INVESTIGATION IAW PARA 4.8 IN REF A. 4. IN SUMMARY, MARINE CORPS SYSTEMS WILL MAINTAIN CURRENT FN PRIVILEGED USERS AND IAOS IAW PROVISIONS SET FORTH IN PARA 3 ABOVE. FN'S IN CURRENT IAO ROLES MAY CONTINUE SERVICE. HOWEVER, FUTURE HIRING OF FN'S TO PERFORM AS IAO'S IS NOT PERMITTED.