The mandatory implementation of cybersecurity regulations is quickly approaching for contractors in the defense industrial base.

As the Pentagon rolls out the second version of Cybersecurity Maturity Model Certification, aka CMMC 2.0 changes, interim rules are expected to go online. As a result, companies can anticipate seeing CMMC 2.0 language appear in the U.S. Department of Defense (DoD) and other lucrative contracts brokered by the federal government. The first interim rules are set for March 2023, meaning CMMC 2.0 mandates will likely appear in agreements come July 2023.

The idea that CMMC 2.0 rules won’t impact deals until July may not create a sense of urgency. But the time it takes to conduct a comprehensive cybersecurity analysis of systems, employee practices, and the way sensitive data is stored and transmitted could take months. Moreover, given the impact the following changes could have on contractors, business leaders could get sidelined if they procrastinate.

1: More Stringent Policies and Procedures

Organizations will be tasked with meeting the NIST 800-171 requirements assigned to each of the three cyber hygiene levels. The forthcoming mandate does away with some process requirements at the lowest level but insists an enterprise “define” upwards of 49 of 110 controls. A cursory look at the three levels shows this could prove a Herculean task for organizations.

• Level 1: Cyber hygiene at this level involves the protection of Federal Contract 

Information (FCI) not intended for public disclosure. Although considered “basic” cyber hygiene, military supply chain businesses must address how FCI is handled and stored.

• Level 2: Companies will be required to document the processes used by staff members. It involves achieving cyber hygiene concerning 14 domains and 110 controls.
• Level 3: A contractor’s cybersecurity posture must be so rigorous it can repel the advanced persistent threats presented by enemy nations. Companies must have a regular third-party assessment and maintain a determined posture.

Industry leaders must often prove they achieved the necessary cyber hygiene level to bid on DoD and other federal contracts. Before the federal government crafted the CMMC 2.0 policy, they primarily took a contractor’s word they complied. That all ends now.

2: Plan of Action and Milestones & Waivers

The number of waivers granted is expected to be slimmed down considerably, and a tight policy has reportedly been established. A minimum score for each control must be satisfied, and no waivers will be allowed for the highest weighted controls (i.e., those worth five points).

Cybersecurity experts and national security insiders are hailing this as a win for America’s digital defense. Contractors who previously relied on stop-gap waivers would be well-served to contact a CMMC Third Party Assessment Organization (C3PAO), conduct the necessary due diligence, and harden their defenses.

3: Changes to Self-Assessments

One of the changes from CMMC 1.0 to 2.0 involves what appears to be flexible self-assessments, at least at first blush. The approaching mandate indicates outfits that fall under Level 1 may conduct their assessment and file a score online.

Initially, some Level 2 organizations were going to have a self-assessment option, while others needed to work with a C3PAO, depending on the nature of the FCI or Controlled Unclassified Information (CUI). However, recent reports indicate Level 2 companies will all be mandated to undergo a third-party assessment. As a result, an estimated 80,000 contractors and subcontractors handle FCI and CUI required to meet Level 2 standards. The same holds for contractors within the Level 3 framework.

4: Senior Officials Tasked with Annual Affirmations

One of the top-tier issues CMMC 2.0 seeks to address is accountability. The DoD once fined or suspended companies after determining they failed to meet federal cybersecurity guidelines. Unfortunately, many of the penalties came after a hacker had already absconded sensitive FCI or CUI.

According to a filing in the Federal Register, the newly-conceived cybersecurity regulations allow “annual self-assessment with an annual affirmation by DIB company leadership” in some cases. This means that faulty self-assessments and failure to maintain a Level 1-3 posture may result in the company and senior management personnel suffering consequences. Given the wide-reaching things that could go awry during internal audits, industry leaders would be well-served to onboard a C3PAO.

5: Preparation Timeline Shortened

Early expectations around the CMMC 2.0 rulemaking process were that it would take 9-24 months. Now, contractors and subcontractors have until July before mandates appear in agreements. Industry leaders should start implementing NIST 800-171 controls before the year’s end. When the first quarter of 2023 kicks off, the 300,000 organizations in the defense industrial base will likely overwhelm the availability of C3PAOs, creating a bottleneck.

How to Prepare for CMMC 2.0 Appearing in Contracts

The best preparation strategy may involve scheduling a gap assessment. This cybersecurity analysis deeply delves into systems, best practices, programs, and how FCI and CUI are stored and transmitted. Business leaders receive a report showing network strengths and vulnerabilities. Accompanying recommendations highlight ways to close security gaps and meet the CMMC 2.0 mandate.

Sedulous Consulting Services is an Approved C3PAO Candidate firm. Our dedicated team members can comprehensively conduct a gap assessment and overcome any CMMC 2.0 challenges contractors and subcontractors face. To schedule a gap assessment, contact Sedulous Consulting Services today

More than 300,000 businesses in the military-industrial base need to implement the Pentagon’s latest cybersecurity policy. The Cybersecurity Maturity Model Certification (CMMC 2.0) does not discriminate between small, mid-sized, and large corporations. The U.S. Department of Defense (DoD) announced it would publish an interim CMMC 2.0 rule in March, with small business contractors seeing it in their agreements soon after. Small business owners may view the federal government’s mandate as overkill. But Robert Metzger, who reportedly inspired CMMC with the startling “Deliver Uncompromised” report, recently explained why small business contractors need to adopt the measure and understand the CMMC Requirements. 

“We know that adversaries will seek the so-called low-hanging fruit and mount attacks against less well-defended companies. The problem is that for smaller businesses, (NIST Special Publication 800-171) can be daunting, intimidating, frustrating, confusing and expensive,” Metzger reportedly said at the Washington Technology CMMC Summit. “But we cannot decide that security is unimportant for small businesses. We cannot give them a waiver. But we must facilitate a means by which small businesses can accomplish security economically.”

With the mandate fast approaching, small businesses would be well-served to take proactive steps in preparation for CMMC 2.0, such as scheduling a cybersecurity gap assessment. A managed IT firm with CMMC 2.0 expertise can provide scalable support. These are things small business contractors need to know about the mandate and why they would be wise to act with a sense of urgency.

How Do CMMC 2.0 Levels Apply to Small Businesses?

There are reportedly more than 300,000 organizations that benefit from lucrative DoD contracts. The bulk of these companies provides materials and services in support of direct military defense contractors that design and build equipment and technologies.

The enemies of Democracy finance some of the world’s most notorious hackers to breach systems at every level. Even the most determined advanced persistent threats understand few cybersecurity gaps persist among corporations that handle top-secret information. That’s why they target small and mid-sized outfits — “low-hanging fruit,” as Metzger stated — in hopes of uncovering scraps of information that expose the greater national security picture. These are the types of digital information they are trying to steal.

• FCI: Federal Contract Information is not intended for public disclosure. Although not necessarily a danger itself, FCI can be used as a piece of the national security puzzle. It may provide clues for rogue nations to discover significant policies and initiatives.
• CUI: Controlled Unclassified Information is created by the government. It may have been linked to the DoD, making it essential to protect. Stolen CUI can be used to learn military activities and potentially place the men and women who serve in harm’s way.

Of the three CMMC 2.0 levels, small businesses must comply based on the type of FCI or CUI the operation stores and transmits. A small technology company with five employees may need to meet the expert cyber hygiene requirements of Level 3. By that same token, a small business of 100 employees could fall under the basic cyber hygiene of Level 1. Business professionals who are unsure about the requirements are advised to contact an accredited CMMC Third Party Assessment Organization (C3PAO) to conduct an audit.

What are CMMC 2.0 Benefits for Small Businesses?

Even when a government mandate is well-intentioned, there’s a tendency to view it as just another expense or, well, a hassle. This holds particularly true of small business leaders who consider their seemingly peripheral contributions inconsequential.

We know that advanced persistent threats do target companies on the outskirts of the military supply chain to infiltrate federal agencies. The SolarWinds software breach of 2020 proved skilled hackers could penetrate thousands of organizations in this fashion, including the U.S Treasury Department. But to hit a little closer to home, small businesses may want to consider CMMC 2.0 as a way to harden their posture for the following reasons.

• Forty-six percent of all breaches affect businesses with fewer than 1,000 employees.
• More than 60 percent of small and mid-sized businesses were targeted in 2021.
• Upwards of 82 percent of ransomware attacks were leveled against small and mid-sized companies in 2021.
• More than one-third of ransomware victims employed fewer than 100 people.
• Small business employees experience social engineering attacks 350 percent more than big corporations.

Verizon’s 2021 Data Breach Investigations Report indicated that even garden variety hackers are targeting small businesses at an increased rate of 61 percent. Symantec’s 2016 Internet Security Threat Report indicated that the number was only 34 percent in 2014 and 18 percent in 2011. It’s easy to see which way the cyberattack trend is heading.

Should your operation get plucked like the “low-hanging fruit,” small business losses typically range from $120,000 o $1.24 million. Needless to say, an organization compromised by hackers will likely lose profitable DoD contract work. And the reputational damage drives companies into bankruptcy.

“The smart move is to protect yourself. Now. Not because you have to comply but because you want your enterprise to stay in business,” Metzger reportedly said. “Be secure beforehand for the sake of your employees, your lenders, your clients, your customers, your investors.”

The good news is that CMMC 2.0 delivers the hardened defense small businesses need to deter low-level hackers and advanced persistent threats alike.

How to Get Started with CMMC 2.0

The first step toward robust cybersecurity calls for a gap assessment. An accredited C3PAO reviews best practices and internal cybersecurity policies and thoroughly vets the small business network for vulnerabilities. Once the data has been analyzed, company leaders receive a report highlighting weaknesses and offering solutions. Not only will you possess a roadmap to CMMC 2.0 compliance, but you can stop being an easy target.

Sedulous Consulting Services is an Approved C3PAO Candidate firm. We perform gap assessments and can help you harden your cybersecurity posture. Contact Sedulous Consulting Services today.

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.

Cybercriminals relentlessly try to breach business systems and steal sensitive and valuable information. Not only do hackers not take the holidays off, but these digital thieves also take advantage of increased online activity and everyday people letting their guard down. So how can businesses prevent cyberattacks during the holidays? 

In terms of situational attacks, cybercrime skyrocketed by upwards of 600 percent during the pandemic as hackers exploited fear and companies shifted to remote workforces. These are other troubling statistics involving data breaches and digital theft.

• Approximately 42 percent of all data breaches involve small or mid-sized businesses.
• Hackers are able to penetrate 93 percent of all business networks.
• Weekly business data breach attempts increased by 50 percent in 2021.
• The most targeted industries included healthcare, the military, and communications.

When including major corporations, the average cost of a data breach in 2021 hovered at $4.24 million. Before 2022 closes, that estimate will likely exceed $4.35 million. With that kind of money at stake, hackers will not be taking the holidays off.

Common Hacking Schemes Used During the Holidays

Online thieves typically change their techniques to maximize data breach success rates. During the pandemic, hackers trolled out disgraceful email scams tricking recipients into believing a loved one was hospitalized and needed money to start treatment. That shows just how low these nefarious individuals will sink. They are more than willing to exploit the holidays to steal your digital assets. These rank among the commonly deployed schemes during the holidays.

• Phony Shipping Alerts: Packages making their way through the delivery system often involve a tracking component. Cyber-thieves targeting businesses are well aware professionals check these emails and text messages from the same devices they use for work. One of the high-percent tricks involves prompting someone to click on a fake tracking link. That’s when malware automatically downloads into the business network, giving criminals access to digital assets.
• Fake Invoices: Along with phony tracking alerts, hackers now send seemingly digital invoices that consumers are inclined to save on a device. It’s basically the same scheme as fake shipping alerts, but the malicious application is embedded in the PDF. Hackers can activate it, at will, and steamroll a business network.
• Unauthorized Transactions: Personal and business accounts are more vulnerable during the run-up to the holidays because purchases are made more frequently. End-of-year business gifts to colleagues, employees, and charitable donations can result in financial confusion sometimes left to clean up after the holidays. Hackers are quick to swipe credit card and bank account numbers of platforms that are not necessarily secure.

Although the number of data breaches increases year-over-year, that doesn’t mean business leaders cannot avoid theft. Hackers bank on the fact that a high percentage of small, mid-sized, and even large corporations have persistent vulnerabilities. By hardening your defenses and educating staff members about hacking schemes, digital bandits are more likely to pass over your network and find an easier mark.

How to Prevent Cyberattacks During the Holidays

It’s essential to maintain a robust cybersecurity posture during the entire year. Digital thieves make a living stealing business and personal information and selling it on the Dark Web. During the holidays and other periods when people change behaviors, cybercriminals reach into their situational bag of tricks to improve their odds. The following measures can help stop hackers before they breach your business network.

• Cybersecurity Awareness: The overwhelming majority of hacks are related to human error. Some employees click on a malicious link or provide their login credentials, and the system gets breached. Many of the hacking schemes deployed during the holidays can be easily recognized by providing staff members with ongoing cybersecurity awareness training. Instead of clicking on that link, they’ll delete the electronic message.
• Password Protections: Most of us have multiple online accounts that require usernames and passwords. The habit of using simple, easy-to-remember combinations makes our personal and professional data vulnerable. By following through with a policy of changing passwords and requiring complex ones are used, the entire company is safer.
• Multifactor Authentication: This ranks among the simplest and most effective ways to prevent cybercriminals from exploiting employee login credentials. When someone goes to access the business network, a code is sent to a secondary device. That code must be entered before the person can proceed. Even if a hacker learns a username and password, they are highly unlikely to possess that second device.
• Zero-Trust Credentials: This cybersecurity strategy involves limiting each user’s bandwidth. Each profile is analyzed to allow only access to the data they need to complete tasks. Should a hacker use the team member’s credentials, their access is similarly restricted.

Perhaps the best way to prevent a data breach during the holidays is to build a culture around cybersecurity. Every decision-maker and frontline employee has a stake in the organization’s success. That makes preventing data breaches everybody’s business.

Contact Sedulous Consulting Services for Determined Cybersecurity

Based in Triangle, Virginia, Sedulous Consulting Services works with small and mid-sized businesses to assess their cybersecurity vulnerabilities, secure network defenses, and prevent data breaches. If you’re concerned about potential cybersecurity vulnerabilities, contact Sedulous Consulting Services.

Business professionals in the military-industrial base have been inquiring about the Cybersecurity Maturity Model Certification (CMMC) for upwards of two years and now is the time to act with urgency.

The federal government decided to pull back the initial CMMC plan, revise it, and develop CMMC 2.0. Like a dark cloud hanging over the contractors and subcontractors, organizations that tap into the U.S. Department of Defense (DoD) revenue stream have been eager to comply. That’s one of the reasons Sedulous Consulting Services was among the first 100 organizations to qualify as a Third-Party Assessment Organization.

Although DoD contractors, supply chain outfits, and managed IT cybersecurity firms have all been stuck in a holding pattern, it appears the DoD is ready to move forward with the long-anticipated CMMC 2.0. The newly minted cybersecurity mandate will task companies with building out technological infrastructure, educating employees about best practices, and maintaining different types of certification.

The goal is to prevent garden variety hackers and advance persistent threats, funded by rival nations, from acquiring Controlled Unclassified Information (CUI) for the purposes of breaching our national security. Organizations that are unprepared or fail to meet the stringent regulatory requirements can expect to find themselves outside the industry, losing profit-driving contracts and subcontracting work.

What Businesses Need to Know About CMMC 2.0 Timeline

The initial CMMC version was put forward in January 2020 and was met with complaints regarding costs, complexity, and confusion regarding assessments and compliance. Small businesses found the mandate particularly challenging because it was difficult for those outside the managed IT cybersecurity industry to determine which level was applicable and how to implement the required controls.

The imminent CMMC 2.0 streamlines the guidelines from five levels to three. But, in all honesty, there are baked-in items that small and mid-sized operations may find frustrating. However, the mandate is here to stay, and your company will be required to meet one of the following three CMMC 2.0 levels.

• Level 1: The federal government calls this the “Foundational” level and it pertains to companies that store or transmit Federal Contract Information (FCI). Generally applicable to suppliers and service providers, businesses will be required to meet 15 controls. Companies will need to have a cybersecurity assessment conducted annually and file the results for review.
• Level 2: This “Advanced” cybersecurity standard calls for implementing and maintaining upwards of 110 controls. The advanced cybersecurity directive has been something of a pain point for small and mid-sized organizations. That’s because it treats companies differ in terms of enlisting a Third-Party Assessment Organization, internal reviews, or a combination of both. If there’s a space where companies get tripped up and lose government-driven revenue, this may very well be it. We advise businesses to err on the side of caution, contact a Third-Party Assessment Organization, and protect their livelihood.
• Level 3: Considered “Expert” cyber hygiene, outfits will need a Third-Party Assessment Organization to review their system, cybersecurity policies, and best practices. An objective analysis will lead to certification or inform stakeholders where deficiencies persist. There are a reported 134 necessary controls embedded in Level 3.

It’s essential to keep in mind that meeting the CMMC 2.0 timeline calls for proactive measures. There are a limited number of certified Third-Party Assessment Organizations and they will be in increasingly higher demand as the rollout moves forward. Putting off scheduling a CMMC 2.0 assessment will likely result in your company landing on a waiting list. Although not visually obvious like the 110 cargo vessels anchored off the California Coast last year or the gas lines after the Colonial Pipeline hack in May 2021, businesses can expect lengthy delays.

CMMC 2.0 Rollout Has Effectively Begun

The federal government concluded its public comment period on Sept. 15, 2022, in compliance with the CMMC Assessment Process. This opens the door to voluntarily having a Third-Party Assessment Organization certify your defenses. Although there was speculation the final CMMC 2.0 version would take up to 24 months, the National Law Review indicates it could be released as soon as the first quarter of 2023.

“If DoD sticks to this new timeline, the CMMC requirements could begin appearing in solicitations as early as May 2023 (60 days after the rules are published). DoD also announced it plans to roll out the CMMC requirements in solicitations under a ‘phased approach.’ In particular, for phase one, when the CMMC requirement first starts appearing in solicitations, all offerors will be required to conduct a self-assessment (rather than have a third-party certification) and provide a positive affirmation of compliance,” the National Law Review reports. “Then, in phase two (with timing still to be determined), solicitations will require either self-assessments or third-party certifications (depending on the type of CUI and required certification level).”

Contact Sedulous Consulting Services For CMMC 2.0 Compliance

Based in Triangle, Virginia, Sedulous Consulting Services ranks among the first 100 organizations to qualify as a Third-party Assessment Organization. We work diligently with small and mid-sized businesses to assess their cybersecurity vulnerabilities, secure their network defenses, and meet the stringent CMMC 2.0 requirements. If your company enjoys profits from a military contract or works in the supply chain, contact Sedulous Consulting Services.

After decades of miscues and rival countries stealing U.S. military intelligence, the federal government effectively drew a line in the sand. The development of the Cybersecurity Maturity Model Certification (CMMC) was to be the single standard that all military contractors and supply chain businesses followed. Previously CMMC 1.0 was the required certification version until CMMC 2.0 was recently announced and released. 

But changes in the Pentagon and White House resulted in revisions of the initial CMMC standards and delayed implementation. To say this has also created confusion among organizations in the military-industrial base would be something of an understatement. Proactive industry leaders were quick to have their cybersecurity defenses assessed and updated to meet what seemed like an imminent CMMC 1.0 mandate. As the rollout date for CMMC 2.0 nears, decision-makers are trying to come to grips with the differences between CMMC 1.0, and 2.0, to maintain their lucrative Department of Defense (DoD) contracts.

Why DoD Requires CMMC 2.0

To understand CMC 2.0, it’s essential to know why the federal government decided to bring wide-reaching cybersecurity regulations under one umbrella. Before the CMMC initiative, contractors and peripheral businesses were largely given the latitude to self-assess their cybersecurity compliance.

Needless to say, not everyone maintained an adequate defensive posture, and hackers funded by America’s enemies breached systems and routinely pilfered off Controlled Unclassified Information (CUI). This data could be found in contracts, invoices, and electronic messages between outfits in the supply chain. Advanced persistent threats — working for countries such as Russia, Iran, and China — would piece CUI together to learn about our confidential national security defenses.

“A determined adversary with the right capabilities is going to find their way in, especially if they put all their resources to bear on it. So, it really comes down to, have you done everything you possibly can, have you been truthful about it,” Karlton Johnson, chair of the CMMC Accreditation Body board of directors, reportedly said. “One of the reasons we are doing CMMC is, people were not being truthful about it. If we go in and find out that you were not doing something, that’s negligence and we have to go that route.”

Back then, the federal government would fine or suspend negligent companies. As if adding insult to these injuries, foreign spies infiltrated the Solar Winds software used at almost every level of government as CMMC 1.0 was nearing its final stages. It was a cybersecurity and national defense nightmare.

How Does CMMC 2.0 Work?

CMMC sets a singular, unified standard that more than 300,000 organizations in the military-industrial base must follow. The CMMC 2.0 guidelines involve a three-tiered system that set cybersecurity controls for companies that fall into a particular category.

The DoD refers to the three groups as Foundational, Advanced, and Expert levels. Each adopts defensive strategies from existing policies such as NIST SP 800-171 and NIST SP 800-172 subsets, among others. It’s not necessarily important for business professionals to know the ins and outs of NIST or even CMMC 2.0 for that matter. But it’s crucial to have a cybersecurity firm with CMMC expertise test, assess, and update your network to meet the incoming mandate. Failing to gain certification or maintain a robust posture could result in your company getting sidelined.

What are the Key Differences Between CMMC 2.0 and 1.0?

The glaring difference between the two measures is that CMMC 1.0 was going to be rolled out with five levels. The 2.0 version reduces that number to three. Although the latest version has fewer tiers, it remains equally complex for people outside the managed IT cybersecurity niche to fully appreciate. That being said, these are the CMMC 1.0 and 2.0 levels, respectively.

CMMC 1.0 Levels

• Level 1: Basic Cyber Hygiene that involves using most current antivirus software, firewalls, and a company-wide cybersecurity policy in place.
• Level 2: Intermediate Cyber Hygiene that involves implementing NIST standards to protect CUI.
• Level 3: Good Cyber Hygiene required 72 practices to be in place to earn certification. Organizations must also create a plan that demonstrates best practices and training.
• Level 4: Proactive Cyber Hygiene typically applies to military contractors who previously followed DFARS protocols, among others. The organization must demonstrate it can identify and repel advanced persistent threats.
• Level 5: Advanced Cyber Hygiene primarily for direct DoD contractors that requires sophisticated methods for identifying and responding to advanced persistent threats in real-time.

One of the challenges business professionals faced was determining which level applied to their company and meet that standard. Although CMMC 2.0 streamlines the tiers, it creates some confusion about certification methods.

CMMC 2.0 Levels

• Foundation: Loosely considered the equivalent of CMMC 1.0 Level 1, businesses must adhere to 15 controls to safeguard contractor information.
• Advanced: Organizations that store or transmit CUI must adhere to 110 controls to protect CUI. This level has been a pain point for companies because it involves different ways to maintain certification.
• Expert: Consistent with Level 5 of CMMC 1.0, companies must be able to detect, repel, and respond to advanced persistent threats. The controls in the Advanced tier rank among the most stringent 134 cybersecurity measures.

Going forward, companies working in the military-industrial base will be required to maintain CMMC 2.0 standards and demonstrate that to the federal government. The DoD is no longer interested in doling out fines after the fact. Advanced proof of CMMC 2.0 is now the standard.

Contact Sedulous Consulting Services For CMMC 2.0 Compliance

Based in Triangle, Virginia, Sedulous Consulting Services ranks among the first 100 organizations to qualify as a Third-party Assessment Organization. We work diligently with small and mid-sized businesses to assess their cybersecurity vulnerabilities, secure their network defenses, and meet the stringent CMMC 2.0 requirements. If your company enjoys profits from a military contract or works in the supply chain, contact Sedulous Consulting Services.

The long-awaited Cybersecurity Maturity Model Certification (CMMC) has effectively arrived, and the federal government is encouraging voluntary assessments from a Third-Party Assessment Organization ahead of full implementation. The U.S. Department of Defense (DoD) completed a major rule-making phase on Sept. 15, which is expected to fast-track CMMC 2.0 into government contracts which that CMMC Compliance Requirements are important to understand. 

That being said, the three levels of cyber hygiene mandated by CMMC 2.0 can prove challenging for small and medium-sized businesses. The stringent regulations have companies that enjoy revenue as contractors and subcontractors implementing cybersecurity controls numbering from 15 to 134. Organizations will also face hurdles in terms of developing a policy that articulates best practices and educates employees about cybersecurity awareness.

Proactive business professionals are taking steps now to avoid getting put on waiting lists when a bottleneck of companies reaches out to comply during the eleventh hour. Sedulous Consulting Services qualified as a Third-Party Assessment Organization early in the process so that our CMMC experts could help shepherd businesses through the process. In The How-To Guide to CMMC Compliance Requirements, we provide insight and tips on CMMC 2.0 Compliance Requirements. 

What are the CMMC 2.0 Requirements?

There are different types of compliance requirements assigned to organizations based on the information they store and transmit. These typically include Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). The former poses a limited national security risk and companies that manage FCI can expect less rigorous — although complex — cyber hygiene requirements.

By contrast, CUI tends to involve a wide range, and some pose a significant threat should the data fall into the hands of a rogue nation. Determining which of the three CMMC 2.0 levels an organization must comply with remains the first hurdle. Following an assessment regarding the FCI and CUI your operation handles, the following requirements may be applicable.

• Level 1: Considered “Basic” cyber hygiene by the DoD, companies that primarily handle FCI fall under its requirements. The level1 CMMC mandate is expected to include 15-17 security controls and 6 covering domains. The controls breakdown relates to the following: Access (4), Identification and Authentication (2), Media Protection (1), Physical Protection (4), System and Communication Protections (2), and 4System and Information Integrity (4).
• Level 2: Touted as “Advanced” cyber hygiene, companies working with a combination of FCI and CUI can anticipate meeting 110 control and 14 domain requirements. Some rank among the most determined forms of cybersecurity, and they pertain to the following: Access Control (22), Awareness Training (3)Audit and Accountability (9), Configuration Management (9), Identification and Authentication (11), Incident Response (3) Maintenance (6), Media Protection (9), Personnel Security (2), Physical Protection (6), Risk Assessment (3), Security Assessment (4), System and Communications Protection (16), and System and Information Integrity (7).
• Level 3: Direct military contractors and those who handle high-level CUI can expect to meet “Expert” cyber hygiene requirements. The cybersecurity of DoD contractors is expected to be hard enough to identify, deter, and repel threats from enemy nations. This will entail more than 130 defense items that include the following: Access Control (8), Asset Management (1), Audit and Accountability (7), Awareness Training (1), Configuration Management (3), Identification and Authentication (4), Incident Response (2) Maintenance (2), Media Protection (4), Personnel Security (6), Physical Protection (6), Recovery (3), Risk Assessment (3), Security Assessment (2), Situational Awareness (1), System and Communications Protection (15), and System and Information Integrity (3).

Businesses on tight IT budgets might have considered in-house assessments as a cost-effective way to comply. Given the number of cybersecurity controls and the complexity of these defenses, it may be prudent to work with a third-party cybersecurity firm with CMMC expertise.

Key Steps to Achieving CMMC Compliance Requirements

Meeting the federal mandate allows businesses to remain in the military-industrial base and generate profits from the often lucrative DoD contracts. The compliance process can be relatively seamless when performed by a CMMC professional. These are the general steps needed to meet the inbound CMMC regulations.

• Identify Data: Review the information your organization stores or transmits and determine whether it is FCI or CUI. If it’s CUI, further analysis may be necessary to align it with one of the three cyber hygiene levels.
• Readiness Assessment: Conduct a thorough audit of your network to identify cybersecurity vulnerabilities. Document the findings and create a plan to cure the gaps.
• Test System: Enlist the support of a Third-Party Assessment Organization to conduct a trial run before the CMMC requirements come online. This provides an opportunity to take corrective measures and earn certification ahead of schedule.
• Cybersecurity Plan: Updates your organization’s best practices, response strategies, and technologies required to meet CMMC demands. It’s also crucial to incorporate cybersecurity awareness training to educate frontline employees about existing and emerging threats.

The DoD has made it abundantly clear that all 300,000 businesses in the military-industrial base will meet the CMMC requirements or find themselves out of the loop. Taking proactive measures before the regulations are part of the process better positions your operation to bid on contracts and generate revenue as a subcontractor.

Contact Sedulous Consulting Services For CMMC 2.0 Compliance

Based in Triangle, Virginia, Sedulous Consulting Services ranks among the first 100 organizations to qualify as a Third-party Assessment Organization. We work diligently with small and mid-sized businesses to assess their cybersecurity vulnerabilities, secure their network defenses, and meet the stringent CMMC 2.0 requirements. If your company enjoys profits from a military contract or works in the supply chain, contact Sedulous Consulting Services.