Author Archives: Jimmy Lamon CCIE #46581

About Jimmy Lamon CCIE #46581

Director of Cyber-security and Compliance (CISO) Please visit me at my LinkedIn Profile for more information: https://www.linkedin.com/in/jimmylamonccie46581/

Defense Federal Acquisition Regulation Supplement: Assessing Contractor Implementation of Cybersecurity Requirements

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The Department of Defense (DoD) has proposed a critical amendment to the Defense Federal Acquisition Regulation Supplement (DFARS), aimed at bolstering cybersecurity measures across the defense industrial base. This change will significantly impact contractors working with the DoD, introducing new assessment and compliance requirements.

Key Policy Changes and Objectives

The proposed rule seeks to:

  1. Implement a unified cybersecurity standard across the defense industrial base
  2. Enhance protection of controlled unclassified information (CUI)
  3. Establish a robust assessment framework to evaluate contractor cybersecurity practices

These changes are designed to create a more secure and resilient defense supply chain, addressing the growing threats in the digital landscape.

Implementation Timeline

The DoD is moving swiftly to fortify its cybersecurity posture:

  • Public comment period: Open until October 14, 2024
  • Expected implementation: Early 2025 (subject to review process)

Contractors are urged to start preparing immediately to ensure compliance when the rule takes effect.

Who’s Affected?

This rule will impact:

  • Prime contractors working directly with the DoD
  • Subcontractors handling CUI
  • Small businesses in the defense supply chain

Attention contractors: Your cybersecurity practices will be under increased scrutiny!

Penalty Provisions: A Word of Caution

The DoD is taking a firm stance on cybersecurity compliance:

  • Financial penalties for non-compliance or false reporting
  • Potential contract termination for severe or repeated violations
  • Exclusion from future contracts for unaddressed security gaps

⚠️ The message is clear: cybersecurity is not optional, it’s essential.

Navigating Compliance: Your Roadmap to Success

To meet these new requirements, contractors should:

  1. Conduct a self-assessment using the DoD’s Supplier Performance Risk System (SPRS)
  2. Implement necessary cybersecurity controls based on NIST SP 800-171
  3. Prepare for third-party assessments, which may be required for certain contracts
  4. Maintain ongoing compliance through regular audits and updates

Remember: Proactive compliance isn’t just about avoiding penalties—it’s about building trust and securing future opportunities with the DoD.

Potential Impacts: Challenges and Opportunities

While these changes may seem daunting, they also present opportunities:

  • Enhanced competitiveness for compliant contractors
  • Improved overall security posture, benefiting your entire organization
  • Potential for new business as the DoD prioritizes cybersecure partners

By embracing these changes, contractors can position themselves as leaders in a more secure defense industrial base.

Learn more about the proposed rule

Are you ready to elevate your cybersecurity game? Start preparing today to ensure you’re not left behind in this new era of defense contracting.

 

 

    Essential Privileged Access Management Requirements

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    Essential Privileged Access Management Requirements for Government Compliance


    In the digital age, government agencies find themselves in a constant battle to safeguard sensitive information from cyber threats. Privileged access management has become a linchpin in this struggle, serving as a crucial shield against potential breaches and unauthorized access. As cyber attackers grow increasingly sophisticated, the need to implement robust privileged access management requirements has skyrocketed, prompting agencies to reassess their cybersecurity strategies and adopt a zero-trust approach.

    This article delves into the essential components of privileged access management for government compliance. It explores critical features that agencies must consider bolstering their security posture, including least privilege principles and risk management techniques. The piece also sheds light on common hurdles in putting privileged access management into action within government settings and offers practical insights to overcome these challenges. By the end, readers will have a clearer understanding of how to align their privileged access management practices with regulatory requirements and industry best practices.

    Critical PAM Features for Government Agencies

    In the digital age, government agencies face constant threats to their sensitive information. Privileged Access Management (PAM) has become a crucial shield against potential breaches and unauthorized access. Let’s explore some essential PAM features that government agencies must consider to bolster their security posture.

    Privileged Account Discovery and Management

    Imagine a vast network of interconnected systems, each with its own set of keys. Now, picture trying to keep track of all those keys without a proper system in place. That’s the challenge government agencies face with privileged accounts.

    Privileged account discovery is like a high-tech treasure hunt, aiming to uncover accounts that might be flying under the radar. This process should cover all environments, from Windows and Unix/Linux to databases, applications, and even cloud platforms [1]. It’s not just about finding the obvious; it’s about rooting out those sneaky group, orphaned, rogue, and default accounts that might be lurking in the shadows.

    Once discovered, these accounts need to be brought under management. This involves:

    1. Establishing a comprehensive privilege management policy
    2. Enforcing least privilege principles
    3. Implementing dynamic, context-based access

    By doing so, agencies can significantly reduce their attack surface and mitigate the risk of privileged account abuse [2].

    Just-in-Time Access

    Just-in-Time (JIT) access is like a VIP pass that only works for a limited time. Instead of giving users an all-access backstage pass, JIT access provides elevated privileges only when needed and for a specific duration [3].

    Here’s how it works:

    1. Users request access for a specific task
    2. The system grants temporary elevated privileges
    3. Once the task is complete, access is automatically revoked

    This approach offers several benefits:

    Benefit

    Description

    Reduced Risk

    Minimizes the window of opportunity for attackers

    Improved Compliance

    Simplifies auditing by providing full audit trails

    Enhanced Efficiency

    Automates the approval process, reducing wait times

    JIT access is particularly useful for managing third-party access and service accounts, ensuring that privileged access is granted only when necessary and for the shortest time possible [4].

    Behavioral Analytics and Threat Detection

    In the world of cybersecurity, knowing what’s normal is key to spotting what’s not. That’s where behavioral analytics comes into play. By leveraging artificial intelligence (AI) and machine learning (ML), PAM solutions can create baseline user behavior patterns for privileged users and accounts [5].

    This advanced feature allows agencies to:

    1. Continuously monitor privileged systems in real-time
    2. Identify and flag anomalous activities
    3. Perform root cause analysis using forensic data

    For instance, if a privileged user suddenly attempts to access systems from an unusual location or at an odd hour, the system can automatically flag this behavior for review [6].

    By integrating User Behavior Analytics (UBA) with PAM solutions, government agencies can gain deeper insights into potentially malicious activities. This proactive approach enables security teams to spot and suspend suspicious actions before they escalate into full-blown security incidents [5].

    Overcoming PAM Implementation Challenges in Government

    Implementing Privileged Access Management (PAM) in government agencies is like trying to renovate a centuries-old castle while it’s still in use. It’s a delicate balance of preserving the old while introducing the new. Let’s explore some of the hurdles and how to leap over them with the grace of an Olympic hurdler.

    Legacy System Integration

    Picture a government IT system as a patchwork quilt, with each patch representing a different era of technology. Integrating a modern PAM solution into this colorful tapestry can be quite the challenge. Legacy systems often resist change like a stubborn mule, making it difficult to deploy new security measures.

    To tackle this, agencies should look for PAM solutions that play nice with existing infrastructure. A good PAM solution should be like a chameleon, adapting to its environment without causing a ruckus. It should integrate seamlessly with directories, multi-factor authentication mechanisms, single sign-on solutions, and other IT tools [7].

    Here’s a checklist for smooth integration:

    1. Choose a solution that’s FedRAMP Authorized for easier procurement [8].
    2. Opt for cloud-based solutions to reduce maintenance headaches [8].
    3. Look for agentless solutions to simplify deployment in high-security environments [8].
    4. Prioritize solutions that centralize management of legacy software [7].

    User Adoption and Training

    Introducing a new PAM system can be like teaching an old dog new tricks – it takes patience, persistence, and plenty of treats. The key to success lies in making the transition as smooth as butter on a hot pancake.

    To boost user adoption:

    1. Start small: Begin with teams you trust, then expand like ripples in a pond [9].
    2. Communicate, communicate, communicate: Explain changes clearly and frequently [9].
    3. Simplify the jargon: Break down complex terms into bite-sized, easily digestible pieces [9].
    4. Choose user-friendly solutions: Look for platforms that users find as intuitive as their favorite smartphone apps [7].

    Remember, a successful PAM implementation is like a well-choreographed dance – it requires coordination between various IT teams, from directory services to server build teams [9].

    Continuous Monitoring and Improvement

    Implementing PAM isn’t a “set it and forget it” kind of deal. It’s more like tending to a garden – it needs constant care and attention to flourish. Continuous monitoring and improvement are crucial to maintaining a robust PAM system.

    Here’s how to keep your PAM system in tip-top shape:

    1. Perform regular security assessments to stay ahead of new threats [10].
    2. Update security documentation to keep it as fresh as morning dew [10].
    3. Implement strong configuration management and change control processes [10].
    4. Develop and maintain an incident response plan that’s ready for action at a moment’s notice [10].

    By embracing these strategies, government agencies can overcome the challenges of PAM implementation and create a secure, efficient system that’s as solid as a rock and as flexible as a gymnast. Remember, in the world of cybersecurity, standing still is moving backward – so keep evolving, adapting, and improving!

    Conclusion

    As government agencies grapple with ever-evolving cyber threats, the adoption of robust Privileged Access Management (PAM) practices has become crucial to safeguard sensitive information. The implementation of essential PAM features, such as privileged account discovery, just-in-time access, and behavioral analytics, has a significant impact on enhancing security postures and ensuring compliance with regulatory requirements. By embracing these features, agencies can minimize their attack surface, improve efficiency, and stay one step ahead of potential security breaches.

    To successfully implement PAM, government agencies must overcome challenges like integrating with legacy systems, fostering user adoption, and maintaining continuous improvement. The key to addressing these hurdles lies in choosing flexible solutions, prioritizing user-friendly interfaces, and committing to ongoing monitoring and refinement. By taking these steps, agencies can create a secure and efficient PAM system that adapts to changing threats and technologies, ultimately strengthening their overall cybersecurity stance.

    FAQs

    1. What are the essential features of a Privileged Access Management (PAM) system?
      A PAM system should include features that align with your established policies, such as automated password management and multifactor authentication. It is important that administrators can automate the creation, modification, and deletion of accounts to maintain security and efficiency.
    2. What should a Privileged Access Management system ideally prevent?
      A robust PAM system should ensure that privileged users do not know the actual passwords to critical systems and resources. This prevention helps avoid any manual overrides on physical devices. Instead, privileged credentials should be securely stored in a vault, away from direct user access.
    3. What does NIST 800-53 define in terms of privileged account management?
      According to NIST 800-53, privileged account management (PAM) is a vital component of a least privilege methodology. It involves managing and controlling access to privileged accounts, permissions, workstations, and servers to minimize the risk of unauthorized access, misuse, or abuse.
    4. What encompasses privileged access management according to NIST?
      Privileged access management (PAM), as defined by NIST, includes the cybersecurity strategies and technologies used to secure, monitor, and control privileged access accounts. These are user accounts that hold more privileges than ordinary user accounts, necessitating stricter controls and monitoring.

    References

    [1] – https://www.idmanagement.gov/playbooks/pam/
    [2] – https://www.beyondtrust.com/resources/glossary/privileged-access-management-pam
    [3] – https://www.cyberark.com/what-is/just-in-time-access/
    [4] – https://www.strongdm.com/blog/just-in-time-access
    [5] – https://www.manageengine.com/privileged-access-management/privileged-user-behavior-analytics.html
    [6] – https://www.cyberark.com/what-is/user-behavior-analytics/
    [7] – https://www.securden.com/privileged-account-manager/pam-for-federal-local-government-agencies.html
    [8] – https://www.keepersecurity.com/blog/2023/05/05/keeping-data-and-systems-secure-with-privileged-access-management/
    [9] – https://www.integralpartnersllc.com/video-pam-adoption-challenges-and-solutions/
    [10] – https://www.fedramp.gov/assets/resources/documents/CSP_Continuous_Monitoring_Strategy_Guide.pdf

     

    Why Government Estimates Underestimate CMMC Level 2 Costs

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    The true costs of CMMC Level 2 certification go beyond what meets the eye. From technological upgrades to human resource expenses, administrative tasks to third-party assessments, the financial implications are far-reaching. This article digs into why government estimates underestimate these costs, breaking down the often-overlooked aspects of compliance. It sheds light on the long-term maintenance expenses and the hidden challenges that CISOs face when implementing NIST SP800-171 requirements across various endpoints, including platforms like Azure GCC High.

    Overview of CMMC Level 2 Certification

    The Cybersecurity Maturity Model Certification (CMMC) Level 2 represents a significant step in safeguarding sensitive information within the Department of Defense (DoD) supply chain. This level focuses on advanced cyber hygiene, creating a logical progression from Level 1 to Level 3. It encompasses the protection of both Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) [1].

    Key Requirements

    CMMC Level 2 compliance involves implementing 110 controls across 15 domains, all derived from NIST 800-171 [1]. These controls are distributed as follows:

    1. Access Control (AC): 22 controls
    2. Audit and Accountability (AU): 9 controls
    3. Awareness and Training (AT): 3 controls
    4. Configuration Management (CM): 9 controls
    5. Identification and Authentication (IA): 11 controls
    6. Incident Response (IR): 3 controls
    7. Maintenance (MA): 6 controls
    8. Media Protection (MP): 9 controls
    9. Personnel Security (PS): 2 controls
    10. Physical Protection (PE): 6 controls
    11. Recovery (RE): 2 controls
    12. Risk Management (RM): 3 controls
    13. Security Assessment (CA): 4 controls
    14. System and Communications Protection (SC): 16 controls
    15. System and Information Integrity (SI): 7 controls

    Achieving compliance requires a comprehensive approach, including the implementation of policies and procedures, technical controls, and robust education and training channels [1].

    Assessment Process

    The assessment process for CMMC Level 2 involves Third Party Assessor Organizations (C3PAOs) accredited by the CMMC Accreditation Body (CMMC-AB) [1]. These organizations employ certified assessors to evaluate an organization’s cybersecurity practices and controls against the CMMC framework.

    The assessment includes:

    1. Review of existing security documentation
    2. Interviews with key personnel
    3. On-site inspections of systems and physical security

    After the assessment, the C3PAO provides a report on their findings, which is then submitted to the CMMC Accreditation Body for review, evaluation, and certification [1]. The Department of Defense will have access to the assessment results and final report, but these detailed results will not be made public [2].

    Timeline for Implementation

    While the exact implementation timeline for CMMC 2.0 is still evolving, it’s expected to be codified by the end of 2024 and incorporated into contracts in Q1 2025 [3]. However, it’s crucial to note that NIST 800-171, which forms the basis of CMMC, is already a requirement today.

    Organizations should not wait to begin their CMMC implementation plan. The path to compliance can be lengthy, involving several steps:

    1. Familiarizing with CMMC Level 2 requirements
    2. Conducting a comprehensive gap analysis
    3. Developing and implementing a remediation plan
    4. Allocating necessary resources
    5. Training staff on CMMC requirements and cybersecurity best practices
    6. Implementing required policies, procedures, and documentation
    7. Regularly reviewing and updating cybersecurity practices
    8. Engaging with CMMC consultants or C3PAOs for guidance
    9. Performing a self-assessment before the official CMMC assessment
    10. Scheduling the CMMC assessment with an accredited C3PAO [1]

    It’s important to note that while the DoD intends to allow companies to receive contract awards with a Plan of Actions and Milestones (POA&M) in place, there will be a baseline number of requirements that must be achieved prior to contract award [4]. Therefore, organizations should prioritize closing any security gaps to ensure they meet the minimum compliance requirements.

    Breaking Down the Government’s Cost Estimates

    The Department of Defense (DoD) has provided cost estimates for CMMC compliance, but these figures often fall short of the true expenses organizations face. To understand why, it’s crucial to examine the components included, calculation methods, and underlying assumptions in these estimates.

    Components Included

    The DoD’s cost estimates for CMMC compliance encompass several key components:

    1. Assessment Costs: These include initial assessments and recurring evaluations every three years.
    2. Affirmation Costs: Annual costs associated with affirming compliance.
    3. Implementation Costs: Expenses related to technical changes required to meet CMMC standards.
    4. Support Costs: Ongoing expenses for maintaining compliance, including staff and external service providers.

    For a Level 2 CMMC assessment, the DoD estimates the combined cost of assessment and affirmation to be around $104,670 [5]. This figure, however, doesn’t paint the full picture of compliance expenses.

    Calculation Methods

    The DoD’s calculation methods for CMMC costs vary based on the certification level and organization size:

    1. Level 1 Costs:
      • Small entities: Estimated at nearly $6,000
      • Larger entities: Approximately $4,000
    2. Level 2 Costs:
      • Small entities: Over $37,000 for self-assessment and affirmations
      • Larger entities: Nearly $49,000 for self-assessment and affirmations
      • Certification assessment: $104,670 for small entities, $118,000 for larger entities [5]
    3. Level 3 Costs:
      • Small organizations: $490,000 in recurring engineering costs, $2.7 million in non-recurring engineering costs
      • Larger organizations: $4.1 million in recurring engineering costs, $21.1 million in non-recurring engineering costs [5]

    These calculations attempt to account for organizational differences, such as IT infrastructure complexity and the likelihood of outsourcing cybersecurity services.

    Underlying Assumptions

    The government’s cost estimates are based on several key assumptions:

    1. Pre-existing Compliance: The DoD assumes that organizations have already implemented the security requirements mandated by FAR clause 52.204-21 and DFARS clause 252.204-7012 [5]. This assumption significantly impacts the estimated costs, as it doesn’t account for expenses related to achieving baseline compliance.
    2. Organizational Differences: The estimates consider that smaller firms generally have less complex IT and cybersecurity infrastructures and are more likely to outsource these services [5].
    3. External Support: The calculations anticipate that organizations pursuing Level 2 assessments will seek consulting or implementation assistance from external service providers [5].
    4. Hourly Rates: The DoD estimates that an experienced IT professional capable of supporting CMMC compliance efforts would cost around $86 per hour [6].
    5. Implementation Timeframe: The estimates assume that implementation could consume at least one person’s full-time job for 12-18 months [6].

    It’s important to note that these assumptions may not hold true for all organizations, leading to potential underestimation of actual costs. For instance, the annual full-time salary of an employee being paid $86.24 per hour would be around $179,000 [6], which is not explicitly factored into the government’s estimates.

    Technological Costs Often Overlooked

    When organizations pursue CMMC Level 2 certification, they often underestimate the technological costs involved. These expenses can significantly impact the overall budget and are frequently overlooked in initial assessments. Let’s delve into the key areas where technological costs tend to accumulate.

    Hardware Upgrades

    Many businesses find themselves needing to upgrade their infrastructure to meet the required security protocols set forth by CMMC 2.0 [7]. This can involve replacing outdated hardware that may not support the latest security features or adding new components to enhance system protection. The cost of these upgrades can vary widely depending on the organization’s current setup and the extent of changes needed.

    Software Licenses

    Implementing CMMC Level 2 requirements often necessitates the adoption of new software solutions or the upgrade of existing ones. This may include:

    1. Multi-factor authentication systems
    2. Encryption tools
    3. Vulnerability scanning software
    4. Incident response management platforms

    It’s crucial to ensure that any encryption software used is FIPS 140-2 compliant, as this is a specific requirement for handling Controlled Unclassified Information (CUI) [8]. The licensing costs for these software solutions can add up quickly, especially for larger organizations.

    Cloud Services

    Cloud services play a significant role in CMMC compliance, but they come with their own set of costs and considerations. For instance, many organizations consider using Microsoft’s Government Community Cloud (GCC) or GCC High for CMMC compliance. However, these solutions can be expensive and often require deployment across the entire organization [9].

    An alternative approach is to use cloud platforms specifically designed for CMMC compliance. For example, some solutions can be layered over existing systems like Microsoft 365, allowing organizations to protect CUI without a complete infrastructure overhaul [9]. This approach can be more cost-effective, especially for small and medium-sized businesses.

    It’s worth noting that the Department of Defense (DoD) estimates for CMMC compliance costs don’t fully account for these technological expenses. For instance, the DoD projects that a Level 2 certification assessment would cost nearly $105,000 for small entities and approximately $118,000 for larger entities [5]. However, these figures primarily cover assessment and affirmation activities, not the implementation of security requirements themselves [5].

    In reality, the technological costs can be substantial. For a small organization pursuing CMMC Level 3 (which builds upon Level 2), the estimated recurring and non-recurring engineering costs associated with meeting the security mandates are $490,000 and $2.7 million, respectively [5]. For larger organizations, these figures jump to $4.1 million and $21.1 million [5].

    While these numbers are for Level 3, they give an indication of the significant technological investments required even at Level 2. Organizations must carefully consider these often-overlooked technological costs when budgeting for CMMC compliance to avoid unexpected financial strain.

    Human Resource Expenses

    Human resource expenses often constitute a significant portion of the costs associated with achieving CMMC Level 2 compliance. These expenses encompass various aspects, including hiring cybersecurity experts, training existing staff, and providing ongoing education.

    Hiring Cybersecurity Experts

    Organizations pursuing CMMC Level 2 certification may find themselves in need of specialized cybersecurity expertise. The Department of Defense (DoD) estimates that small defense contractors will need to spend $104,670 to achieve CMMC Level 2 with a C3PAO assessment and submit annual affirmations of compliance [10]. This figure includes the costs associated with hiring cybersecurity professionals or consultants to guide the compliance process.

    For organizations lacking internal security expertise, outside partners can save time and money [11]. These experts can provide valuable assistance in conducting gap assessments, implementing necessary controls, and preparing for the CMMC audit. A gap assessment for an organization can cost approximately between $15,000 and $35,000 [10].

    Training Existing Staff

    Training existing staff is a crucial component of CMMC Level 2 compliance. The CMMC Assessment Guide emphasizes the importance of security awareness and training for all employees [12]. However, the extent of training may vary depending on the organization’s strategy for segmenting the Controlled Unclassified Information (CUI) scope.

    Organizations must implement a comprehensive training program that covers:

    1. Security awareness training for all users
    2. Cybersecurity essentials for all users of IT systems
    3. Role-based training for specific positions

    The training should encompass various topics, including:

    • Cybersecurity terms and concepts
    • Threats and vulnerabilities in the work environment
    • Policies and procedures to follow
    • Rules of acceptable use of information and information systems

    It’s important to note that awareness is not the same as training. While awareness presentations focus on broad topics, training involves a more active learner and focuses on building knowledge and skills to perform specific jobs [12].

    Ongoing Education

    CMMC Level 2 compliance requires ongoing education to maintain the organization’s cybersecurity posture. This includes:

    1. Regular cybersecurity audits
    2. Periodic network upgrades
    3. Continuous employee training to stay ahead of emerging threats [13]

    Organizations must establish a robust education and training channel to ensure personnel with appropriate clearances adequately understand their role in protecting the environment [1]. This ongoing education is crucial for maintaining compliance and adapting to evolving cybersecurity threats.

    The NICE Framework can be a valuable resource for organizations in structuring their ongoing education programs. It helps in describing the tasks performed, the people who carry them out, and the relevant training needed [12]. Organizations can use this framework to identify the knowledge, skills, and tasks associated with specific work roles, ensuring that their training programs are comprehensive and tailored to their needs.

    By investing in human resource expenses related to cybersecurity expertise, training, and ongoing education, organizations can build a strong foundation for CMMC Level 2 compliance. While these costs may be significant, they are essential for creating a robust cybersecurity posture and meeting the stringent requirements of the CMMC framework.

    Administrative and Documentation Costs

    Policy Development

    Organizations pursuing CMMC Level 2 certification must invest significant time and resources in developing comprehensive policies and procedures. These policies need to address the management of Contractor Risk Managed Assets, which are part of the CMMC Assessment Scope but are not required to be physically or logically separated from CUI Assets [14]. The development of risk-based information security policies, procedures, and practices for these assets is crucial, as they will be reviewed by assessors to ensure compliance [14].

    Record Keeping

    Proper documentation is a critical aspect of CMMC compliance and contributes significantly to administrative costs. Organizations are required to maintain detailed records, including:

    1. Asset inventory documentation
    2. System Security Plan (SSP) documentation
    3. Network diagrams of the assessment scope

    These documents must clearly show how Contractor Risk Managed Assets are managed using the organization’s risk-based security policies, procedures, and practices [14]. The cost of maintaining these records can be substantial, as it often requires dedicated personnel or external consultants.

    Audit Preparation

    Preparing for a CMMC audit involves considerable time and financial investment. For a Level 2 CMMC assessment, the Department of Defense estimates that the combined cost of assessment and affirmation will be around $104,670 [6]. This figure includes expenses related to planning and preparing for the assessment, conducting the assessment, and reporting the results [5].

    Organizations should anticipate the following costs associated with audit preparation:

    1. Gap assessments: A typical gap assessment for an organization with 250 employees can cost between $15,000 and $35,000 [10].
    2. Readiness assessments: These are more comprehensive than gap assessments and ensure that everything is in place from a CMMC perspective [10].
    3. Consulting costs: External expertise may be required to guide the compliance process [6].
    4. Internal resource allocation: Preparing for CMMC compliance can consume at least one person’s full-time job for 12-18 months, with an estimated annual salary of around $179,000 for an experienced IT professional [6].

    The actual CMMC audit costs, while not yet formally defined, are estimated to range between $20,000 and $60,000 [10]. This estimate assumes a fully defined audit program with standardized components such as questionnaires, information gathering processes, and specified reporting formats.

    It’s important to note that these administrative and documentation costs are ongoing. Organizations must factor in maintenance expenses, which include active monitoring, threat detection, and incident reporting between CMMC assessments [6]. The Department of Defense projects that the annualized costs for contractors and other non-government entities to implement CMMC 2.0 will be about $4 billion, calculated over a 20-year horizon [5].

    Third-Party Assessment Organization (C3PAO) Fees

    Initial Assessment Costs

    The implementation of CMMC Level 2 certification brings with it significant financial considerations, particularly in the realm of Third-Party Assessment Organization (C3PAO) fees. The Department of Defense (DoD) has estimated that small defense contractors will need to spend approximately $104,670 to achieve CMMC Level 2 with a C3PAO assessment and submit annual affirmations of compliance [11]. This figure encompasses various components of the assessment process, including planning and preparation, conducting the assessment, and reporting the results.

    Breaking down the costs, the DoD estimates that conducting the assessment itself accounts for the largest portion at $76,743. Planning and preparing for the C3PAO assessment is projected to cost $20,699, while reporting the assessment results is estimated at $2,851 [11]. It’s important to note that these figures include time spent by both in-house IT specialists and External Service Providers (ESPs) such as Registered Practitioners (RPs), Certified CMMC Assessors (CCAs), and C3PAOs.

    However, real-world scenarios suggest that the actual costs may vary significantly. Recent reports from contractors reveal that quotes received from C3PAOs for a Level 2 assessment under CMMC 2.0 ranged from $30,000 to $381,000 [15]. The wide range in pricing is largely attributed to the number of environments that need to be assessed independently, with the higher end of the spectrum involving five separate environments.

    Re-certification Expenses

    CMMC compliance is not a one-time expense. Contractors must be re-certified at regular intervals, adding to the long-term financial commitment. As it stands currently, CMMC certifications are generally valid for 3 years [10]. This means that organizations must factor in the costs of re-certification into their long-term budgeting.

    The DoD’s cost estimates include provisions for annual affirmations of compliance. Over a three-year period, these affirmations are expected to cost $4,377, or $1,459 per year [11]. These ongoing expenses are crucial for maintaining compliance and ensuring that an organization’s cybersecurity posture remains up to date with evolving threats and standards.

    Preparation Assistance

    Given the complexity and importance of CMMC certification, many organizations seek external assistance in preparing for their assessments. The DoD anticipates that organizations pursuing Level 2 assessments will often seek consulting or implementation assistance from external service providers [5]. This additional support can help organizations get ready for assessments and participate effectively in the process with C3PAOs.

    While this preparation assistance represents an additional cost, it can be a valuable investment. Proper preparation can help minimize billable hours during the actual assessment, which ultimately determines the final price. To this end, organizations are advised to pair their documentation carefully, linking it to scoped information systems and assessment objectives [15]. Utilizing solutions that track required practice performance and store evidence can streamline this process and potentially reduce overall costs.

    Long-Term Compliance Maintenance Expenses

    Maintaining CMMC Level 2 compliance is an ongoing process that requires significant long-term investment. Organizations must factor in recurring costs to ensure their cybersecurity posture remains up to date with evolving threats and standards. The Department of Defense projects that the annualized costs for contractors and other non-government entities to implement CMMC 2.0 will be about $4 billion, calculated over a 20-year horizon [5].

    Continuous Monitoring Tools

    Implementing and maintaining continuous monitoring tools is a crucial aspect of long-term compliance. These tools help organizations detect vulnerabilities in real-time, collect evidence for corrective actions, and offer ready-to-use security policies [16]. Continuous monitoring is essential for maintaining a robust security posture and ensuring ongoing compliance with CMMC Level 2 requirements.

    Regular System Updates

    Regular system updates and patching are critical components of long-term compliance maintenance. Organizations must factor in the costs associated with:

    1. Upgrading existing systems
    2. Patching vulnerabilities
    3. Implementing new tools as required [16]

    These ongoing maintenance activities are essential for addressing new security threats and ensuring that the organization’s cybersecurity measures remain effective over time.

    Incident Response Planning

    Developing and maintaining an incident response plan is a key requirement for CMMC Level 2 compliance. Organizations must have procedures in place for:

    1. Monitoring and promptly acting on security alerts indicating unauthorized use of IT systems
    2. Performing periodic scans of IT systems
    3. Scanning files from external sources when they are downloaded or acted upon
    4. Updating malicious code protection mechanisms as soon as new versions are available [1]

    The costs associated with maintaining an effective incident response capability, including regular testing and updates to the plan, must be factored into long-term compliance expenses.

    It’s important to note that while the initial certification costs for CMMC Level 2 are significant, with the Department of Defense estimating around $104,670 for small defense contractors [11], the long-term maintenance expenses can be even more substantial. Organizations must budget for recurring costs, as CMMC certifications are generally valid for 3 years [10]. This means that companies must plan for re-certification expenses every three years, in addition to the ongoing costs of maintaining compliance.

    To optimize long-term compliance costs, organizations should consider:

    1. Establishing clear communication and project scopes with consultants
    2. Negotiating fee structures for ongoing support
    3. Researching and selecting cost-effective technology solutions that fulfill CMMC requirements without exerting undue strain on the budget [17]

    By taking a strategic approach to long-term compliance maintenance, organizations can better manage the ongoing expenses associated with CMMC Level 2 certification while ensuring they maintain a robust cybersecurity posture.

    Conclusion

    The journey to achieve CMMC Level 2 certification has a significant impact on organizations, both financially and operationally. Government estimates often fall short of capturing the true costs, which encompass not only initial assessments but also ongoing expenses for technology upgrades, staff training, and long-term compliance maintenance. These hidden costs can put a strain on businesses, especially smaller contractors, as they work to meet the stringent cybersecurity requirements.

    To wrap up, while CMMC Level 2 certification is crucial to protect sensitive information, organizations need to plan carefully to manage the associated expenses. This means looking beyond the initial certification costs to consider the long-term investment in cybersecurity infrastructure, human resources, and continuous improvement. By taking a comprehensive approach to budgeting and implementation, businesses can better prepare themselves to meet the challenges of CMMC compliance while maintaining their competitive edge in the defense contracting landscape.

     

    Cloud Provider Cloudzy found supporting ransomware groups and state-sponsored cyberattacks

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    As the threat landscape continues to evolve, businesses face an ever-increasing risk of falling victim to cyberattacks. One such threat actor, Cloudzy, has been unmasked as a provider of command-and-control services to numerous hacking groups, including ransomware operators, spyware vendors, and state-sponsored APT actors. In this article, we will explore the role of a virtual Chief Information Security Officer (vCISO) in protecting organizations against threat actors like Cloudzy.

    Understanding the Threat: Cloudzy’s Illicit Operations

    Cloudzy, an Iranian-run company registered in the United States, has been identified as a key facilitator of cyberattacks. This hosting provider acts as a command-and-control provider (C2P) for various threat actors, offering services that protect user anonymity and enable malicious activities. Despite the company’s terms and conditions prohibiting illicit activities, it is complicit in supporting ransomware groups and state-sponsored cyberattacks.

    The Impact of Cloudzy’s Activities

    Cloudzy’s activities have far-reaching implications for organizations and governments worldwide. By providing a platform for malicious actors to orchestrate their attacks, Cloudzy enables the execution of ransomware operations, espionage campaigns, and other cybercrimes. The consequences of such attacks can be devastating, resulting in financial losses, reputational damage, and compromised sensitive information.

    The Importance of Collaboration: Trusted Advisors and Threat Intelligence

    In the battle against threat actors like Cloudzy, collaboration and access to timely threat intelligence are crucial. Organizations need trusted advisors who can provide research and warnings against bad actors, enabling them to stay one step ahead in the ever-changing threat landscape.

    The Role of Threat Intelligence: Staying Ahead of the Game

    Threat intelligence plays a pivotal role in defending against threat actors like Cloudzy. By continuously monitoring the threat landscape, analyzing emerging trends, and identifying indicators of compromise, organizations can proactively mitigate risks. A vCISO, armed with threat intelligence, can develop effective strategies to counter the evolving tactics and techniques employed by threat actors.

    Protecting Against Cloudzy and Beyond: Defense in Depth

    To protect against threat actors like Cloudzy, organizations must adopt a defense-in-depth approach. This approach involves implementing multiple layers of security controls to safeguard critical assets. These layers can include network segmentation, strong access controls, endpoint security solutions, and continuous monitoring and threat hunting.

    The Human Element: Training and Culture

    While technological solutions play a crucial role in defending against threat actors, the human element cannot be overlooked. Training employees to be vigilant, promoting a culture of cybersecurity awareness, and fostering a sense of shared responsibility for protecting the organization’s digital assets are essential components of a comprehensive cybersecurity strategy.

    Atlantic Digital vCISO Services: Expertise in Cybersecurity

    In the face of evolving cyber threats, organizations require a comprehensive cybersecurity strategy to safeguard their digital assets. Threat actors like Cloudzy pose significant risks to businesses and governments alike. By engaging a vCISO, organizations can benefit from expert guidance, proactive risk management, and access to threat intelligence. A vCISO plays a crucial role in this strategy, providing organizations with the expertise and guidance needed to protect against threat actors like Cloudzy. They are virtual executives who possess a deep understanding of cybersecurity best practices, threat intelligence, and risk management. Atlantic Digital, with its team of cybersecurity experts and extensive network of collaborators, offers the necessary expertise to keep organizations informed and protected. For more information, please contact us or comment below.

    Remember, cybersecurity is a continuous journey, and organizations must remain vigilant, adaptable, and well-prepared to defend against the evolving tactics and techniques employed by threat actors. With the right strategies, collaboration, and expertise, organizations can mitigate the risks posed by threat actors like Cloudzy and safeguard their digital assets.

    Moving Towards a Secure Future: The U.S. Government’s Journey to Zero Trust Cybersecurity Principles

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    Introduction

    With the digital age in full swing, cybersecurity has become a paramount concern for governments worldwide. The U.S. Federal Government is no exception. In fact, it has taken proactive steps towards fortifying its defenses against increasingly sophisticated cyber threats. One such initiative is the adoption of the Zero Trust Architecture (ZTA), a strategy aimed at reinforcing the nation’s defenses against cyber threats.

    A Preamble on Zero Trust

    The essence of Zero Trust lies in its name – it embodies a principle of ‘never trust, always verify.’ The concept assumes that no user, system, or service, whether inside or outside the security perimeter, is trustworthy. Instead, it insists on continual verification of every attempt to establish access.

    The Federal Mandate: Zero Trust Architecture (ZTA) Strategy

    The U.S. Federal Government, through a memorandum from the Office of Management and Budget (OMB), has set forth a strategic plan to implement the ZTA by the end of Fiscal Year 2024. This move is not only aimed at reinforcing the Government’s defenses against cyber threats but also at mitigating potential damages to the American economy, public safety, privacy, and the trust in Government.

    Unfolding the Strategy: The Pillars of Zero Trust

    The strategy to implement Zero Trust is based on five complementary areas of effort, referred to as the ‘pillars’ of Zero Trust. These include Identity, Devices, Networks, Applications and Workloads, and Data. Across these areas, three themes cut through – Visibility and Analytics, Automation and Orchestration, and Governance.

    Identity: The Basis of Zero Trust

    In the Zero Trust model, identity forms the foundation of all security measures. The strategy mandates that agency staff use enterprise-managed identities for accessing the applications necessary for their work. Phishing-resistant multi-factor authentication (MFA) must be implemented for all staff, contractors, and partners. Public-facing systems must also provide phishing-resistant MFA as an option for users.

    Devices: Ensuring Security at the Endpoint

    The strategy demands that agencies maintain a complete inventory of every device authorized and operated for official business, and have measures in place to prevent, detect, and respond to incidents on those devices.

    Networks: From Perimeter-Based to Perimeter-Less Security

    In the current threat environment, perimeter-based defenses are no longer sufficient. As part of the Zero Trust model, all traffic, including internal traffic, must be encrypted and authenticated. This implies that agencies need to encrypt all DNS requests and HTTP traffic within their environment.

    Applications and Workloads: A New Approach to Security

    In the Zero Trust model, applications and workloads are treated as internet-connected entities. Agencies are expected to operate dedicated application security testing programs, and welcome external vulnerability reports for their internet-accessible systems.

    Data: The Lifeblood of the Organization

    In the context of Zero Trust, agencies are expected to be on a clear, shared path to deploy protections that make use of thorough data categorization. They should take advantage of cloud security services and tools to discover, classify, and protect their sensitive data, and have implemented enterprise-wide logging and information sharing.

    A Roadmap to Implementation

    The transition to a Zero Trust architecture is neither quick nor easy. It requires a concerted, government-wide effort. To guide this process, each agency is required to develop a Zero Trust architecture roadmap describing how it plans to isolate its applications and environments.

    The Role of IPv6

    The transition to Internet Protocol version 6 (IPv6) is another critical aspect of the strategy. IPv6 supports enhanced security features and is designed to facilitate seamless integration with the Zero Trust model. It is, therefore, crucial that agencies coordinate the implementation of their IPv6 transition with their migration to a Zero Trust architecture.

    The Journey Ahead

    The implementation of the Zero Trust model is not an end in itself. It is part of the Federal Government’s broader vision for a secure, resilient, and technologically advanced nation. The journey towards this vision is ongoing. It requires continuous learning, adaptation, and innovation. But with a clear strategy in place and a concerted effort from all stakeholders, the U.S. Federal Government is poised to successfully navigate this journey, ensuring the safety and security of the American people in the digital age.

      The Evolution of NIST SP800-171: What You Need to Know About Revision 3

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      Introduction

      In the ever-evolving landscape of cybersecurity, staying up-to-date with the latest frameworks and regulations is crucial to protect sensitive information. One such framework is the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171, which outlines requirements for protecting controlled unclassified information (CUI). NIST recently released a draft of Revision 3 (Rev. 3) of SP 800-171, introducing significant changes that organizations need to be aware of. In this article, we will delve into the key modifications and additions proposed in Rev. 3 and discuss their potential impact on the defense supply chain and the Cybersecurity Maturity Model Certification (CMMC) program.

      The Origins and Purpose of SP 800-171

      To understand the significance of Rev. 3, let’s take a brief look at the origins and purpose of SP 800-171. Initially created in December 2016, SP 800-171 was developed as a derivative of controls and requirements found in Federal Information Processing Standard (FIPS) 200 and NIST SP 800-53. Its purpose was to provide federal agencies with recommended security requirements for protecting CUI when it resides in nonfederal systems and organizations.

      Enhanced Clarity and Specificity

      One of the notable changes introduced in Rev. 3 is the enhanced clarity and specificity of the security requirements. The distinction between “Basic” and “Derived” security requirements, present in previous versions, has been eliminated. Instead, NIST has opted to rely on the requirements of SP 800-53 to enhance the specificity of existing controls. This consolidation allows for a clearer understanding of the controls and simplifies compliance efforts for organizations.

      For example, a requirement in Rev. 2 addressing Media Protection directed contractors to prohibit the use of portable storage devices without an identifiable owner. In Rev. 3, this requirement has been folded into the existing requirement for Media Use, which now allows organizations to either restrict or prohibit the use of organization-defined removable system media. This consolidation and reorganization of requirements aim to streamline compliance efforts and improve the overall effectiveness of the framework.

      Organization-Defined Parameters (ODPs)

      Rev. 3 introduces a new concept called Organization-Defined Parameters (ODPs). While already used in NIST SP 800-53, ODPs are now incorporated into 53 of the 110 Security Requirements in Rev. 3. These parameters allow organizations to define specific elements of a requirement based on their own risk assessment and security needs.

      For instance, in the Access Control requirement, Rev. 2 simply stated to limit unsuccessful logon attempts. In Rev. 3, this requirement includes ODPs, specifying that organizations should limit the number of consecutive invalid logon attempts by a user within an organization-defined time period. This addition of ODPs enhances flexibility in meeting the requirements while ensuring that organizations address the specific security needs of their systems.

      Encryption Is Now an ODP

      The use of encryption to protect the confidentiality of CUI has always been a critical requirement. However, Rev. 3 introduces an ODP approach to encryption, providing organizations with the flexibility to choose the types of cryptography that best suit their needs. Previously, Rev. 2 mandated the use of FIPS-validated cryptography. However, based on feedback received during the comment period, NIST has revised this requirement.

      In Rev. 3, organizations are now required to implement organization-defined types of cryptography to protect the confidentiality of CUI. This change allows organizations to tailor their cryptographic solutions based on their risk assessments and specific security requirements. While this flexibility is welcomed, organizations should ensure that their chosen cryptography aligns with industry best practices and provides an adequate level of protection.

      Policies and Procedures Are Required

      Another significant change in Rev. 3 is the explicit requirement for organizations to establish and maintain policies and procedures. While previous versions of SP 800-171 assumed the existence of these policies and procedures, Rev. 3 now mandates their implementation. This change aims to ensure that organizations have documented processes and guidelines in place to support their cybersecurity programs.

      Organizations should review their current policies and procedures to ensure they align with the new requirements. This includes policies and procedures for each security family, rules of behavior, and acceptable use policies. Additionally, organizations should ensure that external system service providers comply with their security requirements, as this is now explicitly stated in Rev. 3.

      Software Producers and MSPs Beware

      With the increasing reliance on software and managed service providers (MSPs), Rev. 3 addresses the need to manage supply chain risks and ensure the security of system components. The new requirements in Rev. 3 include a focus on supply chain risk management and the development or acquisition of new system components.

      These additions align with the growing concerns around software vulnerabilities and the need to ensure the integrity of the supply chain. Organizations should be prepared to assess and mitigate supply chain risks and consider the inclusion of software and firmware development processes in their cybersecurity programs. Stay informed about upcoming rules and regulations, such as Software Bills of Materials, to ensure compliance with the evolving cybersecurity landscape.

      Navigating the Changes: A Proposed Approach

      With the release of the Rev. 3 draft, organizations must understand the changes and begin planning for their adoption. To effectively navigate the modifications, a systematic approach can be employed:

      1. Review the Change Analysis: NIST has provided a change analysis document that highlights the differences between Rev. 2 and Rev. 3. Start by reviewing this document to gain an understanding of the key changes.
      2. Identify Significant Changes: Focus on the requirements that have been identified as significant changes in the change analysis document. These changes may require more attention and adjustment in your cybersecurity program.
      3. Assess Existing SSPs and SPRS/800-171A Assessments: Evaluate your existing System Security Plans (SSPs) and Security and Privacy Requirements Scoping Tool (SPRS)/800-171A Assessments to determine if they are prepared for the pending changes. Identify any gaps and develop a plan to address them.
      4. Implement Organization-Defined Parameters: Take advantage of the flexibility offered by ODPs. Assess your organization’s risk tolerance and define parameters that align with your specific needs. Ensure that your SSPs reflect these defined parameters.
      5. Address Supply Chain Risk Management: Review your supply chain management processes and identify areas that require improvement to mitigate supply chain risks. Consider the inclusion of software and firmware development processes in your cybersecurity program.
      6. Update Policies and Procedures: Review and update your policies and procedures to align with the explicit requirement in Rev. 3. Ensure that you have documented processes for each security family, rules of behavior, and acceptable use policies.
      7. Prepare for Independent Assessments: Start planning for independent assessments of your control implementation. This includes conducting internal audits or engaging independent resources to assess compliance with the requirements.
      8. Maintain Awareness of Updates: Stay informed about the progress of Rev. 3 and the finalization of the framework. Monitor official guidance from NIST and other relevant authorities to ensure ongoing compliance with the latest requirements.

      The Impact on DoD’s Cyber Initiatives

      Many organizations wonder how the release of Rev. 3 will affect the DoD’s CMMC program and related efforts. DFARS 252.204-7012 requires contractors to comply with the current version of NIST SP 800-171. This means that, theoretically, contractors could be required to comply with Rev. 3 once it is finalized.

      To address this potential scenario, DoD is expected to issue guidance outlining the phased implementation of Rev. 3’s requirements across the defense supply chain. This guidance will help contractors align their compliance efforts accordingly. While some coordination challenges may arise, it is crucial for organizations to adapt to the changes and ensure compliance with both Rev. 3 and existing requirements to avoid any conflicts.

      How vCISO Services Can Help

      As the changes introduced in Rev. 3 become a reality for organizations, seeking assistance from experienced professionals can alleviate the burden of compliance. Atlantic Digital, a leading provider of vCISO services, offers expertise in navigating the complexities of cybersecurity frameworks like NIST SP 800-171.

      With Atlantic Digital’s vCISO services, organizations can benefit from strategic guidance and support in implementing the necessary changes to meet Rev. 3’s requirements. Their team of dedicated professionals can assess your current cybersecurity program, develop tailored solutions, and provide ongoing advisory services to ensure ongoing compliance.

      Conclusion

      As organizations brace themselves for the release of NIST SP 800-171 Rev. 3, it is crucial to understand the proposed changes and their implications. The consolidation of requirements, the introduction of ODPs, and the emphasis on supply chain risk management reflect the evolving cybersecurity landscape.

      By staying informed, conducting thorough assessments, and seeking support from experts like Atlantic Digital, organizations can navigate the complexities of Rev. 3 and ensure the continued protection of sensitive information. Embrace the changes, adapt your cybersecurity programs, and embrace the opportunity to enhance your security posture in the face of evolving threats.

      Additional Information: Atlantic Digital can help as these changes become reality for your organization with our vCISO services. With our expertise and comprehensive approach, we can guide your organization through the complexities of NIST SP 800-171 Rev. 3 and ensure compliance while enhancing your overall cybersecurity posture. Contact us today to learn more about how our vCISO services can support your organization.

      Decoding the Cloud: Unraveling the Differences Between IaaS, PaaS, and SaaS

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      Introduction to Cloud Computing

      Hello there! I see you’ve stumbled upon my little corner of the internet. Today, we’re going to chat about something that has been buzzing around the tech world like a swarm of over-caffeinated bees: cloud computing. Now, don’t let the jargon scare you away. We’re going to break it down into bite-sized pieces, just like Grandma’s apple pie.

      In the simplest terms, cloud computing is storing and accessing data and programs over the internet instead of your computer’s hard drive. Now, don’t get me wrong. It’s not about your hard drive. You’re not managing hardware and software—that’s the responsibility of an experienced vendor like salesforce.com, Amazon, Microsoft, Google, and IBM. The shared infrastructure they manage is a cloud.

      Now, why is it called ‘cloud computing’? Well, the name comes from the use of a cloud-shaped symbol to represent the complexity of the infrastructure it contains in system diagrams. Cloud computing is an internet-based computing solution where resources are shared rather than having local servers or personal devices handling applications.

      Understanding On-Premises Applications vs Cloud Applications

      Now, let’s talk about the difference between on-premises and cloud applications. For a non-cloud application, we own and manage all the hardware and software. We say the application is on-premises. You might remember the good old days when every piece of software needed its dedicated server (and the server room that looked like the inside of a spaceship). But with cloud computing, things are a tad bit different.

      Cloud applications (or cloud apps) are software applications where the servers and the software are not installed in your business premises but are in a remote data center run by a cloud services provider. This provider takes responsibility for the software and its maintenance, leaving you free to focus on your business without worrying about IT-related issues.

      With cloud computing, cloud service vendors provide three kinds of models for us to use: IaaS, PaaS, and SaaS. If you’re scratching your head, don’t worry! We’ll get to what these abbreviations mean shortly.

      Understanding Cloud Service Models: IaaS, PaaS, SaaS

      Alright, get ready for some more acronyms, because we’re about to dive into the different types of cloud service models: Infrastructure as a Service (IaaS), Platform as a Service (PaaS), and Software as a Service (SaaS). These might sound like a mouthful, but they’re not as complex as they sound. Trust me, I’m a teacher.

      IaaS provides us access to cloud vendors’ infrastructure, like servers, storage, and networking. We pay for the infrastructure service and install and manage supporting software on it for our application. It’s like renting a house and bringing your furniture.

      Next up is PaaS. If IaaS is renting a house and furnishing it yourself, then PaaS is like renting a fully furnished house. PaaS goes further. It provides a platform with a variety of pre-configured features that you can use to develop, run, and manage applications without the complexity of building and maintaining the infrastructure.

      Last but not least, we have SaaS. This is like a hotel room service – you rent the software and use it through an internet connection. You don’t have to worry about installation, set-up, and daily upkeep and maintenance.

      In-depth Analysis: Infrastructure as a Service (IaaS)

      Let’s begin our in-depth analysis with IaaS. As we’ve already discussed, IaaS provides the infrastructure such as virtual machines and other resources like virtual-machine disk image library, block and file-based storage, firewalls, load balancers, IP addresses, virtual local area networks etc. These resources are provided in a virtualized environment, so they can be easily scaled up or down according to business requirements.

      Common examples of IaaS platforms include Amazon Web Services (AWS), Google Cloud Platform, and Microsoft Azure. In IaaS, you rent the hardware, and you have the freedom to install any software and configuration. It offers high flexibility and control over your infrastructure but also puts the responsibility of managing everything on your shoulders.

      In-depth Analysis: Platform as a Service (PaaS)

      Now, let’s move on to PaaS. Here, the cloud provider gives you not only infrastructure but also middleware, development tools, business intelligence (BI) services, database management systems, and more. PaaS is used by developers who want to create web or mobile apps without setting up or managing the underlying infrastructure of servers, storage, network, and databases needed for development.

      You might have heard of Heroku, Google App Engine, or even Salesforce. These are examples of PaaS. It provides a platform and environment to allow developers to build applications and services over the internet. PaaS services are hosted in the cloud and accessed by users simply via their web browser.

      In-depth Analysis: Software as a Service (SaaS)

      Lastly, let’s talk about our dear friend SaaS. Here, the cloud provider hosts and manages the software application and underlying infrastructure and handles any maintenance, like software upgrades and security patching. Users connect to the application over the Internet, usually with a web browser on their phone, tablet, or PC.

      Examples of SaaS applications are plentiful: Google Apps, Salesforce, Dropbox, and more. SaaS is a popular choice for businesses that want to implement an application quickly, with minimal upfront costs. Plus, the pay-as-you-go model is quite attractive to many businesses.

      Comparing IaaS, PaaS, and SaaS: Key Differences

      Now that we’ve got the basics down, let’s look at the key differences between IaaS, PaaS, and SaaS. The most significant difference lies in what each service is essentially responsible for.

      IaaS gives you the highest level of flexibility and management control over your IT resources. PaaS builds on the IaaS model by also including the operating systems, middleware, and runtime environment, while SaaS provides a complete software solution that you purchase on a pay-as-you-go basis from a cloud service provider.

      How to Choose the Right Cloud Service Model for Your Business

      Choosing the right cloud service model for your business depends on your specific needs. Are you a small business looking for an easy software solution? SaaS might be the right pick. Are you a growing business that needs more control over your applications? PaaS could be your best bet. Or maybe you’re a large enterprise that needs a massive amount of storage and power, in which case IaaS might be the way to go.

      Remember, there’s no one-size-fits-all answer here. The best cloud service model for your business depends on your unique needs, resources, and technical expertise.

      Transitioning from On-Premises to Cloud: Steps and Considerations

      Transitioning from on-premises to the cloud can seem like a daunting task, but with careful planning, the process can be smooth and beneficial. The first step is understanding your business’s specific needs and how a cloud service can meet those needs.

      Next, you’ll need to choose a cloud service model that fits your business’s needs. Then, you’ll need to plan your migration strategy, which could include moving data, applications, and other business elements to the cloud.

      Finally, you’ll need to monitor your cloud service regularly to ensure it’s meeting your business’s needs and adjust as necessary.

      Conclusion: The Future of Cloud Services

      So, there you have it. We’ve decoded the differences between IaaS, PaaS, and SaaS, and hopefully, you’re a bit more comfortable with these concepts. As we move forward, the cloud’s future looks promising, with new technologies and innovations on the horizon.

      Remember, the cloud isn’t a one-size-fits-all solution, but rather a flexible tool that can be tailored to your business’s unique needs. So whether you’re a small business owner, a tech giant, or someone in between, there’s a cloud service model out there for you.

      Happy cloud surfing!

      SEC Final Rules on Cybersecurity: A Comprehensive Analysis

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      The Securities and Exchange Commission (SEC) recently released its long-anticipated final rules on cybersecurity risk management, strategy, and governance. This monumental development has generated widespread discussion within the corporate world.

      In this article, we’ll decode these rules, their implications for boardroom accountability, and their potential impact on cybersecurity governance reform. Buckle up, as we dive into the intricate world of SEC regulations and cybersecurity.

      1. An Overview of the SEC’s Cybersecurity Rules

      The SEC’s final rules on cybersecurity are robust and transformational in many respects. However, they have raised eyebrows for letting the boardroom off the hook for cybersecurity governance accountability, at least for now.

      1.1. The Proposal for Director Cyber Expertise

      The SEC proposed a rule that would require boards to disclose if they have a director with cybersecurity expertise. This proposal aimed to increase transparency about the abilities of corporate directors to govern this complex area.

      1.2. The Shortcoming

      Unfortunately, this proposal was not adopted. As a result, Chief Information Security Officers (CISOs) lack regulatory support for an experienced advocate in the boardroom. This increases the job difficulty and accountability of CISOs.

      2. The Impact on Management Teams

      The SEC amplified the pressure on management teams to understand the linkages between cybersecurity, their information systems, and their value in the eyes of a reasonable investor.

      2.1. Incident Disclosure Requirement

      The SEC introduced an incident disclosure requirement that triggers based on the impact of the incident and its materiality. Previously, this requirement was triggered upon incident discovery.

      2.2. The Scope of the Disclosure

      The disclosure focuses on the impact, not the nature of the incident. This approach aims to prevent providing valuable information to attackers. Furthermore, the SEC introduced a delay in disclosure if it is in the interest of national security or public safety.

      3. The Role of Third-Party Systems

      The SEC final rules stipulate the disclosure of cybersecurity incidents involving third-party systems that companies use. This new provision puts a challenging systemic risk disclosure requirement in place for the first time.

      4. The Definition of a Cybersecurity Incident

      The definition of a cybersecurity incident, as discussed in the SEC Open Meeting, is an unauthorized occurrence. This implies that inherent risks realized from within the system would not need to be disclosed.

      5. Increased Transparency and Accountability

      The final rules retain a disclosure requirement around the use of third-party experts in cybersecurity. This aims to provide more transparency regarding in-house versus outsourced capabilities for investors.

      6. The Boardroom’s Role

      The SEC did not entirely exempt the boardroom from the final rules. However, they did remove the requirement of disclosing how the board integrates cybersecurity into its business strategy, risk management, and financial oversight.

      7. The Importance of Investors

      Now that the SEC has established some rules, investors will play a pivotal role in cybersecurity governance reform. As they interact more with boards on these issues, they might exert more influence and drive reforms.

      8. The Future of Cybersecurity and Board Reform

      The SEC’s final rules are seen as the first steps on a crucial journey. Despite the softened stance on boardroom accountability, the need for management to understand the impacts of digital business systems remains.

      9. The Role of Lawmakers

      Lawmakers are not giving up on director cyber expertise. An example is S. 808 Cybersecurity Disclosure Act of 2021, which would compel the SEC to issue final rules on boardroom cyber expertise.

      10. Final Thoughts

      While the SEC’s final rules have sparked a crucial conversation about boardroom accountability in cybersecurity governance, they also underscore the need for individual corporate boards to take self-regulatory initiatives. As we move forward, the role of investors and lawmakers in shaping cybersecurity governance reform will be crucial.

      So, there you have it! A comprehensive breakdown of the SEC’s final rules on cybersecurity. As always, it’s important to remember that regulation is just one piece of the cybersecurity puzzle. Whether you’re a CISO, a board member or an investor, the ultimate responsibility for cybersecurity lies with you. Here’s to safer, more secure digital futures for us all!

      Understanding the Cybersecurity Maturity Model Certification (CMMC) 2.0

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      Atlantic Digital vCISO Services

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      In today’s digital age, the threat of data breaches and cyberattacks is ever-present. This is especially true for organizations operating in the United States defense space, where the protection of sensitive information is of paramount importance. The Department of Defense (DoD) recognizes the need to ensure that the companies responsible for our nation’s most advanced technologies have the ability to safeguard them from unauthorized or improper use. To address this, the DoD has implemented the Cybersecurity Maturity Model Certification (CMMC) as a compliance requirement for defense contractors.

      The Purpose of CMMC

      The CMMC is a systemic attempt to apply security best practices that have been evolving for over two decades in sectors such as finance and healthcare to the unique characteristics of the defense industrial base. It aims to protect sensitive unclassified defense information from unauthorized access, disclosure, or theft. By implementing the CMMC, the DoD intends to ensure that contractors and suppliers have adequate cybersecurity measures in place to safeguard sensitive national security information.

      The Evolution of CMMC

      CMMC has undergone several iterations to enhance its effectiveness and align with accepted cybersecurity standards. The latest version, CMMC 2.0, streamlines requirements and introduces a three-level framework that aligns with the National Institute of Standards and Technology (NIST) cybersecurity standards.

      Level 1 – Foundational

      At Level 1, organizations are required to meet 15 foundational requirements. This level involves an annual self-assessment and affirmation of compliance. It sets the groundwork for establishing basic cybersecurity practices and serves as a starting point for organizations aiming to enhance their security posture.

      Level 2 – Advanced

      Level 2 builds upon the foundational requirements of Level 1 and introduces 100 additional requirements aligned with NIST SP 800-171. This level necessitates a triennial third-party assessment and an annual affirmation of compliance. Organizations at Level 2 are expected to implement more advanced security measures to protect controlled unclassified information (CUI).

      Level 3 – Expert

      Level 3 represents the highest level of cybersecurity maturity in the CMMC framework. It encompasses over 110 requirements based on NIST SP 800-171 and 800-172. Level 3 requires a triennial government-led assessment and an annual affirmation of compliance. Organizations at this level must demonstrate expertise in implementing advanced security controls to protect CUI and safeguard critical defense information.

      The Relationship between NIST and CMMC

      The CMMC requirements are closely tied to the NIST cybersecurity standards. Contractors must undergo self-assessments or third-party assessments to determine compliance with the applicable NIST standard. The Defense Federal Acquisition Regulation Supplement (DFARS) clause states that basic safeguarding requirements for CMMC Level 1 compliance. Under CMMC 2.0, a Level 2 assessment is conducted against the NIST SP 800-171 standard, while a Level 3 assessment is based on a subset of NIST SP 800-172 requirements.

      Certifying Compliance with CMMC

      Certifications for CMMC compliance must be provided by independent CMMC auditors known as C3PAOs or CMMC Assessors. These organizations evaluate defense contractors’ cybersecurity practices and determine whether they meet the required level of cybersecurity controls specified by the CMMC framework. The goal is to ensure that contractors and suppliers handling sensitive defense information have robust cybersecurity measures in place to protect against unauthorized access, disclosure, or theft.

      How We Can Help

      Navigating the complexities of CMMC compliance can be daunting for organizations in the defense industry. At Atlantic Digital, we specialize in assisting organizations with CMMC compliance and elevating their cybersecurity practices. Our team of professional CMMC assessors is well-versed in the CMMC process and can guide your organization in meeting the required cybersecurity controls. We understand the importance of protecting sensitive information and are committed to helping you secure your organization and ensure compliance with the CMMC framework.

      Contact us today to learn more about how we can help you navigate the CMMC compliance process and strengthen your cybersecurity posture.

      The Importance of Secure Smart Devices in the Modern World

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      In today’s interconnected world, the proliferation of network-connected products has revolutionized the way we live and work. From smartphones and smart speakers to internet routers and wearable devices, the average household is now equipped with multiple network-connected devices. However, this rapid growth in the Internet of Things (IoT) industry has also brought about significant cybersecurity challenges.

      The Risks of Unsecure Smart Devices

      The market is flooded with unsecure smart devices, posing a risk not only to their owners but also enabling the creation of botnets for malicious activities. Numerous examples highlight the damage that can be caused by unsecure smart devices. In 2016, the Mirai botnet co-opted over 2,000 routers and smart cameras to launch devastating Distributed Denial of Service (DDoS) attacks1. Hackers also targeted smart heating systems in apartments, leaving residents without heat2. These incidents are not isolated, as attacks against IoT devices have been on the rise, with 1.5 billion attacks reported in the first half of 20213.

      The Need for Legislation

      To address this growing concern, the UK government has taken a proactive approach by enacting the Product Security and Telecommunications Infrastructure (PSTI) Act 20224. This comprehensive legislation focuses on enhancing the security of smart devices and the country’s telecommunications infrastructure. The PSTI Act is divided into two parts, with the first part emphasizing device security. Accompanying this is the Security Requirements for Relevant Connectable Products Regulations 20235.

      The PSTI Act is a groundbreaking move that establishes the UK as the first country to mandate minimum cybersecurity requirements for consumer connectable products before they are made available for sale. This legislation aims to protect consumers and drive improvements in product security across the industry. It addresses key issues such as default passwords, vulnerability disclosure policies, and the duration of security update support6.

      Key Provisions of the PSTI Act

      The PSTI Act outlines several crucial provisions that organizations responsible for smart devices in the UK must adhere to:

      1. No default passwords: Manufacturers must ensure that their devices do not come with default passwords, which are often a weak point exploited by hackers.
      2. Vulnerability disclosure policy: Organizations should have a clear policy in place for reporting and addressing security vulnerabilities in their products.
      3. Transparency on security updates: Manufacturers must provide information about the minimum length of time for a product’s security update lifecycle, ensuring that devices remain protected throughout their intended lifespan6.

      The legislation covers a wide range of devices, including smartphones, wearable products, IoT devices, children’s toys, internet routers, smart appliances, and home assistants. The scope of the PSTI Act encompasses anything that can connect to a network or the internet6.

      The Power of the Secretary of State

      The PSTI Act grants the Secretary of State significant authority to enforce security requirements on relevant connectable products. The Secretary of State has the power to specify security requirements to protect consumers and users of such products. These requirements apply to manufacturers, importers, and distributors6.

      The Act also allows the Secretary of State to issue compliance notices, ensuring that organizations take cybersecurity seriously. Compliance notices can be issued to manufacturers, importers, and distributors, making cybersecurity legally enforceable rather than merely advisory. Importantly, the Act prevents organizations from bypassing security requirements by importing products from outside the UK6.

      Ensuring Compliance and Accountability

      The PSTI Act introduces measures to ensure that organizations comply with security requirements. The Act empowers the Secretary of State to deem compliance with security requirements under certain conditions. Compliance can be determined based on conformity to specified standards or meeting requirements imposed by recognized standards, including those set outside the UK6.

      It is worth noting that while the legislation does not explicitly cover second-hand products, it does regulate refurbished or reconditioned devices sold as new. This ensures that even these products meet the necessary security standards to protect consumers6.

      The Act also enables the Secretary of State to issue Stop Notices and Recall Notices. These measures can be imposed on organizations covered by the PSTI Act, forcing them to halt the sale of specified products or recall products already in the market. This mechanism ensures that swift action can be taken to address cybersecurity concerns, similar to how cars can be recalled for safety reasons6.

      The Grace Period and Penalties

      The PSTI Act was given Royal Assent in December 2022, allowing organizations a grace period of 12 months to prepare for compliance. This grace period gives organizations time to establish the necessary systems and policies to meet the security requirements outlined in the legislation. The Act will come fully into force in December 20236.

      Organizations that fail to comply with the PSTI Act will face financial penalties. These penalties can include fines of up to £10 million or 4% of the person’s worldwide revenue, whichever is higher. These penalties aim to hold organizations accountable for their cybersecurity practices and drive the adoption of robust security measures6.

      The Impact on Innovation and Market Dynamics

      While there have been concerns that the PSTI Act may stifle innovation and impose financial burdens on startups and emerging technologies, its primary goal is to create a more secure market. By removing insecure products that compete solely on price, the legislation drives the market towards more secure alternatives. This encourages innovation in security and fosters a safer environment for consumers6.

      The PSTI Act aligns with a broader global trend in cybersecurity regulation. Initiatives such as the EU’s Cybersecurity Act and the California Senate Bill 327 in the United States demonstrate a growing recognition of the importance of cybersecurity in protecting consumers and driving global standards6.

      The Future of Cybersecurity Regulation

      The PSTI Act represents a fundamental shift in how governments approach cybersecurity. By establishing a regulatory framework and enabling enforcement, the Act ensures that security requirements keep pace with technological advancements. The legislation can be easily updated through supplementary material, allowing for flexibility and adaptability in the face of evolving cybersecurity threats6.

      Regulation and legislation alone are not sufficient; enforcement is crucial. The PSTI Act’s effectiveness will depend on the willingness to take action against non-compliance. With robust enforcement, the PSTI Act can drive significant improvements in the security of smart devices and protect consumers from the risks posed by unsecure products6.

      In conclusion, the PSTI Act is a landmark piece of legislation that addresses the cybersecurity challenges posed by unsecure smart devices. By mandating minimum security requirements and enforcing compliance, the Act aims to create a safer environment for consumers and drive improvements in product security. As the first of its kind in the world, the PSTI Act positions the UK as a leader in cybersecurity regulation, setting an example for other countries to follow. With the Act coming into full force in December 2023, organizations must prioritize cybersecurity and ensure their products meet the necessary security standards to protect consumers and the integrity of the telecommunications infrastructure.

      Additional Information

      The PSTI Act complements other cybersecurity initiatives, such as the European Union’s Cybersecurity Act and the California Senate Bill 327. These efforts demonstrate a global recognition of the need for robust cybersecurity measures and the importance of protecting user data and privacy78. The National Cyber Security Centre (NCSC) and key allies have also released guidance on smart city security, emphasizing the need to balance cybersecurity risks in the development of smart cities9. These collective efforts contribute to a more secure and resilient digital landscape.

      Footnotes

      1. More than 2,000 TalkTalk routers hijacked by Mirai botnet variant ↩
      2. DDoS attack leaves Finnish apartments without heat ↩
      3. Kaspersky: Attacks on IoT devices double in a year ↩
      4. Product Security and Telecommunications Infrastructure (PSTI) Act 2022 ↩
      5. Security Requirements for Relevant Connectable Products Regulations 2023 ↩
      6. References from the original article have been rephrased and rewritten to maintain originality. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14
      7. Product Security and Telecommunications Infrastructure Bill will reinforce protections for consumer devices and mandate improvements to default security settings ↩
      8. European Commission lays out proposed security regulations on device and software security to better protect consumers and drive global standards ↩
      9. The NCSC and key allies have drawn up new guidance to help communities balance the cybersecurity risks involved with creating smart cities ↩