Microsoft Office 365 GCC High: Achieving ITAR Compliance in the Cloud

The ITAR is a set of regulations governing the manufacturing, brokerage, export, and import of defense articles, defense services, and sensitive technical data. Those companies that export, manufacture, broker, or import items, services, or technologies on the USML must achieve ITAR compliance. These regulations impose strict access controls, classification procedures, and physical security to prevent unauthorized access to sensitive technologies and data. For cloud-based services, ITAR compliance is complex, given the distributed nature of cloud computing across geographic boundaries and regulatory jurisdictions. This is where Microsoft Office 365 GCC High comes in. It is purposely built for ITAR compliance and provides a segregated cloud environment and comprehensive security controls tailored to highly sensitive government data. Key capabilities that make Office 365 GCC High critical for ITAR compliance include:

Ensuring data sovereignty

ITAR compliance requires that access to technical data on defense items and services be restricted to U.S. persons only. Microsoft Office 365 GCC High ensures data sovereignty by storing all customer data in data centers located in the Continental United States. Additionally, access to data in Office 365 GCC High tenants is strictly limited to U.S. persons. These persons undergo thorough citizenship checks and background screening, including those listed here. Office 365 GCC High doesn’t route any data internationally, mitigating ITAR compliance risks associated with foreign access to ITAR-controlled data.

Microsoft Office 365 GCC High is an isolated cloud segment

Office 365 GCC High is a logically and physically isolated cloud segment particularly designed for U.S. government agencies and federal contractors. It meets the rigorous security and compliance standards, such as the ITAR, required by U.S. government agencies. The isolation provides an additional layer of security over commercial cloud services, preventing unauthorized access or exposure of ITAR-controlled and other sensitive data.

Robust access controls

Microsoft Office GCC High implements robust identity and access controls that restrict data access only to authorized personnel. Features like attribute and role-based access controls, identity management, and multi-factor authentication (MFA) are integrated into Office 365 GCC High. The integrated MFA uses a federated identity model, enabling the use of CAC and PIV cards. This tenant’s auditing capabilities provide detailed visibility into user activities for compliance reporting, which prevents unauthorized access to ITAR-controlled data.

Strong encryption

ITAR requires that data be encrypted at rest or in transit. ITAR-controlled data should only be accessed by the receiver when it enters their security boundary. To this end, Microsoft actively commits to meet the FIPS 140-2 standard requirements. ITAR compliance requires that technical data related to defense items and services be encrypted end-to-end using FIPS 140-2 cryptographic modules. The access information, like encryption keys, is managed in U.S. data centers. Encryption extends to services like Exchange, SharePoint, Teams, and OneDrive. This ensures that sensitive ITAR-controlled technical data is safeguarded from potential unauthorized access and disclosure.

Comprehensive auditing and logging

One of Office 365 GCC High’s services is comprehensive auditing and logging that tracks detailed user activities. Logs capture events such as access attempts, file edits, and data exports. Organizations can then audit these logs for compliance reporting and forensic purposes in the event of a security incident. If an organization detects a violation, the ITAR encourages them to voluntarily report those violations to the DDTC. However, auditing is not a one-time event but rather a continuous activity to ensure there are no ITAR compliance gaps. 

Thorough background checks

ITAR demands that technical data on defense articles and services be only accessible to approved U.S. persons. Microsoft Office 365 GCC High helps meet ITAR compliance in the cloud by ensuring all personnel who may come into contact with ITAR-controlled data are thoroughly vetted and screened. They undergo rigorous background checks on their citizenship, employment eligibility, and criminal history, among others. Background checks include criminal history verification, fingerprinting, government watchlist screening, and identity verification. Their details are run against OFAC, DDTC’s debarred parties list, and the Bureau of Industry and Security list, among others.


Microsoft Office 365 GCC High meets extensive compliance standards and accreditations required for handling highly sensitive government data. This includes FedRAMP High authorization, EAR/ITAR compliance, NIST SP 800-53/171 compliance, and DoD SRG IL 4 compliance. The accreditations demonstrate the tenant’s commitment to maintaining the highest standards of compliance and security in its cloud offerings. They also provide customers with the assurance that GCC High has undergone rigorous third-party audits. These audits validate that it has implemented the necessary security controls to meet ITAR requirements for handling restricted data.

Disaster recovery

GCC High provides robust disaster recovery and business continuity protections. Customer data is replicated in near real-time across multiple isolated U.S. data centers. Built-in redundancy across sites protects against localized failures. In a disaster event, backup systems and failover mechanisms reduce disruption and prevent data loss. These capabilities help maintain the integrity and availability of ITAR-controlled technical data. They also ensure that organizations can quickly recover their operations in the event of a disaster, minimizing service downtimes and disruptions.

These capabilities help government agencies and contractors implement physical, technical, and administrative controls required for ITAR compliance in the cloud. Microsoft Office 365 GCC High provides a reliable platform to securely manage, collaborate, and share sensitive defense-related data and technologies subject to ITAR. Do you need help achieving ITAR compliance in the cloud? Are you looking to migrate to a Microsoft Office 365 GCC High tenant? Look no further than Cleared Systems. Our experts can help you seamlessly migrate to Office GCC High tenants, ensuring you achieve ITAR compliance without any disruptions. Contact us today for ITAR compliance consulting and Office 365 GCC High migration, among other managed services.

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What is GCC High?

Microsoft 365 Government Community Cloud (GCC) High is a specialized cloud solution tailored for U.S. federal, state, local, tribal, and territorial government organizations, as well as for contractors who hold or process data subject to specific security regulations. In this article, we will explore the features, benefits, and differences between Microsoft 365 GCC High and other Office 365 offerings.

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