Full Packet Capture as Strategic and Regulatory Imperative

Matt BromileyEndace partnered with SANS to review a wide range of cybersecurity regulations around the globe. This report, by Matt Bromiley, Certified Instructor at SANS, examines at how always-on packet capture enables organizations to comply with these key regulations, while also providing an essential foundation of effective cyber defense.

The report also includes detailed “tear-sheets” which outline how always-on full packet capture enables compliance with the specific requirements of key regulations and frameworks including Zero Trust, NIST CSF, ISO 27-001, NIS2 Directive, Australian ISM and more.

This page provides the information specific to OMB M-21-31.

See the overview of the full research study here:

Full Packet Capture as Strategic and Regulatory Imperative

Enabling OMB M-21-31 Compliance for Federal Agencies

The US Office of Management and Budget’s (OMB) Memorandum M-21-31 mandates that all federal agencies implement comprehensive cybersecurity logging capabilities, including an explicit 72-hour full packet capture (FPC) requirement. Following the devastating SolarWinds supply chain compromise, M-21-31 establishes a four-tier event logging (EL) maturity model designed to standardize incident response (IR) capabilities across the federal government. Compliance isn’t optional; agencies that fail to meet M-21-31 requirements may face:

  • Regulatory penalties and oversight actions
  • Loss of operational authorization (ATO)
  • Suspension of critical services
  • Congressional scrutiny and public accountability

Federal CISOs, risk officers, and executive leadership should view M-21-31 as a strategic operational requirement. It ensures IR readiness, preserves forensic evidence integrity, and enables agencies to participate confidently in federal cybersecurity initiatives, threat sharing programs, and cross-agency coordination. However, this is not done in a vacuum. Federal cybersecurity teams face mounting pressure from:

  • Advanced persistent threats targeting government infrastructure
  • Complex multicloud and hybrid environments requiring unified visibility
  • IR times measured in hours, not days, with constrained resources

Enterprise-grade FPC solutions directly address M-21-31’s core requirements while providing comprehensive network visibility. This allows organizations to detect and investigate threats faster while reducing operational complexity of multi-framework compliance requirements.

FPC doesn’t replace existing federal security tools: It enhances the landscape. By serving as a common evidence foundation across CISA tools, SIEM platforms, and threat sharing initiatives, FPC facilitates actionable intelligence and more accurate detection and response.

OMB M-21-31 Compliance Framework

The tearsheet below references EL maturity tiers, established by M-21-31 to show where and how FPC supports compliance in each domain. This helps federal agencies turn regulatory requirements into operational readiness and mission resilience.

Download Tearsheet

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