As I understand it-
You can't secure a mounted nfs share with SELinux because it can't apply its labels (and I wonder which other filesystem types that wouldn't work either).
AppArmor would allow you to secure (to the level apparmor does) pretty much any path in the system and so you can secure an nfs/smb/anything mount.
For me this is pretty critical in making a choice of security systems.
Attention captain obvious- nfs security shortcomings are offtopic in replies ;) .
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