More than 300,000 organizations that do business in the military-industrial base must implement heightened cybersecurity safeguards in compliance with newly-minted federal regulations.

The U.S. Department of Defense (DoD) has mandated that companies handling varying levels of information must harden their defensive posture to meet the guidelines established by the Cybersecurity Maturity Model Certification 2.0, known as CMMC 2.0. Impacted enterprises range from direct DoD contractors to subcontractors, and even small and mid-sized outfits that handle deliveries and basic services are required to earn CMMC certification.

The challenges ahead for business professionals outside the managed IT, and cybersecurity sector will likely require the support of a CMMC Third Party Assessment Organization (C3PAO). The two critical issues facing businesses involve determining which of the three CMMC certification levels apply to their organization and scheduling a gap assessment to identify cybersecurity weaknesses.

What Sensitive DoD Information Must Be Protected?

American business leaders need to understand that garden variety hackers and advanced persistent threats funded by rival nations are dangerous to national security. But, unfortunately, some mom-and-pop operations may believe they are relatively inconsequential. Unfortunately, nothing could be further from the truth.

The cybercriminals funded by rogue countries, such as Iran, Russia, and China, are determined and patient. They are not uncommon to target military supply chain companies and steal invoices, locations, and electronic messages. This data may be used in conjunction with other stolen information to conclude America’s defensive strategies. The following are the types of data the DoD has deemed necessary to protect against prying foreign eyes.

• Controlled Unclassified Information: Commonly referred to as CUI, this entails information created or controlled by the government. Although not considered secret, per se, it can be used as a piece of the national security puzzle. Examples include personal identity records, proprietary business information, and communication for official use only.
• Federal Contract Information: Generally called FCI by industry insiders, this information is linked to government contracts. It defines how a business creates or supplies products to the federal government. In other cases, it outlines a service or payment process that is not necessarily disclosed to the public.

When America’s enemies gain access to this information, it can be used like breadcrumbs, leading to highly classified plans and processes. Every business leader’s patriotic duty is to protect the men and women who serve in the military and ensure domestic tranquility. Gaining CMMC certification is effectively doing your part.

What are the CMMC Certification Levels?

An organization’s level of compliance is dictated mainly by the type of information it stores and transmits. This facet of CMMC certification can prove elusive to some business leaders who might assume cybersecurity involves a relationship with the DoD. That is not the case because a seemingly small business could handle sensitive CUI or FCI requiring advanced protections. These are the three levels of CMMC certification.

• Level 1 (Foundational): The DoD requires basic cyber hygiene based on implementing 17 defensive practices. Foundational cybersecurity focuses primarily on the storage or transmission of FCI.
• Level 2 (Advanced): Designed to protect CUI, the DoD requires companies to implement and maintain 110 security controls. These are aligned with the National Institute of Standards and Technology Special Publication on cybersecurity or NIST SP 800-171. Significant differences persist for outfits that fall into the Advanced category regarding CMMC certification requirements.
• Level 3 (Expert): The CUI housed and transmitted from organizations tasked with Expert-level CMMC certification are considered high-value targets. Sophisticated hackers, backed by enemy states, work tirelessly to breach these networks. Achieving CMMC certification calls for 13410 NIST SP 800-171 controls and NIST SP 800-172 requirements.

Determining which CMMC certification level an enterprise is mandated to meet typically requires an assessment of CUI or FCI by a C3PAO. Once that has been established, a deep penetration into the organization’s cybersecurity capabilities is needed to identify weaknesses and close gaps.

A Cybersecurity Gap Assessment Can Help Achieve CMMC Certification

A cybersecurity gap assessment aims to identify exploitable weaknesses and craft a plan to secure your assets with best-practice mitigation or remediation mechanisms. This process is widely used by small, mid-sized, and large corporations to protect sensitive and valuable digital assets from theft. However, a gap assessment can also highlight subpar practices that invite hackers to target companies with malicious software, particularly ransomware. In terms of achieving CMMC certification, the following gap assessment steps prove invaluable.

• Evaluate network security in light of CMMC protocols
• Evaluate best practices by staff members and network users
• Gather data regarding information and cybersecurity controls
• Analyze the findings to determine inherent weakness

Business leaders receive a detailed gap assessment report that highlights cybersecurity deficiencies and a Remediation & Mitigation Strategy. Regarding achieving CMMC certification, the information speaks directly to the vulnerabilities that would otherwise disqualify an operation from working within the military-industrial base. Fortunately, gaps in cybersecurity are correctable and can be closed before a CMMC review.

Sedulous Provides Gap Assessments to Achieve CMMC Certification

The need to meet the CMMC 2.0 mandate has taken on a sense of urgency. Businesses must comply to avoid being sidelined and losing otherwise lucrative DoD work. Sedulous Consulting Services is a trusted and vetted authorized C3PAO candidate, and our experienced cybersecurity professionals perform gap assessments tailored to your business. 

If you need to earn CMMC certification, contact Sedulous Consulting Services today.

Identifying the Top 3 CMMC 2.0 Challenges

The Pentagon plans to publish a cybersecurity rule during the first quarter of 2023 that will quickly be inserted into military supply chain contracts. Once the deadline passes, organizations that benefit from lucrative U.S. Department of Defense (DoD) contracts and subcontracts could be sidelined. Unfortunately, that means time is of the essence in terms of Cybersecurity Maturity Model Certification (CMMC 2.0) compliance. Inevitably, there will be some things that are confusing with the CMMC 2.0 release, so to prepare we’ve outlined the Top 3 CMMC 2.0 Challenges. 

Small, mid-sized, and large companies working in the military-industrial base can anticipate some headwinds in meeting the standards set under CMMC 2.0. The federal government has upped the ante, so to speak, because foreign hackers have managed to penetrate systems with the most determined cybersecurity defenses. For example, a Russian-backed hacking group infiltrated the U.S. Treasury and the U.S. Department of Commerce in 2020 through would many consider a backdoor.

Sophisticated and well-funded by rogue nations, hackers work tirelessly to identify vulnerabilities in the military supply chain. By piecing together sensitive data, or planting malicious software, America’s national security policies and procedures can be exploited. That’s why CMMC 2.0 is being implemented, and everyone needs to harden their cybersecurity posture. Organizations that have yet to onboard a CMMC Third Party Assessment Organization (C3PAO) can anticipate challenges resulting from the following.

1: Delaying A CMMC 2.0 Assessment

One of the most significant challenges organizations face is mainly self-inflicted. The notion that the DoD plans to release its rulemaking early in 2023 gives a handful of business leaders a false sense they have plenty of time. Nothing could be further from the truth.

It’s important to understand that some networks require only minor enhancements to achieve CMMC 2.0 compliance. A C3PAO could very quickly vet the system and identify easily correctable vulnerabilities. By that same token, companies tasked with meeting the stringent guidelines outlined in Level 2 and Level 3 of the model could require significant upgrades and a cybersecurity policy that meets DoD standards. Implementation could take months, and staff members may need cybersecurity awareness training.

More business professionals need to realize that a limited number of C3PAOs are available to perform assessments, make recommendations, and help the in-house IT team adjust. As the CMMC 2.0 standards in contracts grow closer, waiting lists are expected, and some companies will miss the deadline. If your organization hasn’t undergone a rigorous cybersecurity assessment, consider yourself tardy.

2: Thinking About CMMC 2.0 Challenges As A Checklist

The federal government continues to change and enhance wide-reaching regulations so often that private-sector people feel they are a nuisance. It’s difficult to disagree with that experience, given CMMC 2.0 comes on the heels of the initial CMMC 1.0 getting scuttled before it was even implemented. It may be human nature to grow weary of changing regulations but treating CMMC 2.0 as a type of checklist will likely lead to failed compliance. Instead, consider what each cyber hygiene level involves.

• Level 1: This basic cyber hygiene level tasks businesses with implementing 17 controls to protect Federal Contract Information (FCI).
• Level 2: This advanced cyber hygiene protocol requires organizations to implement and maintain 110 cybersecurity controls to prevent the theft of Controlled Unclassified Information (CUI). These controls were developed by the National Institute of Technology and Standards (NIST).
• Level 3: Considered expert cybersecurity, companies must meet 110 NIST controls and a subset of enhanced protections. These are subject to regularly scheduled audits by a certified third-party assessment firm.

Despite what some might consider bureaucratic clumsiness, cybersecurity mandates such as the Health Insurance Portability and Accountability Act (HIPAA), the 1999 Gramm-Leach-Bliley Act, and the 2002 Homeland Security Act protect everyday people from hackers stealing valuable and sensitive digital information. The rollout of CMMC 2.0 will provide enhanced security for the men and women in the armed forces, as well as everyday civilians.

Few operations can update antivirus software and check the proverbial box for the DoD. The CMMC 2.0 mandate requires regular reviews, recertification, and changes are likely to continue.

‍3: Not Having A Comprehensive Cybersecurity Strategy For CMMC 2.0

To remain in the DoD supply chain, wide-reaching organizations need a System Security Plan (SSP) that meets NIST guidelines. An SSP goes much further than hardening a network’s cybersecurity measures. Instead, it looks at how CMMC-related defenses are implemented and their effect on other systems in their orbit. The basic concept is that a hacker could spend a great deal of time and energy targeting a seemingly peripheral small business because its syncs with a bigger national security fish that houses useful CUI or FCI.

Businesses can expect that CMMC 2.0 auditors will deeply dive into a business’s written SSP and compare it to actual best practices. To say more than a few small and mid-sized companies do not have an up-to-date and fully functioning SSP would be something of an understatement. That’s why SSP development and implementation are significant challenges to meeting the fast-approaching CMMC 2.0 mandate.

Prepare for the CMMC 2.0 Deadline by Scheduling a Gap Assessment

Executing a gap assessment is a crucial step in achieving CMMC 2.0 compliance. This process involves collecting wide-reaching security data regarding your current security posture. Once this data is gathered, an experienced C3PAO firm analyzes every facet of your cybersecurity. Business leaders receive a report and expert advice about curing vulnerabilities and how to mitigate or remediate them. This step can position you for CMMC 2.0 compliance and avoid being sidelined.

Sedulous Consulting Services is an approved  C3PAO candidate and managed IT/Cybersecurity firm. Our dedicated and experienced team members can comprehensively conduct a gap assessment and help your business overcome any CMMC 2.0 challenges ahead. Contact Sedulous Consulting Services today.