Navigating the Latest DoD Memo on CMMC Certification Requirements with Atlantic Digital

Introduction

The Department of Defense (DoD) continually updates its cybersecurity protocols to safeguard sensitive information within the Defense Industrial Base (DIB). The latest memorandum, “Implementing the Cybersecurity Maturity Model Certification (CMMC) Program” (DoD), introduces significant changes to the Cybersecurity Maturity Model Certification (CMMC) requirements, directly impacting contractors and service providers. This paper examines these updates, addresses critical compliance challenges, and outlines how Atlantic Digital (ADI) helps clients achieve compliance.

Understanding the Latest DoD Memo on CMMC

The recent DoD memorandum formalizes the CMMC framework by confirming a phased implementation and clarifying the conditions under which different levels of certification are required. It also provides new guidance on waivers and subcontractor compliance. 

Key updates include: 

  • CMMC certification requirements will be introduced incrementally upon publication of the final DFARS rule, 2019-D041. Contractors must prepare for increasing compliance obligations over the next two years as Level 1, Level 2, and Level 3 requirements take effect. 
  • The memo reiterates that CMMC Level 3 requirements should not be unnecessarily imposed on subcontractors unless they handle mission-critical CUI. Program Managers are advised to take a risk-based approach when determining subcontractor obligations. 
  • Service and Component Acquisition Executives (SAE/CAE) may waive CMMC certification requirements under certain conditions but must still ensure compliance with cybersecurity safeguards.  

Phased Implementation Process 

The DoD memo confirms that CMMC implementation will begin once the final Title 48 CFR rule is published. Implementation will proceed as follows: 

  • Upon publication of the final DFARS rule, 2019-D041, CMMC Level 1 requirements will take effect for applicable contracts. 
  • One year after DFARS publication, CMMC Level 2 assessments will be introduced as part of the phased implementation process. 
  • Two years after DFARS publication, CMMC Level 3 certification assessments will be mandatory, when appropriate.  
  • The DoD will update Instruction 8582.01 and provide additional guidance regarding the application of NIST SP 800-172 protections for Level 3 contractors. 

CMMC Level Assessments 

CMMC builds upon NIST SP 800-171 self-assessments already obligatory under DFARS 252.204-7019, and organizations must continue conducting these assessments as required. Additionally, the CMMC Program requires pre-award assessments of covered contractor information systems against prescribed cybersecurity standards for safeguarding Controlled Unclassified Information (CUI) and Federal Contract Information (FCI). 

Assessment Breakdown: 

  • CMMC Level 1 requires an annual self-assessment against 17 basic cybersecurity practices, based on the Federal Acquisition Regulation (FAR) 52.204-21. 
  • CMMC Level 2 requires adherence to NIST SP 800-171 requirements. Depending on the sensitivity of the Controlled Unclassified Information (CUI) handled, assessments may be either self-assessments or conducted by a Certified Third-Party Assessment Organization (C3PAO). 
  • CMMC Level 3 requires a DoD-led assessment, incorporating NIST SP 800-172 enhanced security requirements. 

Flow-Down Requirements for Subcontractors  

The memo warns that CMMC Level 3 requirements should not be unnecessarily flowed down to all subcontractors, as this could impose undue financial and administrative burdens. Program Managers must ensure only essential subcontractors handling mission-critical CUI are subject to Level 3 requirements.  

New CMMC Waiver Process 

The memo establishes a waiver process, allowing SAE/CAE officials to waive CMMC certification under specific conditions. Waivers do not remove cybersecurity compliance obligations but offer flexibility in cases where certification requirements could limit competition. 

Waiver Guidelines: 

  • CMMC waivers may be granted on a case-by-case basis by SAE/CAE officials 
  • All cybersecurity requirements remain in effect, regardless of whether a waiver is granted. 
  • According to the memo, “There are no circumstances likely to warrant approval of requests to waive CMMC Level 1 requirements.” 
  • The memo confirms that some “…CMMC Level 2 third-party assessment requirements may be waived under certain conditions,” but “there are no circumstances likely to warrant approval of requests to waive CMMC Level 2 self-assessment requirements.”  
  • Waivers for Level 3 contractors will be highly limited due to their handling of mission-critical CUI. 

Identified Compliance Challenges

While the DoD memo provides clarity on CMMC requirements, additional challenges arise when managing information such as Export-Controlled Information (EXPT), which is regulated under separate frameworks like the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). Unlike Controlled Technical Information (CTI), which directly triggers CMMC Level 2 requirements under DoD contracts, EXPT is a broader category of Controlled Unclassified Information (CUI) that applies across multiple federal agencies, including the Departments of Commerce and State. As a result, contractors handling EXPT may face cybersecurity requirements that extend beyond DoD mandates and into multi-agency oversight (DoD, Export Solutions). 

Key Challenges 

  • Export Controlled (EXPT) information is classified as Controlled Unclassified Information (CUI) under the National Archives’ CUI Registry. This classification encompasses unclassified technical data, software, or other items subject to export restrictions under the International Traffic in Arms Regulations (ITAR) or Export Administration Regulations (EAR) (National Archives, DoD) 
  • While EXPT itself is not categorized as Controlled Technical Information (CTI), there are instances where the same dataset may be classified as both EXPT and CTI (National Archives, National Archives). In such cases, contractors may be required to comply with multiple regulatory frameworks, including DFARS 252.204-7012 and export control laws. 
  • The presence of EXPT in a Department of Defense (DoD) contract does not automatically trigger CMMC certification requirements. However, if a contract involves both EXPT and CTI, the contractor may be required to undergo a full CMMC Level 2 assessment due to the handling of CTI. Additionally, in cases where a non-DoD agency is involved, equivalent cybersecurity measures may be required even if the DoD does not impose them directly. 
  • Since ITAR and EAR compliance imposes security requirements beyond those outlined in NIST SP 800-171, organizations must implement a dual compliance strategy. Contractors should assess regulatory obligations across all awarding agencies to ensure alignment with both DoD and export control cybersecurity requirements. 

In this sense, understanding the interplay between CMMC, DFARS, and export control regulations is critical for organizations handling sensitive government data. The presence of EXPT can introduce additional layers of compliance, even when CMMC is not explicitly required by DoD. Contractors must evaluate regulatory obligations beyond DoD contracts, ensuring that cybersecurity measures align with both defense and non-defense federal agency requirements. 

Atlantic Digital’s (ADI’s) Strategy and Compliance Solutions

Atlantic Digital offers a strategic approach to navigating CMMC compliance, ensuring organizations meet the necessary standards while addressing challenges posed by complex regulatory frameworks. ADI’s team helps contractors determine their certification requirements, implement necessary safeguards, and provide solutions to comply with both DoD mandates and broader federal regulations. Through comprehensive risk assessments, ongoing education, and specialized support, ADI ensures that clients can confidently meet their compliance obligations, optimize their security measures, and remain competitive in the defense sector. 

How ADI Helps Clients Achieve Compliance: 

  • ADI assists clients in aligning multiple frameworks, offering contract-based certification guidance, and determining whether CMMC certification is required based on contract requirements from DoD and other federal agencies. 
  • ADI advises clients on separating CUI from other sensitive data to avoid excessive security obligations on subcontractors, in accordance with DoD recommendations. 
  • ADI works with clients to educate subcontractors on their cybersecurity responsibilities to enhance compliance and reduce risks. 
  • ADI stays updated on changes to DFARS, CMMC methodologies, and regulatory guidance, ensuring clients remain compliant with strict cybersecurity requirements. 

Conclusion

The evolving cybersecurity landscape demands that contractors remain agile and informed. The latest DoD CMMC implementation memo provides clarity on assessment levels, waivers, and subcontractor requirements. However, challenges remain for organizations handling information regulated under separate frameworks, requiring a strategic approach to compliance. Atlantic Digital empowers clients to meet these challenges by offering expert guidance on aligning multiple cybersecurity frameworks, minimizing unnecessary security obligations, and ensuring compliance with both DoD and other regulations. 

ADI’s comprehensive solutions ensure that clients can navigate the complexities of CMMC compliance, mitigate risks, and achieve robust cybersecurity resilience. For expert CMMC strategy and compliance solutions, contact ADI today to ensure your business remains secure and competitive in the evolving defense sector. 

The Limits and Realities of Cyber Insurance

Cyber attacks now cost organizations $4.88 millions per breach on average (IBM). This stark reality underscores the importance of cyber insurance as a critical tool for financial and operational risk mitigation. However, the complexities and limitations inherent in these policies create significant challenges for businesses. To navigate these drawbacks effectively, organizations must understand the evolving threat landscape, policy limitations, claims management hurdles, and cost considerations. 

Evolving Threat Landscape

The sophistication and scale of cyber threats have reshaped the insurance industry, leading to increasingly restrictive coverage and higher barriers to policy access. These developments demand that businesses critically evaluate emerging risks and align their risk management strategies accordingly. 

Ransomware Attack Patterns
Ransomware remains one of the most pressing threats in 2024, evolving from basic encryption tactics to advanced strategies that cause significant financial and operational disruption. For instance, the average ransomware demand reached $5.2 million per incident in the first half of 2024 (Infosecurity Magazine), and LockBit, one of the most notorious ransomware groups, claimed at least 428 victims alone (Flashpoint). High-profile targets include critical sectors such as political systems, healthcare, manufacturing, financial services, and infrastructure (ADI). The mounting frequency and severity of these attacks underscore the importance of cyber insurance while simultaneously making comprehensive coverage increasingly elusive. 

At the same time, nation-state-sponsored cyber activities present unique risks. Nation-state actors accounted for 45% of all cyberattacks targeting government institutions in 2024 (Cyble). These actors often infiltrate critical infrastructure systems undetected, launching attacks at strategically chosen moments (State Scoop).  Marked by persistent threats and AI-driven disinformation campaigns, these operations are frequently excluded from standard cyber insurance policies, leaving affected organizations vulnerable to substantial financial and operational risks. 

Other Attack Vectors
The risk landscape continues to shift beyond ransomware and nation-state threats. IoT malware attacks, for example, have surged by 400% (Infosecurity Magazine). Abuse of valid credentials remain a critical vulnerability, accounting for 44.7% of data breaches in 2023 (Deloitte), while infostealer attacks compromised over 53 million credentials in the first half of 2024 (Flashpoint). AI-powered cyber attacks further exacerbate these issues by enabling automated hacking and sophisticated phishing campaigns at scale (Crowdstrike, CSO) Notably, manufacturing has emerged as the most targeted industry in this evolving threat landscape (WEF). Together, these trends highlight the importance of adopting holistic security practices alongside cyber insurance.

Policy Coverage Limitations and exclusions

As cyber risks evolve, insurance providers have responded by tightening policy terms, which significantly impacts businesses’ ability to transfer risk effectively. Stricter qualification requirements, such as multi-factor authentication, patch management, employee security trainings, among others (ADI, Netwrix, Trend), in addition to exclusions for critical infrastructure, business interruption gaps, and limitations on third-party liability coverage create challenges that organizations must carefully navigate. 

Critical Infrastructure Exclusions
One significant limitation involves exclusions related to failures in critical infrastructure. Policies increasingly exclude losses stemming from disruptions to essential services, such as electricity, water, gas, satellite, and telecommunications. This exclusion reflects insurers’ concerns about the systemic nature of these failures, which can cause widespread, catastrophic losses beyond the financial capacity of individual insurers to absorb. This shift reflects insurers’ limited capacity to manage systemic catastrophic losses, leaving critical industries particularly exposed (ABI, Munich RE, Gallagher)

Business Interruption Gaps
Business interruption coverage presents another significant limitation. Policies can include waiting periods before activation, narrowly define covered events, and may require complete business shutdowns to trigger coverage. Contingent business interruption, which protects against service provider failures, is not universally included in cyber insurance policies, leaving businesses vulnerable to operational disruptions. (SCS Agency, Corvus, Insurance Advisor). 

Third-Party Liability Issues
Third-party liability coverage also features notable restrictions. Policies may exclude claims from employees, contractors, or partially owned subsidiaries and often cap coverage for regulatory investigations, lawsuits, and settlements. These exclusions require careful evaluation (Intelice, SCS Agency, ABI, Gallagher).

Claims Management Challenges

Even when coverage is in place, navigating the claims process presents its own set of obstacles. Businesses must adhere to strict reporting timelines, documentation standards, and recovery requirements to avoid delays or denials. 

Response Time Requirements
Timely reporting is critical to avoid claim denial. Most insurers require notification of incidents within 60 days of an event (Lawyers Mutual, NACHC)). Quick coordination with approved vendors and stakeholders is also essential to meet policy deadlines. 

Documentation Demands
Insurers now require rigorous documentation for claims, including detailed incident response logs, system restoration costs, business interruption calculations, third-party vendor expenses, and evidence of pre-incident security measures. Formal proof of loss submissions are typically required within 90 days (WTW), Failure to meet these demanding standards can result in denied claims or delayed payouts. 

Recovery Process Complexities
The recovery process itself is not without challenges. Insurers frequently mandate the use of pre-approved vendors, limiting flexibility. Moreover, policies generally only cover system restoration to pre-incident states, leaving businesses responsible for any improvements. This meticulous cost-tracking adds to the administrative burden during post-incident recovery (Marsh).

Cost-Benefit Considerations

As the U.S. cyber insurance market dominates 59% of the $16.66 billion in global premiums (NAIC), businesses must weigh the costs and benefits of coverage carefully. 

Premium vs Coverage Analysis
U.S. insurers reported $7.25 billion in direct written premiums in 2024 (NAIC). Premiums vary based on company size, industry risk, security measures, and claims history. Small businesses, for example, pay an average of $145 per month (Insureon), while larger organizations face significantly higher premiums. 

Deductible Structure Impact
Deductibles also play a crucial role in shaping the cost-benefit analysis of cyber insurance. With average deductibles around $2,500 (Insureon), companies may adjust their self-insured retentions (SIRs) to manage premium expenses (Johnson and Bell, Lowenstein Sandler). 

Return on Insurance Investment
When evaluating the return on investment (ROI) for cyber insurance, businesses must consider factors such as reputation protection, regulatory compliance support, crisis management assistance, and legal liability coverage Improved loss ratios reported by insurers—dropping from 66.4% in 2021 to 44.6% in 2022—reflect better risk management and policy terms (NAIC). 

Future Market Predictions
The global cyber insurance market is projected to grow from $14 billion in 2023 to $23 billion by 2026 (Insurance Business Magazine). This growth underscores the increasing costs of premiums and evolving coverage requirements discussed earlier, as insurers adapt to the rising frequency and severity of cyber incidents. This growth will be driven by technological advancements, emerging threats, and enhanced risk assessment tools. AI, in particular, is reshaping risk modeling, claims processing, and incident monitoring. However, human expertise remains critical to bridging existing coverage gaps and ensuring comprehensive protection (Insurance Thought Leadership, ABA, Munich RE).

Conclusion

While cyber insurance provides a vital safety net for businesses facing financial and operational risks, its limitations—from restrictive policies to complex claims processes—pose significant challenges. As the market continues to grow, organizations must adopt proactive risk management strategies, meet stringent insurer requirements, and address coverage gaps. Ultimately, cyber insurance should complement, not replace, robust cybersecurity practices. By aligning insurance coverage with comprehensive security measures, businesses can enhance resilience in an increasingly hostile digital landscape.

Cyber Insurance in 2024—Key Requirements and Industry Insights

Businesses are losing an average of $4.88 million per breach from cyber attacks in 2024, and these figures continue to increase (IBM). The rising threats have turned cyber insurance from a nice-to-have into a must-have business tool. The cyber insurance market moves faster than ever. Insurers now demand tougher requirements and adjust their coverage to counter new threats. Companies must meet strict cyber insurance standards such as “the use of multifactor authentication, regular software updates, vulnerability patching and training employees” (Cybersecurity Dive). 

This piece breaks down today’s cyber insurance world, what you need for coverage, and the trends that shape the industry in 2024.  

Current State of the Cyber Insurance Market

The U.S. leads the world’s cyber insurance market, which has reached a new level of maturity, generating USD 16.66 billion in global premium volume during 2023, with the U.S. contributing 59% of the total (NAIC). U.S. insurers alone reported USD 7.25 billion in direct written premium, marking steady growth since 2022. This expansion is further reflected in a 11.7% increase in active policies, totaling 4,369,741 in 2023 (NAIC).  

Key indicators reveal a market that is stabilizing and evolving to meet demand: 

  • Premium rates dropped by 6% in regions of all sizes. 
  • The SME segment remains underserved, with 72% of uninsured businesses recognizing their cyber risks but lacking coverage. 
  • Overall market conditions have stabilized, with lower rate increases and some flat renewals, signaling a maturation phase for the sector. 

(Cybersecurity DiveNAIC

However, this stabilization does not imply reduced risks. While market conditions appear steadier, the frequency and severity of claims have continued to increase since 2022 (Coalition). According to Allianz’s annual cyber risk outlook, the frequency of large cyber claims (over €1 million) increased by 14% and their severity by 17% in the first half of 2024. Notably, data and privacy breaches were involved in two-thirds of these major losses (Allianz). In response, insurance providers have tightened their underwriting rules significantly. They now have detailed requirements that organizations need to meet for cyber coverage.  

Mandatory Security Controls

Today, organizations need specific security measures in their digital world to get cyber insurance coverage. Multi-factor authentication (MFA) is the main requirement, and insurers want it on all critical systems and administrator accounts, but there are other core security controls: 

Control Description 
Multi-Factor Authentication (MFA) A security measure that requires users to provide two or more verification methods, such as a password and a mobile app, to gain access. MFA significantly reduces unauthorized access risks. 
Patch Management The process of consistently updating and fixing software vulnerabilities to prevent exploits. Includes prioritizing, testing, and deploying updates to systems and applications. 
Endpoint Detection and Response (EDR) A cybersecurity solution for detecting, analyzing, and responding to threats on devices like laptops and mobile phones. 
Incident Response Plan A detailed plan outlining steps to identify, contain, eradicate, and recover from a cyberattack. Includes public relations strategies and technical/business continuity measures. 
Employee Training and Awareness Regular training sessions that educate employees on identifying phishing attempts, using strong passwords, and adopting safe online practices to minimize human error as a cybersecurity risk. 
Immutable and Isolated Backup Systems Ensures data cannot be altered or deleted, a safeguard against ransomware attacks. 
Privileged Access Management (PAM) Critical for managing and securing administrator-level accounts, which are high-value targets for attackers. Insurers value PAM to enforce least-privilege access and limit lateral movement during breaches. 
Compliance with regulations and policies Ensures organizations adhere to standards like NIST SP 800-171 or CIP regulations, which establish required cybersecurity practices for specific industries. 
Third-party risk management Establishes a framework for evaluating and monitoring vendors’ and partners’ cybersecurity practices to reduce supply chain vulnerabilities. 
Modern Attack Surface Management (ASM) ASM provides real-time visibility and continuous risk assessment, enabling proactive responses to vulnerabilities. Integration across devices, accounts, and applications strengthens the overall cybersecurity posture. 
Secure network access controls Applies encryption, MFA, and other security measures to mitigate risks associated with remote desktop protocols and remote work. 

Other requirements might include cybersecurity awareness training for all users, security information and event management (SIEM), monitoring event logs, content filtering, supply chain risk management, replacement of end-of-life systems, secure remote access, and vulnerability prioritizationRecent industry data show the great majority of cyber breaches come from human mistakes, highlighting the importance of reliable security measures in that regard (UpGuardVerizon). 

Furthermore, technology has transformed cyber insurance requirements. Insurers now need sophisticated security measures that use artificial intelligence and machine learning. Recent data show that machine learning algorithms have improved threat detection rates dramatically compared to traditional methods (Cyber MagazineESTTrendKasperskyWSJ). 

Extended Detection and Response (XDR) has become essential, replacing traditional endpoint detection and response (EDR) systems. Insurance providers now need: 

AI Security Component Description 
Threat Intelligence Immediate correlation in multiple security layers 
Automated Response Machine learning-driven incident containment 
Predictive Analytics Proactive vulnerability identification 
Behavioral Analysis Continuous monitoring of user patterns 

In addition, cloud security governance has become vital. Insurers need complete protocols for cloud-based operations. Key requirements include: 

  • Implementation of immediate telemetry data monitoring 
  • Dynamic risk assessment through API-driven systems 
  • Continuous compliance validation in multi-cloud environments 
  • Automated configuration management and vulnerability scanning 

(Proofpoint,  Coalition

Compliance Framework Implementation

Organizations seeking cyber insurance coverage should consider adopting recognized cybersecurity frameworks that align with industry standards. In fact, insurers often require organizations to adhere to established cybersecurity frameworks to assess and mitigate risks effectively. Some prominent frameworks include: 

  • NIST Cybersecurity Framework: Developed by the National Institute of Standards and Technology, this framework provides a structured approach to managing and reducing cybersecurity risks. 
  • ISO 27001: This standard specifies the requirements for establishing, implementing, maintaining, and continually improving an Information Security Management System (ISMS). 
  • SOC 2: Developed by the American Institute of Certified Public Accountants, SOC 2 focuses on controls relevant to security, availability, processing integrity, confidentiality, and privacy. 

(BitSightNemko) 

Documentation and Reporting Standards

Detailed documentation is central to securing and maintaining cyber insurance coverage, ensuring clarity and compliance throughout the policy period. Cyber insurance policies must clearly outline the protocols for reporting security incidents, including specific deadlines and notification procedures. To meet insurer requirements, organizations must maintain thorough records across key areas, including: 

  • Legal and regulatory compliance costs 
  • Breach notification procedures 
  • Investigation and review processes 
  • Settlement coverage specifications 

This documentation must not only meet regulatory requirements but also provide sufficient detail to facilitate smooth claims processing. Insurers increasingly demand proof of proactive measures, such as regular security audits and system reviews, to ensure that organizations maintain robust cybersecurity practices throughout the policy term. By meeting these expectations, businesses can demonstrate preparedness and reduce potential liability. 

(WTWCoalitionFDICCISA

Cost-Benefit Analysis

Organizations need to assess how their cyber insurance investments impact their finances; particularly as premium costs fluctuate. Small businesses, for instance, typically pay an average of USD 145 per month for cyber insurance, although this amount can vary depending on several key factors. Insurance providers consider the following elements when determining premiums: 

Factor Impact on Premium 
Company Size/Revenue Higher revenue = Higher premium 
Industry Sector Healthcare/Finance = Higher rates 
Security Measures Strong controls = Lower rates 
Claims History Previous incidents = Higher costs 
Data Management Sensitive data = Premium increase 

Small businesses can typically secure basic coverage at more affordable rates, while larger organizations with a significant online presence face higher premiums due to the greater risks they encounter (Insure onTechInsuranceFounders Shield).

ROI Assessment Methods

Cyber risk quantification (CRQ) has changed how companies calculate ROI for cyber insurance investments. Companies now use automated CRQ solutions that give more accurate results than manual calculations. The assessment looks at: 

  • Financial effects of possible cyber events 
  • How well current security controls work 
  • Possible losses compared to premium costs 
  • Whether coverage matches identified risks 

(SqualifyKOVRR)

Risk Mitigation Benefits

The total global cyber insurance premiums were estimated to be around USD 14 billion at the end of 2023, with projections to reach USD 23 billion by 2026. North America remains the largest market segment within the global total (IndustrialCaptive). This growing investment in cyber insurance reflects the comprehensive protection it offers, with research indicating that companies with robust cyber insurance spend less when breaches occur. In 2024, the average claim payments for cyber insurance show the financial impact of cyber incidents: 

  • The average loss amount is approximately $100,000 
  • For small and medium-sized enterprises (SMEs), the average claim cost is around USD 345,000, with ransomware events specifically averaging USD 485,000. 
  • The average claim for all organizations is $812,360  

(Network AssuredAstraCoalition

Cyber insurance also offers several additional services that enhance its overall value, including: 

  • Risk assessment and security audits before problems occur 
  • Help with incident response planning 
  • Employee cybersecurity training programs 
  • Special forensic services when needed 

By implementing recommended security measures, organizations not only strengthen their defenses but may also improve their insurance terms, potentially lowering premiums through the demonstration of a strong security posture.

Industry-Specific Compliance

Different industries face varying cybersecurity compliance requirements and insurance mandates based on their unique challenges. For example, the healthcare sector saw a 93% increase in large breaches from 2018 to 2022, and ransomware incidents jumped by 278% during this period (HHS). Furthermore, data from 2023 reveal that 58% of the 77.3 million individuals affected by data breaches were victims of healthcare business associate attacks, “a 287% increase compared to 2022” (AHA). In that sense, healthcare organizations face strict cybersecurity rules because they handle sensitive patient data. Some of these rules include: 

  • Data Protection: Encryption of patient records 
  • Access Management: Role-based authentication 
  • Incident Response: 72-hour breach notification 
  • Business Continuity: Extended downtime procedures 

(HIPPA JournalVISEVEN

Similarly, financial institutions must follow detailed cybersecurity frameworks set by regulators. For instance, the New York Department of Financial Services (NYDFS) has rolled out stronger requirements (DFS) that focus on better governance oversight; broader notice requirements; required encryption of non-public information; and strict multi-factor authentication protocols. 

In the same vein, critical infrastructure protection has become a national priority. The Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (CISA) works with 12 other agencies to protect various sectors. They have enhanced security protocols, including include changes in sector-specific cybersecurity performance goals; required incident reporting; regular vulnerability checks; and integration with national cybersecurity frameworks (CISAGallagherThe RegisterCISACISA).  

The energy sector faces unique challenges, as it needs protection against threats that could disrupt vital supplies. The North American Electric Reliability Corporation’s (NERC) Critical Infrastructure Protection standards require strong security measures, including risk assessments and system resilience testing (FERC). 

In short, companies need to meet sector-specific requirements to keep their cyber insurance coverage. Insurance providers now look more closely at security controls and incident response capabilities. Breaking these rules can lead to heavy penalties, including monetary fines and possible coverage denials.

Conclusion

Cyber insurance has evolved from a supplementary safeguard to a critical business necessity, driven by the rising costs of breaches and the growing sophistication of cyber threats. Today, organizations must meet rigorous security standards, such as implementing multi-factor authentication (MFA) and adopting AI-driven threat detection systems. While premium rates have generally declined, the strength and breadth of coverage options reflect the stability of the market.

Modern cyber insurance policies are now built upon strong security practices, established compliance frameworks, and rigorous documentation standards. Companies that demonstrate robust security controls through regular assessments can secure more favorable coverage terms. The continued evolution of cyber threats is mirrored by the increasing reliance on advanced technologies, especially AI-driven security solutions.

The financial impact remains significant, with premiums varying based on company size, industry, and the strength of implemented security measures. Sectors such as healthcare, finance, and critical infrastructure face additional compliance requirements due to the sensitive nature of their data and operations.

These comprehensive requirements not only protect insured organizations but also contribute to enhanced cybersecurity practices across industries. As the cyber insurance market matures, it continues to adapt its standards and coverage models to address emerging threats and technological advancements.

Where Atlantic Digital Makes the Difference

Cyber insurance demands strong cybersecurity foundations, and that’s exactly what Atlantic Digital delivers. Through our CMMC compliance solutions, we help businesses achieve more than just certification. By guiding you through CMMC’s stringent security controls, including MFA, risk management, continuous monitoring, and incident response, we ensure you meet the tough standards insurers now require.

CMMC can be your key to becoming a more insurable, resilient business.

Is your organization prepared to meet these new requirements? Let Atlantic Digital help you implement the right cybersecurity measures and frameworks to secure insurance coverage and mitigate risks. Contact us today!

Strengthening Your Cybersecurity: MFA and CMMC Level 2 

In today’s digital battlefield, protecting sensitive information is no longer optional; it’s mission-critical. For defense contractors and businesses handling Controlled Unclassified Information (CUI), the Cybersecurity Maturity Model Certification (CMMC) Level 2 sets the bar for security standards. At the heart of this framework lies a powerful ally: Multi-Factor Authentication (MFA). 

Why MFA Matters in CMMC Level 2 

Imagine your data as a fortress. Passwords are the first line of defense, but they’re vulnerable to breach. MFA adds extra layers of security, turning your fortress into an impenetrable stronghold. It’s like having a guard who not only checks your ID but also your fingerprint and a secret handshake. 

For businesses striving to meet CMMC Level 2 requirements, MFA is not just a nice-to-have: it’s a must-have. Here’s why: 

  1. MFA ensures that only authorized personnel can access sensitive systems, aligning perfectly with CMMC’s stringent CUI protection measures. 
  1. By requiring multiple forms of verification, MFA significantly reduces the risk of unauthorized access, even if passwords are compromised. 
  1. Implementing MFA helps tick off several boxes in the CMMC Level 2 checklist, particularly those related to user authentication policies. 

MFA Basics: Securing Your Digital Kingdom 

Implementing MFA doesn’t have to be a Herculean task. At its core, MFA combines: 

  • Something you know (like a password) 
  • Something you have (such as a smartphone) 
  • Something you are (biometrics like fingerprints) 

By requiring at least two of these factors, MFA creates a robust defense against cyber threats. 

The Bottom Line 

In the world of cybersecurity, MFA is your secret weapon. It’s not just about meeting CMMC Level 2 requirements: it’s about safeguarding your business, your clients, and your reputation. 

Ready to fortify your defenses?Contact Us to discuss how our vCISO + Enterprise Architect services can help you navigate the complexities of CMMC Level 2 and position your organization for long-term success in defense contracting. 

The 32 CFR CMMC Final Rule: Implications, and Preparations for Defense Contractors

Introduction

The cybersecurity landscape is undergoing rapid transformation, and the Department of Defense (DoD) is making substantial strides to safeguard sensitive information. On October 15, 2024, the 32 CFR Cybersecurity Maturity Model Certification (CMMC) Final Rule was published in the Federal Register, marking a pivotal development in defense cybersecurity (visit Atlantic Digital for a detailed timeline of these developments). This framework strengthens cybersecurity compliance across the Defense Industrial Base (DIB) by aligning with NIST standards and reinforcing the security posture of DoD contractors. Understanding the key changes and implications of this new rule is essential for defense contractors navigating the evolving landscape of cybersecurity regulations.

Key Changes and Requirements

The CMMC Final Rule introduces significant changes to the cybersecurity requirements for DoD contractors. It places the onus of compliance timing on contractors and subcontractors, requiring them to achieve the specified CMMC level before contract awards. This shift necessitates careful consideration of business objectives, and the resources required for certification. 

Once fully implemented, the DoD will only accept assessments from authorized and accredited Certified Third-Party Assessment Organizations (C3PAOs) or certified CMMC Assessors (DoD CIO, Cyber AB). This ensures a standardized approach to cybersecurity evaluation across the DIB. The proposal introduces a tiered system for assessments based on the sensitivity of the information handled.  Contractors dealing with Federal Contract Information (FCI) will be required to perform annual self-assessments, while those managing critical national security information will undergo CMMC Level 2 third-party assessments. The most critical defense programs will face government-led assessments. (Atlantic Digital

Additionally, the rule introduces a CMMC assessment appeal process, allowing organizations to address disputes related to assessor errors or unethical conduct. However, ultimate liability in assessment disputes remains between the organization seeking certification and the C3PAO (DoDCIO). To maintain transparency and accountability, the DoD will have access to assessment results and final reports. Contractors’ self-assessment results will be stored in the Supplier Performance Risk System (SPRS), while CMMC certificates and third-party assessment data will be housed in the CMMC Enterprise Mission Assurance Support Services (eMASS) database (DoD CIO). 

Impact on Small and Medium Businesses

The CMMC Final Rule has significant implications for small and medium businesses (SMBs) in the DIB. These organizations face unique challenges in achieving compliance with the new cybersecurity standards.  

One of the primary hurdles is the correct identification and categorization of CUI and FCI. Many small businesses struggle with this task (DoD CIO). Additionally, the financial burden of implementing CMMC requirements presents a significant concern for these businesses. The costs associated with security controls, audit preparation, and the certification process can be substantial, placing a heavy strain on companies with limited budgets (Atlantic Digital). Furthermore, small businesses must also consider the operational, technical, legal, and scheduling implications of either achieving or failing to meet compliance standards, which can affect their ability to continue doing business with the DoD (Atlantic Digital). SMBs need to work proactively to address these challenges, to enhance cybersecurity resilience, and capitalize on growth opportunities in the defense sector.

Preparing for FY25 Implementation

As the Department of Defense (DoD) prepares for full CMMC implementation, contractors must take calculated measures to ensure compliance. The phased rollout plan, expected to begin in FY25, underscores the need for readiness, as the number of contracts requiring CMMC certification is projected to increase significantly. (ClearanceJobs, Atlantic Digital). 

To prepare, organizations should first identify their required CMMC level based on the sensitivity of the information they handle. Conducting a thorough NIST 800-171 and CMMC gap analysis is crucial to assess the current cybersecurity posture. Companies must then develop comprehensive System Security Plans (SSPs) and Plans of Action & Milestones (POA&Ms) to address any identified gaps (Federal Register). 

Partnering with a C3PAO is crucial for the certification process. However, to prevent conflicts of interest, C3PAOs are prohibited from offering consulting services before conducting their assessments. This is where Atlantic Digital (ADI) comes in. As a consultant, ADI provides expert guidance that simplifies the certification process, ensuring timely compliance and facilitating smooth access to government contracts.

Conclusion

The evolving cybersecurity landscape and the DoD’s push to enhance protection through the CMMC final rule represent a significant shift for defense contractors. The framework aims to strengthen the cybersecurity posture of organizations across the DIB by aligning with NIST standards and streamlining compliance requirements. With the phased implementation plan set to begin in FY25, it is crucial for contractors to proactively address the upcoming changes. 

Understanding the intricacies of the proposed CMMC final rule is essential for organizations seeking to maintain and secure their defense contracts. The adjustments outlined in the Federal Register Final Rule emphasize the need for contractors to be vigilant, prepared, and aligned with new compliance requirements. By conducting thorough gap analyses, developing robust security plans, and engaging with experts at organizations such as ADI, contractors can better navigate the complexities of CMMC certification and ensure they meet the necessary standards. 

As the defense sector prepares for these pivotal changes, staying informed and taking decisive action will be crucial for maintaining a competitive edge and safeguarding sensitive information. The CMMC Final Rule represents not only a regulatory shift but also an opportunity for organizations to enhance their cybersecurity resilience and align with industry best practices. Contact Atlantic Digital to learn more about how our tailored services can safeguard your organization’s future in the evolving landscape of defense industry cybersecurity.

 

CMMC Timeline

Introduction 

The Cybersecurity Maturity Model Certification (CMMC) serves as a vital framework established by the Department of Defense (DoD) to bolster cybersecurity within the Defense Industrial Base (DIB). As cybersecurity threats continue to evolve, the necessity for a comprehensive certification process has become increasingly urgent. The publication of the 32 CFR Cybersecurity Maturity Model Certification (CMMC) 2.0 Final Rule in the Federal Register on October 15, 2024, marks a pivotal development in the DoD’s mission to safeguard sensitive information. This framework is designed not only to enhance compliance among defense contractors but also to ensure the implementation of robust security measures essential for protecting Controlled Unclassified Information (CUI).

Understanding the nuances of the Federal Register is critical in this context, as it serves as the official journal of the U.S. government, detailing proposed and final rules along with other significant regulatory documents.

The Federal Register and Its Role in Rulemaking 

The Federal Register plays a crucial role in the rulemaking process by providing transparency and enabling public feedback on proposed regulations. The publication of a proposed rule in the Federal Register follows a period of internal development and review, leading to a public comment period where stakeholders can express support, concerns, or suggestions for modifications. Although the timeline for finalizing a rule can vary, the publication of a proposed rule signifies the DoD’s intent to enforce new cybersecurity standards, making these requirements binding across the DIB.  Once a rule is finalized, it is officially published in the Federal Register as a Final Rule, signaling that all public input has been considered, and the rule is ready to be implemented and enforced as law. (Federal Register). 

Timeline for the CMMC Program 

Building on the foundation established by the Federal Register, understanding the evolution of the CMMC program leading to CMMC 2.0 is essential. It is important to note that the security requirements forming the basis of CMMC 2.0 Level 2, as outlined in NIST SP 800-171, have been mandatory for DoD contractors handling sensitive information since December 2017. This requirement followed the introduction of DFARS clause 252.204-7012, which addresses the safeguarding of Covered Defense Information and Cyber Incident Reporting in DoD solicitations and contracts. However, enforcement of these requirements initially relied on self-attestation, lacking an effective verification process.

Consequently, many contractors did not fully implement the necessary security controls, which limited the DoD’s ability to ensure compliance. In response to these challenges, the DoD initiated the CMMC program as a structured framework for verifying compliance with the DFARS requirements. This initiative established a system through which compliance is assessed by CMMC Third Party Assessment Organizations (C3PAOs), which are certified by the DoD (RiskInsight). 

Some of the CMMC program key milestones are as follows:  

  1. In 2019, the DoD announced the development of the Cybersecurity Maturity Model Certification (CMMC) as a crucial step to enhance the cybersecurity posture of the Defense Industrial Base (DIB) sector against evolving threats. This initiative was conceived by the Office of the Under Secretary of Defense for Acquisition and Sustainment (OUSD(A&S)) to transition from a self-attestation model of security to a structured certification process (Federal Register). 
  1. On September 9, 2020, the DoD published the 48 CFR CMMC interim rule to the DFARS in the Federal Register (DFARS Case 2019-D041 85 FR 48513), which implemented the DoD’s initial vision for the CMMC program (“CMMC 1.0”) (DoDCIO, Federal Register).  This rule integrated requirements from the DFARS clause DFARS 252.204-7012, mandating defense contractors to implement NIST SP 800-171 controls to safeguard Covered Defense Information (CDI—Unclassified information specifically connected to defense contracts, programs, or operations), and report cyber incidents within 72 hours (Summit7). Additionally, it extended these obligations to subcontractors throughout the supply chain, introducing clauses like 252.204-7020 and 252.204-7021 that govern compliance with CMMC requirements and assessment methodologies. This shift formalized the CMMC certification process and emphasized the importance of protecting Controlled Unclassified Information (CUI), which is sensitive information that, while not classified, could still pose a risk to national security or other critical interests if improperly disclosed. 
  • CMMC 1.0 ensured that contractors handling CUI met a baseline cybersecurity standard and could respond quickly to cyber incidents. It required these contractors to obtain third-party CMMC certification through C3PAOs, marking a significant departure from the self-attestation approach under DFARS 252.204-7012.  The interim 48 CFR CMMC 1.0 rule became effective on November 30, 2020, marking the start of a phased rollout of CMMC requirements over five years (Federal Register, DoDCIO, CyberSheath, Acquisition.gov, LII / Legal Information Institute). 
  1.  In March 2021, the Department initiated an internal review of CMMC’s implementation, responding to approximately 750 public comments on the 48 CFR CMMC interim final rule. This review led to proposed updates, that would ensure the incorporation of the latest CMMC 2.0 requirements into the federal acquisition process. These updates were intended to provide clarity and enforce compliance, aligning cybersecurity requirements with the CMMC standards (Federal Register). 
  1. The DoD announced 32 CFR CMMC 2.0, on November 4, 2021. This revision aimed to simplify the certification structure to three levels and reduce the cost burden on small and medium-sized businesses (SMBs), while also aligning assessments with NIST standards and maintaining key protections outlined in DFARS 252.204-7012 (Summit7, DoDCIO, CyberSheath), The 32 CFR CMMC 2.0 Proposed Rule was subsequently published in the Federal Register on December 26, 2023 (DoD).  
  1. On June 27, 2024, the DoD submitted a draft of the 32 CFR CMMC 2.0 Final Rule to the Office of Information and Regulatory Affairs (OIRA), which is part of the standard rulemaking process, marking a key step toward the finalization of CMMC 2.0 (RiskInsight).    
  1. Additionally, on August 15, 2024, the DoD issued a Proposed Rule to amend the Defense Federal Acquisition Regulation Supplement (DFARS), incorporating the latest CMMC 2.0 requirements (Arnold & Porter, Atlantic Digital). This amendment updates the existing requirements of DFARS 252.204-7021, which outlines the cybersecurity certification levels that contractors must achieve to handle sensitive defense information. This rule builds directly upon the requirements established in DFARS 252.204-7012.  It also aligns with 32 CFR 117.8, which specifies reporting requirements for contractors working with classified information. Both 32 CFR 117.8 and the DFARS regulations emphasize the importance of reporting security incidents and any material changes that could affect defense contracts. (National Archives, DoD).  Following its publication in the Federal Register, the Proposed Rule initiated a public comment period. Once this period concludes and revisions are implemented based on stakeholder feedback, the rule is expected to be finalized in early 2025, becoming enforceable and requiring all contractors to comply with the updated CMMC 2.0 standards to be eligible for DoD contracts. This proposed rule will also serve as an update to the 48 CFR, which governs the entire federal acquisition process, ensuring consistent alignment with cybersecurity requirements. 
  1. Finally, the 32 CFR CMMC 2.0 Final Rule was published on October 15, 2024, and will become effective on December 16, 2024. This rule mandates that contractors must be certified under CMMC 2.0 before they can bid on or be awarded defense contracts; thereby, enforcing the CMMC 2.0 requirements across the DIB. The phased rollout will facilitate a gradual compliance process for contractors, ultimately strengthening cybersecurity across the entire defense supply chain.  The full impact of the Final Rule is expected to manifest in early 2025 (Arnold & Porter, ECURON). 

In sum, the 48 CFR Final Rule, which includes the DFARS as a supplement to the Federal Acquisition Regulation, will enforce compliance through contractual obligations. In contrast, the 32 CFR Final Rule will outline the detailed cybersecurity practices contractors are required to adopt. This alignment between the DFARS and the 32 CFR Final Rule demonstrates the DoD’s concerted effort to integrate stringent cybersecurity controls and reporting protocols into defense contracts, ensuring that the entire defense supply chain is fortified against potential cybersecurity threats.

Conclusion

The timeline of the CMMC program reflects a critical evolution in the DoD’s approach to cybersecurity. The integration of the CMMC requirements into the federal acquisition process, as detailed in the Federal Register, underscores the importance of a structured, enforceable framework for protecting sensitive information. By mandating compliance and certification, the DoD is taking essential steps to enhance the cybersecurity posture of the Defense Industrial Base, ensuring that contractors are equipped to manage and mitigate potential threats effectively. To learn more about the CMMC timeline and its implications, visit the Atlantic Digital Blog or contact us for a consultation regarding your CMMC compliance needs.

How to Use a Password Vault for Enhanced Security

In a world where cybercrime lurks around every digital corner, protecting our online identities has become a high-stakes game. Enter the password vault, a game-changer in the realm of cybersecurity. This nifty tool isn’t just another tech gadget; it’s a fortress for your digital life, guarding your most sensitive information from prying eyes and sneaky hackers. As data breaches become more common than cat videos on the internet, having a reliable password manager is no longer a luxury—it’s a necessity. 

Let’s dive into the world of password vaults and discover how they can transform your online security. We’ll explore why these digital safes are crucial in today’s cyber landscape, how to pick the perfect one for your needs, and the tricks to squeeze every ounce of protection from your chosen vault. Plus, we’ll uncover the magic of multi-factor authentication and how it teams up with your password vault to create an impenetrable shield for your digital identity. By the end, you’ll be ready to kick those weak, reused passwords to the curb and embrace a future where remembering “password123” is a thing of the past.

The Importance of Password Security

In the digital age, password security stands as the frontline defense against cyber threats. Yet, many people underestimate its significance, leaving their digital lives vulnerable to attacks. Stolen credentials are among the most prominent causes of data breaches within organizations (Verizon, Norton). This underscores the critical need for robust password practices.

Common Password Mistakes

People often make several password mistakes that compromise their security: 

  1. Reusing passwords: Nearly two thirds of people reuse the same password for multiple online accounts. This practice significantly increases the risk of multiple account compromises if one password is breached. 
  1. Using personal information: Many choose passwords based on personal details like pet names. This information is often easily obtainable through social engineering, making passwords vulnerable to guessing attacks. 
  1. Opting for weak combinations: Common passwords like “123456” or “password” are still widely used. These are among the first combinations attackers attempt, making accounts easy targets. 
  1. Insufficient length: Short passwords are inherently less secure . Each additional character exponentially increases the number of possible combinations, enhancing security. 

(LastPass, Norton)

Risks of Weak Passwords

The consequences of weak passwords can be severe: 

  1. Unauthorized access: Weak passwords open the door to unauthorized entry into personal and business accounts. 
  1. Identity theft: A single compromised password can lead to identity theft, with attackers using stolen credentials to impersonate individuals and engage in fraudulent activities. 
  1. Financial losses: For businesses, a breached account can result in stolen funds or intellectual property, potentially costing millions. 
  1. Reputational damage: Security breaches often lead to lost customer trust and potentially irreparable brand damage. 

(IBM, Norton)

Benefits of Using a Password Vault

A password vault, also known as a password manager, offers a solution to these security challenges: 

  1. Enhanced security: Password managers store and encrypt passwords, enabling users to easily and safely log into their accounts. 
  1. Convenience: Users only need to remember one master password, alleviating the burden of memorizing multiple complex passwords. 
  1. Automatic updates: Many password managers can automatically update passwords, ensuring they remain strong and unique. 
  1. Security alerts: These tools often include features like security alerts for compromised sites, helping users stay informed about potential threats. 

(CISA)

By using a password vault, internet users can significantly reduce their risk of identity theft. Those without password managers are three times more likely to experience identity theft compared to those who properly use them (CNBC).

Choosing the Right Password Vault

In the digital age, selecting the right password vault is crucial for safeguarding one’s online identity. With numerous options available, it’s essential to understand the key features and considerations when choosing a password manager.

Key Features to Look For

When evaluating password vaults, several critical features stand out: 

  1. Multi-Platform Support: A good password manager should work seamlessly across various devices and operating systems, including Windows, Android, iOS, and macOS. 
  1. Strong Encryption: Look for password managers that use AES 256-bit encryption, the Department of Defense standard for data protection. 
  1. Password Generator: An effective password generator creates strong, unique passwords that are practically impossible to crack. 
  1. Autofill Functionality: This feature automatically fills in login credentials, saving time and protecting against keyloggers. 
  1. Secure Sharing: The ability to share passwords securely with family members or colleagues is a valuable feature. 
  1. Multi-Factor Authentication (MFA): Enabling MFA for the password vault itself adds an extra layer of security. 

(Password Boss)

Popular Password Vault Options

Several password managers have gained popularity due to their robust features: 

  1. NordPass: Recognized for its top-notch premium features and well-organized mobile apps 
  1. Bitwarden: A popular choice for free password management with unlimited credential storage 
  1. 1Password: Known for its Watchtower function, which checks for compromised websites and vulnerable passwords 
  1. Enpass: Offers free desktop use and local data storage options

(PC Mag, tech radar, CBS News)

Free vs Paid Solutions

The choice between free and paid password managers depends on individual needs: 

Free Options: 

  • Bitwarden, LogMeOnce, NordPass, and Proton Pass offer unlimited credential storage for free users. 
  • Some free plans provide basic features but often come with limitations. 

Paid Solutions: 

  • Offer advanced features like secure password sharing and dark web monitoring. 
  • Typically provide better cross-platform support and synchronization. 
  • Business plans often include admin dashboards for managing team security. 

(PCWorld

Ultimately, while free password managers can be sufficient for basic needs, paid solutions offer more comprehensive features and enhanced security measures. For businesses, a paid subscription is often essential to ensure robust protection against potential data breaches.

Maximizing Your Password Vault’s Security

Creating a Strong Master Password

The cornerstone of password vault security lies in crafting an unbreakable master password. This digital key should be a unique, 16-character-long fortress that would make even the most determined hacker throw in the towel. Forget about using “Fluffy2022” – that’s about as secure as a paper lock on a bank vault. Instead, think random and complex. Mix uppercase and lowercase letters, sprinkle in some numbers, and don’t forget those special characters – they’re the secret sauce of password security. 

For those who struggle to remember complex strings, consider using a passphrase. It’s like a secret code that only makes sense to you. For instance, “dedicate-dial9-osmosis” is not only a mouthful but also takes centuries to crack. Just remember, your master password should be as unique as your fingerprint – never reuse it for any other account (Bitwarden).

Enabling Additional Security Features

Two-factor authentication (2FA) is like adding a moat filled with digital crocodiles around your password fortress. Enable it for your password manager and every account that offers it. It’s an extra layer of defense that makes hackers think twice before attempting to breach your digital castle (Bitwarden). 

For businesses, creating separate “Collections” for different teams (DEV, MANAGEMENT, OPS, STAFF) ensures that employees only access the passwords they need. It’s like giving each department their own secret treehouse – no peeking allowed!

Secure Password Sharing

Sharing passwords is like lending someone your toothbrush – it should only be done when absolutely necessary and with extreme caution. If you must share, avoid sending passwords via email – it’s about as secure as shouting them across a crowded room. Instead, use your password manager’s secure sharing feature. 

Remember, the more a password is shared, the higher the risk of compromise. When team members leave, change any passwords they had access to faster than you can say “You’re fired!”  It’s not personal; it’s just good security hygiene.

Conclusion

In today’s digital landscape, the use of a password vault has become crucial to safeguard our online identities. These digital safes offer a robust solution to common password pitfalls, providing enhanced security, convenience, and peace of mind. By leveraging features like strong encryption, multi-factor authentication, and secure password sharing, users can significantly reduce their risk of falling victim to cyber attacks and identity theft. 

Embracing a password vault is more than just a tech upgrade; it’s a fundamental shift in how we approach online security. It allows us to move beyond the limitations of human memory and the vulnerabilities of weak passwords, ushering in a new era of digital protection. To learn more about cybersecurity and how to secure your business, contact Atlantic Digital for expert guidance. Remember, in the ever-evolving world of cybersecurity, staying ahead of threats is not just smart—it’s essential to protect what matters most in our digital lives.

Cyber Attacks on the Rise: Understanding New and Emerging Cyber Threats 

In an increasingly interconnected world, the specter of cyber attacks looms larger than ever before. As our reliance on digital technologies grows, so too does the sophistication and frequency of malicious activities in cyberspace. From crippling ransomware attacks to stealthy data breaches, the landscape of cyber threats has an impact on individuals, businesses, and nations alike. The cyber attacks map continues to expand, revealing a global battlefield where the biggest cyber attacks in history have left indelible marks on our collective consciousness. 

This article delves into the evolving nature of cyber threats, shedding light on the various types of cyber attacks that pose significant risks in today’s digital age. It explores the emergence of Advanced Persistent Threats (APTs), highlighting their long-term, targeted approach to compromising sensitive information. Furthermore, the piece examines the alarming rise of Ransomware-as-a-Service (RaaS), a business model that has democratized cybercrime and increased its reach. By understanding these new and emerging threats, readers will be better equipped to safeguard their digital assets and contribute to a more secure cyberspace. 

The Evolving Landscape of Cyber Threats

The cyber threat landscape continues to evolve rapidly, impacting individuals, businesses, and nations alike. As the frequency and sophistication of attacks increase at an alarming rate, organizations across all sectors are facing an unprecedented level of risk. 

Among these threats, ransomware attacks have become increasingly prevalent, now accounting for “one out of every four breaches” (Verizon). This surge is exacerbated by the expansion of the Internet of Things (IoT), which has opened new avenues for cybercriminals, and with the number of IoT devices expected to reach nearly 30 billion by 2030 (Statista), the potential for exploitation continues to grow. Concurrently, social engineering attacks (including phishing, whaling, and vishing-voice phishing) have gained prominence, particularly with the widespread shift to remote workforces. This acceleration of digitization and remote working, spurred by the COVID-19 pandemic, further expanded the attack surface for cybercriminals (WEF).

Compounding these risks, the ongoing rollout of 5G technology introduces additional security vulnerabilities, and the advent of quantum computing poses significant challenges to current cybersecurity protocols (NIST), with the potential to break traditional encryption methods and render existing defenses obsolete. 

Sector-specific risks are also becoming increasingly apparent. According to the European Repository of Cyber Incidents (EuRepoC), state institutions and political systems are the most commonly targeted, accounting for “53% of all incidents.” Critical infrastructure is another primary target, representing 38.55% of incidents, with the healthcare sector facing 20.8% of all attacks. Financial organizations are also heavily targeted, making up 19.3% of attacks on critical infrastructure. The 2024 IBM X-Force Threat Intelligence Index report further underscores that the manufacturing industry is highly vulnerable to malware and ransomware attacks. Additionally, professional, business and consumer services, energy organizations, and the retail and wholesale industry are among those at the highest risk (IBM).

Understanding Advanced Persistent Threats (APTs)

Advanced Persistent Threats (APTs) are sophisticated, prolonged cyberattacks targeting specific organizations to steal sensitive data. These attacks are typically carried out by well-funded, experienced cybercriminal teams. APTs often utilize multiple attack methods, including spear phishing, zero-day exploits, and supply chain attacks. Their primary objectives include data theft, sabotage, and long-term monitoring of targeted networks. 

APTs exhibit several key characteristics: 

  1. Specific goals and objectives 
  1. Enhanced timeframe for operation 
  1. Multiple points of compromise 
  1. Coordinated and well-resourced attacks 
  1. Expensive to execute 
  1. Redundant points of entry 

(Niels G., SoftwareLab, M-Trends, St. John

To mitigate APT risks, organizations should: 

  1. Implement robust access control measures (NIST
  1. Utilize EDR and XDR tools for real-time threat detection (Gartner, Gartner
  1. Conduct regular penetration testing (OWASP, NIST
  1. Monitor network traffic for anomalies (NIST

These strategies can help organizations detect and respond to APT attacks more effectively.

The Rise of Ransomware-as-a-Service (RaaS)

Ransomware-as-a-Service (RaaS) has emerged as a grave threat in the cybercrime landscape. This malicious adaptation of the software-as-a-service model allows even novice criminals to execute sophisticated ransomware attacks. RaaS operators develop and maintain the ransomware tools, selling them to affiliates who carry out the attacks. The business model typically involves revenue sharing, with affiliates paying a percentage of successful ransom payments to the operators (Microsoft). 

RaaS operates similarly to legitimate SaaS businesses. Operators provide ransomware kits, infrastructure, and even customer support to their affiliates. Revenue models vary, including monthly subscriptions, one-time fees, and profit-sharing arrangements. Some high-profile groups even interview potential affiliates to ensure their capabilities. 

The rise of RaaS has led to a significant increase in ransomware attacks. In 2022, the average ransom demand climbed 144% to $2.2 million, while the average payment rose 78% to $541,010 (paloalto). These attacks can be particularly devastating for critical infrastructure, healthcare organizations, and businesses relying on sensitive data for daily operations. 

To combat RaaS threats, organizations should implement robust cybersecurity measures. These include maintaining offline backups, regularly applying security patches, and implementing access controls such as multi-factor authentication and network segmentation. Employee training on recognizing phishing attempts and social engineering tactics is crucial. Additionally, organizations should develop comprehensive incident response plans to address potential RaaS attacks swiftly and effectively (Microsoft, SentinelOne, CISA, FCC).

Conclusion

The ever-changing landscape of cyber threats continues to pose significant challenges for individuals, businesses, and nations alike. From the rise of Advanced Persistent Threats to the alarming spread of Ransomware-as-a-Service, the digital world faces an array of sophisticated attacks that have an impact on our collective security. As we navigate this complex environment, it’s crucial to stay informed about emerging threats and to implement robust cybersecurity measures to protect our digital assets. 

To tackle these challenges head-on, organizations must prioritize cybersecurity awareness, invest in cutting-edge defense technologies, and develop comprehensive incident response plans. Regular security audits, employee training, and staying up-to-date with the latest threat intelligence are essential steps to strengthen our digital defenses.  

To learn more and to secure your business, reach out to Atlantic Digital. By working together and staying vigilant, we can build a more resilient digital future and mitigate the risks posed by evolving cyber threats. 

Feasibility of SMBs in the Defense Industrial Base

Introduction

The feasibility of small to medium-sized businesses (SMBs) within the Defense Industrial Base (DIB) is largely dependent on their ability to achieve Cybersecurity Maturity Model Certification (CMMC) in 2025. This certification is essential for securing and renewing contracts with the Department of Defense (DoD), driven by the need to safeguard Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) from cybersecurity threats. 

In 2025, many DoD contracts, especially those involving CUI, will mandate CMMC Level 2 certification. This requirement is part of a phased implementation strategy by the DoD, with full enforcement expected by fiscal year 2026. The DoD provided an estimate that about 80,598 entities will be affected by the CMMC Level 2 requirements. Of these, it is anticipated that around 95% (approximately 76,598 entities) will need to obtain certification from a Certified Third-Party Assessor Organization (C3PAO) due to the involvement of Controlled Unclassified Information (CUI) in their contracts, rather than relying on self-assessment alone (Venable LLP; The National Law Review; InterSec). 

Achieving CMMC Level 2 involves meeting 320 assessment objectives outlined in NIST SP 800-171a, posing a substantial challenge for SMBs with limited cybersecurity resources. The DoD has estimated that the cost for small defense contractors to achieve this certification is around $104,670 (Prevail), covering third-party assessments and ongoing compliance efforts. However, real-world scenarios suggest that the actual costs may vary significantly (Atlantic Digital, Etactics). The transition to CMMC, announced in November 2021, has simplified the certification process by reducing the levels from five to three, thereby easing some administrative burdens on smaller businesses. Nonetheless, maintaining certification remains a challenge for SMBs. The high demand for certified assessors as the compliance deadline nears further emphasizes the need for early preparation. 

While the path to CMMC Level 2 certification is demanding, it offers an opportunity for SMBs to strengthen their cybersecurity posture and secure a position in the defense contracting landscape. The ability of these businesses to navigate these requirements will be crucial for their continued participation in the DIB and the resilience of the broader defense supply chain. For SMBs unsure whether CMMC Level 2 is necessary, it is essential to check their contracts for DFARS Clause 252.204-7012, “Safeguarding Covered Defense Information and Cyber Incident Reporting.” This clause, enforced since 2016, mandates that contractors implement the security requirements specified in NIST SP 800-171 to protect Covered Defense Information (CDI) and report cyber incidents to the DoD. Achieving CMMC Level 2 ensures compliance with these rigorous standards, emphasizing foundational and advanced cybersecurity practices crucial for securing sensitive information and supporting national security. 

Operational and Technical Feasibility

Compliance with CMMC Level 2 requires alignment with NIST SP 800-171 standards, which specify security requirements for nonfederal information systems, and are essential for protecting CUI (NIST). Organizations must assess whether their processes, workforce, and systems can support the demands of CMMC Level 2. The Center for Development of Security Excellence (CDSE) highlights the need for a well-prepared workforce and robust processes (CDSE). Similarly, the Cybersecurity and Infrastructure Security Agency (CISA) underscores that a comprehensive approach combining technological solutions with staff training is vital for CMMC Level 2 compliance (CISA); thus, SMBs need to establish the necessary cybersecurity infrastructure, invest in cybersecurity technologies, and workforce training and development to meet these standards.

Economic Feasibility

The economic feasibility of achieving CMMC Level 2 certification is a major concern for SMBs in the DIB. Government estimates for certification costs often underestimate the full scope of expenses. A thorough cost-benefit analysis must account for initial assessment costs and recurring expenses for maintaining compliance.

Initial Assessment Costs 

According to the DoD, “a Level 2 certification assessment is projected to cost nearly $105,000 for small entities and approximately $118,000 for larger entities (including the triennial assessment and affirmation and two additional annual affirmations)” (in Defensescoop). However, real-world examples show significant variation in initial assessment costs, from $30,000 to $381,000 (Etactics). For a small organization requiring a basic 4-person, cloud-only setup, Atlantic Digital (ADI) has been quoted $30,000, whereas larger organizations face costs closer to $100,000. These figures cover assessments by a C3PAO but exclude costs for technology upgrades, staff training, and long-term compliance (Atlantic Digital). 

Cost Considerations 

  1. Technology and Infrastructure Upgrades: Essential upgrades can be costly. For instance, engineering costs for CMMC Level 3, which builds on Level 2, range from $490,000 to $21.1 million (Farmhouse, Dewpoint). These figures, while for Level 3, highlight the substantial investments needed even at Level 2. 
  1. Staffing and Outsourcing: Hiring specialized staff or consultants is often necessary. External consultant costs can start at $60,000 annually, rising to $150,000 and beyond for comprehensive support (Atlantic Digital). 
  1. Operational Costs: Ongoing expenses include training programs and upgrades: 
Operational Costs 
KnowBe4 for training $9,072/year  
Endpoint upgrades $1,000/user  
DocuSign $3,000/year  
External Certificate Authority (ECA) $500/user  
Privileged User Training $400 /Privileged User annually  
Password Vault $96/Privileged User annually 
  1. Migration and Implementation Costs: Medium-sized companies have spent over $1 million annually over three years for cloud migrations and an additional $240,000/year for consulting, staff augmentation and compliance maintenance (Atlantic Digital). 
  1. Additional Costs: SMBs with on-premises CUI handling may face extra costs for printing, upgrades, infrastructure improvements, and physical security (Atlantic Digital). 

In short, the financial burden of achieving and maintaining CMMC Level 2 compliance can be significant for SMBs. While federal estimates provide a starting point, actual costs can be much higher. A comprehensive approach, including detailed cost estimations and leveraging cost-effective services, is essential for SMBs to navigate these economic challenges. 

Atlantic Digital has published a blog post detailing the expenses associated with CMMC certification and discussing why the government often underestimates these costs.

Legal Feasibility

Adherence to DoD cybersecurity and data protection regulations is crucial to avoid legal and financial repercussions. The Defense Counterintelligence and Security Agency (DCSA) emphasizes that compliance is essential for continued participation in DoD contracting opportunities (DCSA, InterSec). Non-compliance could result in loss of contracts and financial penalties.

Schedule Feasibility

The 2025 deadline for CMMC Level 2 presents a significant challenge due to the limited number of Certified Third-Party Assessment Organizations (C3PAOs). As of July 2024, about 56 C3PAOs are available, each capable of handling 1 to 10 assessments per month, resulting in an estimated 504 to 5,040 assessments before the deadline. This assessment capacity may be insufficient to meet the needs of the many small and medium-sized businesses (SMBs) seeking certification, given the rigorous and resource-intensive nature of the CMMC assessment process. The high demand emphasizes the need for timely scheduling and thorough planning (CyberAB, Taft Privacy & Data Security Insights; MxD; CMMC Audit Preparation; PreVeil). 

Typical timelines for achieving CMMC Level 2 certification range from 6 to 12 months, depending on factors like existing cybersecurity posture and resource allocation. Organizations without existing cybersecurity measures may require 18 to 24 months to achieve certification (CMMC Audit Preparation; ECURON; InterSec).

Market Feasibility

The global cybersecurity market is projected to expand from USD 190.4 billion in 2023 to USD 298.5 billion by 2028, with a compound annual growth rate (CAGR) of 9.4% (MarketsandMarkets). This growth is driven by the increasing frequency and complexity of cyberattacks, along with the rising demands placed on businesses, governments, and individuals to enhance their cybersecurity measures. The U.S. Department of Defense (DoD) has allocated approximately $401 billion—nearly 49% of its total $842 billion Fiscal Year 2024 budget—for contract obligations (Defense Comptroller). This budget includes a historic $170 billion for procurement, the largest ever (Federal Budget IQ), aimed at acquiring the weapons, equipment, and services necessary to maintain and improve military operational capabilities. DoD Defense Industrial Base (DIB) contractors are integral to these procurement efforts, underscoring the critical importance of robust cybersecurity measures.  

CMMC Level 2 requirements are mandated for all DoD contracts involving CUI, with exceptions only for contracts that exclusively pertain to commercial off-the-shelf (COTS) items. The DoD anticipates that 220,000 companies -the DIB encompasses roughly 300,000 companies (DoD)- will be affected by CMMC requirements in general, and CMMC Level 2 applies to over 80,000 entities (about 36%) of those contractors (Wiley, Blank Rome). Achieving CMMC Level 2 certification not only aligns with the DoD’s significant emphasis in cybersecurity but also presents substantial opportunities for certified businesses within both the broader cybersecurity market and the DoD’s defense sector (USFCR).

Financial Impact of Non-Compliance

Failing to achieve the required CMMC certification by 2025 could lead to significant financial losses for all contractors. The potential revenue loss includes: 

  1. Immediate Revenue Loss: Government contractors often rely heavily on a few key contracts. The value of these contracts can range widely, but for many small businesses, a single contract can be worth anywhere from $100,000 to several million dollars annually. 
  1. Dependency on DoD Contracts: Many DIBs primarily serve the DoD. Failing to get certified could result in losing most or all of their revenue. For example, if a business has $1 million in annual revenue from DoD contracts, failing to certify would mean losing this revenue entirely. 
  1. Future Opportunities: The lack of CMMC Level 2 certification will make businesses ineligible to compete for an estimate of over $100 billion of the larger $401 billion budget allocated for DoD contract obligations. 

Benefits of Compliance

Achieving CMMC Level 2 certification provides several key benefits for small and medium-sized businesses (SMBs), including: 

  1. Regulatory Compliance: Ensures adherence to stringent cybersecurity practices required by the DoD, thereby enhancing the credibility and market positioning of SMBs.  
  1. Market Opportunities: Opens doors to new opportunities with other federal agencies and commercial entities, supporting business continuity and growth. 
  1. Competitive Edge: Prevents the loss of DoD contracts and supports long-term resilience by complying with CMMC requirements. 

(USFCR)

Conclusion

In sum, the feasibility of SMBs in the DIB hinges on their ability to meet CMMC Level 2 certification by 2025. Achieving this certification presents both challenges and opportunities. Financially, SMBs must navigate significant costs, including assessment fees, technology upgrades, and ongoing compliance expenses. Operationally, preparing for certification requires robust cybersecurity infrastructure and staff training. By strategically planning and leveraging cost-effective solutions, SMBs can enhance their chances of achieving certification and securing their place in the defense contracting ecosystem. The benefits of compliance include enhanced market opportunities, competitive advantage, and alignment with national security goals. The upcoming deadline underscores the importance of timely and proactive measures to ensure continued participation in the DIB. 

To support SMBs in this critical endeavor, Atlantic Digital (ADI) offers specialized services to help businesses achieve CMMC Level 2 certification efficiently and cost-effectively. ADI provides expert guidance through initial assessments, gap analyses, and tailored cybersecurity solutions, ensuring that SMBs meet the stringent requirements necessary to maintain or secure DoD contracts. By partnering with Atlantic Digital, SMBs can not only overcome the financial and operational challenges of CMMC certification but also strengthen their cybersecurity posture. This partnership enables SMBs to remain competitive in the DIB and capitalize on the vast market opportunities that come with compliance. For more information on how Atlantic Digital can assist your business in achieving CMMC Level 2 certification, visit Atlantic Digital.

References

  1. Air & Space Forces Magazine. (2024). Pentagon: 2024 Budget is ‘First and Foremost‘ About Procurement.  
  1. Atlantic Digital. 2024. Internal records. 
  1. Blank Rome. (2024). https://www.blankrome.com/publications/understanding-basics-cmmc-level-2 
  1. CDSE. (2024). Center for Development of Security Excellence (CDSE). Cybersecurity (cdse.edu) 
  1. CISA. (2024). CMMC 2.0 Program Overview.  
  1. CMMC Audit Preparation. (2024) CMMC Compliance FAQs – Organizations seeking certification (cmmcaudit.org) 
  1. CyberAB. (2024). CyberAB 
  1. Compliance Island. Compliance Island Total Cost Estimator 2023.xlsx. 
  1. Defense Comptroller. (2024) Financial Summary Tables. Under Secretary of Defense (Comptroller) > Budget Materials > Budget2024 
  1. Defense.gov. (2024). DOD Harnessing Emerging Tech to Maintain Enduring Advantage.  
  1. Dewpoint. (2024). CMMC in 2024: The Basics, Costs, and Timeline 
  1. DCSA. (2024). Controlled Unclassified Information (CUI) Protocols.  
  1. Defensescoop (2024). Pentagon reveals updated cost estimates for CMMC implementation 
  1. DoD. (2024). Defense Industrial Base Cybersecurity Strategy 2024.  
  1. ECURON. (2024). CMMC Certification Process and Timeline – ECURON 
  1. Etactics (2024) CMMC 2.0 Certification Cost: An Accurate Assessment — Etactics 
  1. Farmhouse Networking. 2024. CMMC Certification: A Comprehensive Cost Guide for Government Contractors 
  1. Federal Budget IQ. (2023). Biden’s FY24 DOD Budget | Federal Budget IQ 
  1. GAO (Government Accountability Office). (2024). 
  1. InterSec. (2024). The Complete CMMC 2.0 Guide (intersecinc.com) 
  1. MarketsandMarkets. (2024). Market Reports 
  1. MxD. (2024). CMMC 2.0: Why Manufacturers Should Get Started Now | MxD (mxdusa.org) 
  1. NIST. (2024). Protecting Controlled Unclassified Information in Nonfederal Information Systems and Organizations. 
  1. PreVeil. (2024). 6 Ways to Save Money on CMMC Certification Costs (preveil.com). 
  1. PreVeil. (2024). What is DFARS 7012 and Why It’s Important (preveil.com) 
  1. Pivot Point Security. (2024). CMMC Audit Preparation.  
  1. Taft Privacy & Data Security Insights. (2024). CMMC 2.0 Is Here to Stay: Where Do We Start? 
  1. The National Law Review. (2024). https://natlawreview.com/article/understanding-basics-cmmc-level-2 
  1. USFCR. (2024) 2024 UPDATE: Cybersecurity Maturity Model Certification (CMMC) 2.0 (usfcr.com) 
  1. Venable. (2024). https://www.venable.com/insights/publications/2023/12/the-new-cmmc-rule-faqs-for-federal-contractors 
  1. Wiley. (2024). https://www.wiley.law/alert-UPDATE-DOD-Proposed-Rule-Solidifies-Plans-for-CMMC-2-0-Program-Security-Requirements-Assessments-Affirmations-and-Some-Flow-Down-Details 

Atlantic Digital’s Comprehensive Solution for DIB Compliance Challenges 

As DIB organizations prepare for the mandatory transition to Cybersecurity Maturity Model Certification (CMMC) Level 2, Atlantic Digital (ADI) offers tailored services to mitigate compliance obstacles and enhance cybersecurity resilience. With extensive expertise in CISO and Enterprise Architect (EA) roles, ADI provides scalable subscription services designed to align with the evolving needs and financial constraints of small to medium-sized DIBs.

 

Critical Challenges Facing DIB Entities

Financial Constraints: The high cost of hiring and retaining cybersecurity professionals and the expenses associated with CMMC assessments.

Complex Compliance Requirements: Transitioning from self-attestation to formal certification under CMMC Level 2.

Limited Resources: Few Certified Third-Party Assessment Organizations (C3PAOs) and escalating cyber threats add to operational pressures.

Atlantic Digital’s Strategic Offerings

Scalable Subscription Services: ADI provides flexible subscription services tailored to meet the specific needs of DIB organizations:

    • Our team of seasoned vCISOs and Enterprise Architects provides a comprehensive, strategic approach to cybersecurity and compliance. From pre-assessment and customized documentation to gap analysis, POAM creation, C3PAO coordination, and continuous monitoring, we’ve got you covered.
    • Our vCISO role ensures that your organization aligns with NIST SP800-53 and MITRE standards, while also preparing you for the future with DoD CIO Zero Trust Architecture (ZTA) methodologies. Meanwhile, our Enterprise Architects bridge the gap between conceptual plans and practical implementations, ensuring your technology infrastructure supports your organizational goals and optimizes your processes.
    • With ADI’s vCISO services, you’ll gain a trusted partner who can anticipate trends, prepare your organization for evolving technologies, and drive technological change in alignment with your business strategy. Our team’s analytical acumen, creativity, and communication skills will empower you to achieve your mission and stay ahead of the competition.

Strategic Alignment with Organizational Structure: ADI collaborates with CFOs, HR leaders, and CEOs to integrate cybersecurity into the core business strategy:

    • Top-Down Organizational Restructuring: Separating roles like CIO, CISO, and EA ensures focused leadership on cybersecurity and compliance, mitigating operational conflicts and enhancing decision-making capabilities.

Cost-Effective Compliance Assurance:

    • Optimized Budget Allocation: ADI’s subscription models offer cost predictability, allowing DIBs to allocate resources efficiently towards compliance without compromising other operational priorities.
    • Preparation for CMMC Level 2 Certification: ADI assists in navigating the complexities of CMMC requirements, leveraging our expertise to streamline assessment preparations and ensure readiness.

Strategic Partnership for Future Growth:

    • Market Positioning: With significant DoD contracts requiring CMMC Level 2 certification imminent, ADI’s services position DIBs to competitively pursue and retain lucrative contracts.
    • Continuous Support and Adaptation: ADI provides ongoing monitoring, updates, and training to maintain compliance readiness amid evolving regulatory landscapes and emerging cyber threats.

Conclusion

Partnering with Atlantic Digital empowers DIB organizations to proactively address compliance challenges, enhance cybersecurity resilience, and capitalize on growth opportunities in the defense sector. Our scalable subscription services ensure cost-effective compliance without compromising security or operational efficiency, positioning your organization for sustained success amidst regulatory complexities.

Contact Atlantic Digital to learn more about how our tailored services can safeguard your organization’s future in the evolving landscape of defense industry cybersecurity.