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SAP Data Security Best Practices for ITAR Compliance

By Michael Cunningham • August 11, 2021

You know how vital SAP data security can be in the age of data privacy and compliance regulations such as GDPR, CCPA, SOX, and others. If you’re a company involved with any part of the defense supply chain—from direct contracts on defense projects to independent upstream suppliers of parts, components, services, and software that are ultimately used in defense products—you’re likely subject to ITAR compliance. 

The International Traffic in Arms Regulations, or ITAR, is a set of government rules that control the export and import of defense-related articles, services, and technology on the U.S. Munitions List (USML) and ensure that sensitive materials (i.e., data) don’t fall into the hands of foreign parties and U.S. enemies. Put another way, if your company’s product, software, technical data, or services are identified on the USML, you’re going to be subject to ITAR requirements.

What Is ITAR Compliance? 

Answering this question is a bit tricky because there is no formal certification process to become “ITAR Compliant” or “ITAR Certified.” Instead, companies are expected to understand the regulations and take the appropriate steps to comply with these requirements. We’re not in the business of offering legal advice, but the U.S. Department of State is an excellent place to start to learn more.

Ensuring that your SAP data security practices comply with ITAR mandates is essential from a security and consequence standpoint. You never want to compromise your data, but you also don’t want to face the risks of high fines and possible jail time for failing to comply with ITAR. The penalties for ITAR infractions are severe, including civil penalties up to $500,000 per violation and criminal fines of up to $1 million and/or ten years imprisonment per violation. (A California electronics company was recently fined $6.6 Million for multiple ITAR export violations)

What’s on the U.S. Munitions List? 

There are 21 categories of Defense Articles in the USML as well as related technical data. For your reference, here are the categories (emphasis mine for #21):

  1. Firearms, Close Assault Weapons, and Combat Shotguns 
  2. Guns and Armament 
  3. Ammunition/Ordnance 
  4. Launch Vehicles, Guided Missiles, Ballistic Missiles, Rockets, Torpedoes, Bombs, and Mines 
  5. Explosives and Energetic Materials, Propellants, Incendiary Agents and Their Constituents 
  6. Surface Vessels of War and Special Naval Equipment 
  7. Ground Vehicles 
  8. Aircraft and Related Articles 
  9. Military Training Equipment and Training 
  10. Personal Protective Equipment 
  11. Military Electronics 
  12. Fire Control, Laser, Imaging, and Guidance Equipment 
  13. Materials and Miscellaneous Articles 
  14. Toxicological Agents, Including Chemical Agents, Biological Agents, and Associated Equipment 
  15. Spacecraft and Related Articles 
  16. Nuclear Weapons Related Articles 
  17. Classified Articles, Technical Data, and Defense Services Not Otherwise Enumerated 
  18. Directed Energy Weapons 
  19. Gas Turbine Engines and Associated Equipment 
  20. Submersible Vessels and Related Articles 
  21. Articles, Technical Data, and Defense Services Not Otherwise Enumerated 

Regarding category 21, technical data refers to any data stored in your SAP ERP application containing information related to items or services designated on the USML. ITAR compliance centers on ensuring this data is not accessible by non-U.S. citizens, including employees, or inadvertently distributed to foreign persons or nations.

Add ITAR Compliance Items to Your Data Classification List 

To comply with GDPR, SOX, and other compliance regulations, you probably have already classified which data in your organization is sensitive and subject to your data security, privacy, and governance policies. Further, with technical data, it’s also a good idea to tag each page with an ITAR notification. This prevents employees with legitimate access from accidentally sharing controlled information with unauthorized users.

Apply Policy-Based Access Controls 

Now that you’ve identified and categorized your data, it’s time to establish who has access to it, when they can access it, from where, on what device, and how often. This is critical but challenging as any company with employees who are non-U.S. citizens or work with non-US subcontractors must prohibit them from accessing ITAR technical data. Adding to the challenge is SAP’s static role-based access controls (RBAC) for governing access because they do not leverage contextual attributes.

Appsian Security can help you create a more policy-based and robust data security program by enabling attribute-based access controls (often called policy-based access controls) that incorporate additional contexts, such as citizenship (nationality), certification, geolocation, network, time of day, and transaction type. Combining contextual attributes with your standard roles-based attributes, you can establish policy-based rules that grant access to ERP applications, technical data, and transactions only if the person meets certain contextual criteria while still allowing them full access to everything they need to do their job.

Leverage Policy-Based Controls to Configure Preventative Controls with Appsian Security 

Once policy-based access controls are in place, Appsian Security can enable you to easily configure preventative controls at the SAP process, transaction, and field level to prevent unauthorized activity, enhance your data privacy, and increase the efficiency of your ITAR compliance program.  

Avoid Unnecessary Data Exposure with Dynamic Data Masking:

An essential requirement of ITAR is ensuring that users accessing SAP applications, either in an authorized or unauthorized manner, do not have needless access to sensitive technical data through various pages, reports, or queries. Appsian can reduce the exposure of technical data with dynamic data masking while still allowing employees to do their assigned work.

Add Stepped-Up Multi-Factor Authentication at the Transaction Level:

Adding MFA at the transaction level ensures that users are not only authorized to access and view the data but perform the actual transaction based on their current context of access and not just their role. This should be applied to highly sensitive transactions like editing a direct deposit account number, accessing compensation data, or anything involving the USML.

Strengthen Data Loss Prevention:

Using context-aware data loss prevention policies, Appsian can prevent users from executing transactions that download technical data in high-risk scenarios, such as: citizenship, after business hours, from untrusted locations, networks, or devices. This prevents employees from downloading and accidentally sharing data they shouldn’t and prevents malicious insider threats from causing damage beyond non-compliance.

Enhance Visibility into ERP Data Access and Usage:

A critical component of ITAR compliance often lacking in SAP is real-time visibility into user behavior around data access and usage. Native SAP logging capabilities were not designed with data security in mind. Appsian360 allows organizations to continuously monitor data access and usage and proactively alerts security teams to anomalous activity, particularly useful for ensuring non-U.S. citizens are not accessing data they shouldn’t.  

Learn How Appsian Helps You Enforce Controls in a Single Policy for Better ITAR Compliance 

What makes ITAR unique from other data privacy regulations is the importance it places on citizenship, certifications, and network/location attributes. Appsian Security can help your organization capture these and other attributes and provide the tools for enforcing them in a single policy.  

Contact the SAP data security experts at Appsian Security to find out how we can help you leverage policy-based controls to eliminate the complexities required with RBAC alone and more efficiently achieve ITAR compliance. 

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