Category Archives: Government

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

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

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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

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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.

Feasibility of SMBs in the Defense Industrial Base

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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 

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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.

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

     

    Comparing (Cybersecurity Maturity Model Certification) CMMC with Other Leading Cybersecurity Compliance Frameworks

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    Understanding cybersecurity frameworks can be confusing due to the multitude of frameworks mandated by various entities to accomplish specific goals. Most modern compliance frameworks focus on protecting an organization’s data—both the data it uses and creates—to support its business operations. The loss of data accessibility, confidentiality, or integrity can lead to severe consequences, including business closures. Compliance frameworks are designed to mitigate the most common risks identified for specific sectors or business types, and because of the variety of frameworks, there is significant overlap between them.

    For instance, every framework typically requires measures such as authentication, endpoint security, and firewalls. Despite these overlapping technologies, each framework also has unique requirements that must be strictly followed. Understanding these differences is crucial when implementing one or more frameworks. Atlantic Digital can help you navigate these requirements, assess your current compliance status, plan your implementation, and facilitate your CMMC implementation. Below is an overview of common cybersecurity frameworks and how they compare to a CMMC implementation.

    Cybersecurity Maturity Model Certification (CMMC)

    The Cybersecurity Maturity Model Certification (CMMC) framework is a comprehensive set of standards designed to enhance the cybersecurity posture of companies within the Defense Industrial Base. It draws from various global cybersecurity standards, including the UK Cyber Essentials and Australia’s Cyber Security Centre Essential Eight Maturity Model, incorporating long-standing best practices into its structure. When compared to other frameworks like the NIST Special Publications 800 Series, CMMC shares many similarities, especially with NIST SP 800-53 and SP 800-171, which are tailored for US government and federal contractors respectively. However, CMMC distinguishes itself by mandating specific levels of security based on the sensitivity of the data handled, rather than basing controls on assessed risk as NIST does. 

    ISO/IEC 27000 Family

    Another notable framework is the ISO/IEC 27000 family, which is internationally recognized and includes standards such as ISO/IEC 27001 for developing information security management systems. While ISO/IEC 27000 focuses on comprehensive security management, CMMC provides a tiered approach with three levels of requirements that scale with the type of data being protected, offering a more granular control structure. 

    Payment Card Industry Data Security Standard (PCI DSS)

    The Payment Card Industry Data Security Standard (PCI DSS) is another framework often compared with CMMC. While PCI DSS requires a fundamental level of security, CMMC’s tiered system is far more comprehensive, potentially leading to a more robust security posture when followed correctly. 

    Implementation

    The cost and difficulty of adopting various cybersecurity frameworks can vary significantly. For instance, achieving full compliance with NIST SP 800-53 is a considerable undertaking for small to medium-sized businesses. In contrast, compliance with NIST SP 800-171, CMMC and ISO/IEC 27001 is generally easier and less expensive to implement and maintain. The Cybersecurity Maturity Model Certification (CMMC) functions as a hybrid model that integrates elements from these and other frameworks, specifically tailored to the defense sector’s needs. Its structured levels enable organizations to incrementally enhance their cybersecurity measures, making it a dynamic and scalable option suitable for companies of all sizes and capabilities. For detailed comparisons and further insights into how CMMC stacks up against other compliance frameworks, resources like Totem’s analysis, Infosec’s mapping, Security Boulevard’s in-depth examination, and Mass News’s discussions on CMMC versus other regulated standards provide valuable information. These resources are excellent starting points for professionals seeking to understand the nuances and practical implications of implementing CMMC in comparison to other cybersecurity compliance frameworks. 

    Conclusion

    Navigating cybersecurity frameworks can be challenging due to numerous mandates aimed at specific goals. These frameworks are crucial for protecting an organization’s data and preventing severe consequences such as business closures. While many frameworks share common requirements, each also has unique mandates that must be followed. Understanding these distinctions is essential for effective implementation.

     

    Atlantic Digital offers expertise in navigating these complex requirements, assessing compliance statuses, planning implementations, and facilitating CMMC integrations. The CMMC framework is tailored for the Defense Industrial Base, integrating global cybersecurity standards and best practices, and mandating specific security levels based on data sensitivity. This makes it distinct from other frameworks like NIST SP 800-53 and SP 800-171, which focus on risk-based controls. 

    Ultimately, understanding and implementing the right cybersecurity framework is crucial for securing operations and sustaining growth in a digital world. Atlantic Digital’s expertise ensures businesses can navigate these complexities, secure their data, and align technology with strategic goals. 

    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.

      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!