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Are all legacy marked FOUO documents now CUI? No. It is not an automatic one-to-one swap. Some information previously marked as FOUO will qualify as CUI.
The standard CUI marking is the acronym CUI. This marking will appear centered across the top of every page of any document with sensitive information in bold font, large enough to be readily visible. This marking replaces legacy markings such as For Official Use Only (FOUO) or Sensitive But Unclassified (SBU).
Question: Is the CUI banner marking replacing anything that we would have labeled FOUO? Answer: Once agencies implement the CUI program, legacy markings such as FOUO or SBU will no longer be used. In some cases, what was previously marked as FOUO would align and be marked as CUI.
CUI replaces legacy markings such as OUO, SBU, and other superseded markings.
For Official Use Only (FOUO) is a document designation, not a classification. This designation is used by Department of Defense and a number of other federal agencies to identify information or material which, although unclassified, may not be appropriate for public release.
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CUI Marking Marking requirements apply to all sensitive information, including newly created information determined to be CUI. This marking replaces legacy markings such as For Official Use Only (FOUO), Sensitive But Unclassified (SBU), and Law Enforcement Sensitive (LES).
In some cases, CUI designations replace For Official Use Only (FOUO) and Sensitive but Unclassified (SBU) designations and markings.

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