Author: admin

Companies must prudently gather evidence of their control over Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) in support of 2025 defense contracts. 

While the timeframe of applicability of CMMC to any given company varies sharply, there is NO REASON to wait.  Waiting will decrease your likelihood of demonstrating compliance!

Most security programs are born in reaction to compliance requirements.  The best programs evolve a culture proactively safeguarding protected information and processing facilities well beyond compliance.  The Military Industrial Base (MIB) has companies with security programs in the full spectrum of maturity.  Where each company falls is unknown.  The Department of Defense hasn’t measured program capabilities – but will do so shortly.  It is time to get prepared to demonstrate to required maturity levels.

Fifty years have passed waiting for an auditable framework.  In 1984, attestation started with the Federal Acquisition Regulation (FAR).  In 2019, the Department of Defense (DoD) added the Defense Federal Acquisition Regulation Supplement (DFARS).  In 2020, the DoD introduced the Cybersecurity Maturity Model Certification (CMMC) to replace DFARS.   Companies now need verified evidence of their controls.

According to a study performed by Merrill Research, “the majority of contractors do not have the people, processes and technologies in place to meet the minimum cybersecurity requirements for doing business with the DoD, but often assess their companies as compliant when conducting their self-assessments”.[i]  Up until now, the government has merely accepted the contracting organization’s attestations to controls.  Unvalidated attestations could be off by an order of magnitude.  Evidence backing up statements may not exist or might even contradict those assertions.  An independent review now would likely identify issues and enable proactive remediation.

Many in the MIB have fallen asleep waiting for CMMC to be implemented.  The first delay in CMMC was due to the design of the model itself.  The change was significant.  Version 1.0 was released in September 2020 and was almost immediately replaced with CMMC 2.0 in just over a year.  CMMC 1.0 had 5 performance tiers with 2.0 only having 3 – Foundational, Advanced, and Expert.  Contracted responsibilities dictate the required performance level. 

The biggest delay has been in the verification and enforcement of rules – what the DoD calls Rulemaking.  As of July 17, 2024, the DoD forecasted publishing of the final rule for the Cybersecurity Maturity Model Certification (CMMC) 2.0 program in the Federal Register by October 26, 2024.  That is just weeks away!  The DoD wants to apply the rule almost immediately – late Q3 or early Q4 2024. The rule, 32 CFR 170[ii], is considered a “Major” rule and will be subject to a Congressional review of up to 120 days before it can be published. Once published, the rule will not be effective for at least 60 days.   That puts applicability roughly six months out.  A gap assessment can identify the remediation needed to get to your desired level before CMMC is mandated.

Two options exist.  All companies in the Military Industrial Base should at least be performing a self-assessment.  Many are taking the added step to be independently certified. 

For decades, compliance was done manually using spreadsheets to capture attestations, evidence, findings, and action plans.  Companies managed their organization one way while reporting compliance another way.  This approach leads to more compliance issues and inefficiencies.  Consider choosing an audit firm that offers an AI-enabled platform to manage your controls and audit them.  Choosing an independent audit firm is a non-trivial exercise.  The 2024 Compliance Benchmark Report[iii] offers some considerations before proceeding.  Almost half (45%) of survey respondents have found their compliance process to be cumbersome and would switch audit providers for efficiency.  Many firms (44%) are using AI to optimize the compliance process.   Clients choose their auditor due to their experience (32%), report quality (19%), and ability to audit using tools and technologies (22).

Our moto is to Trust But Verify.  The DoD will adopt that motto soon.  Let us help you efficiently create verifiable security now in preparation for CMMC!

---

[i] BREAKING: Few Companies Ready for CMMC Compliance, Study Finds – https://www.nationaldefensemagazine.org/articles/2024/10/1/few-companies-ready-for-cmmc-compliance-study-finds

[ii] Cybersecurity Maturity Model Certification (CMMC) Program – https://www.federalregister.gov/documents/2023/12/26/2023-27280/cybersecurity-maturity-model-certification-cmmc-program

[iii] The A-LIGN 2024 Compliance Benchmark Report – https://go.a-lign.com/Benchmark-Report-2024?_ga=2.264079822.310205026.1724775344-1179027787.1724289118&_gac=1.22166217.1724775344.CjwKCAjw8rW2BhAgEiwAoRO5rEAeqLSA1sELyTey0JBOfYQFqCrKl7pVKDNFSXQHQ2MzoM2D-iX7tBoC1d8QAvD_BwE

Few drivers utilize an outdated, paper-based map when driving long distances.  Too many real-time conditions impact driving options.  Choosing what security technologies to implement and when to implement them has similar complexity.    Utilize your Value-Added Reseller to help define your annual security technologies roadmap.  Let your IT Security Roadmap put you in the driver’s seat to the best return-on-investment.

Keeping up with the change in technology can be overwhelming, from increased business usage to the rapid advancements in the cybersecurity market.  What often took 5-10 years to adopt a couple of decades ago, is in production in just a few years.  This article establishes some simple next steps to address the issue.  A Commonsense approach to Security Improvement is needed. 

Just 2 decades ago, Gartner’s vision for Information Security program adoption captured three unique perspectives – organizational, data-centric, and technical.  One leg of the program needs a view of the current security technologies and the ones being considered soon.  A bit later, ISACA came to a similar conclusion.  Their blueprint for The Business Model for Information Security[i] included a Technology component to address Human Factors of People, Enabling and Support of Process, and the Architecture of the Technology to be used.  Without factoring all three areas, IT Security decisions end up the square peg to the round hole.

Few organizations can resource the planning of security technologies, however.  Enterprises often have architecture teams and subscription services to firms like Gartner or Forester.  Small-to-midsized organizations need other options.  One commonsense approach leverages Value Added Resellers (VARs) to establish and maintain the client’s roadmap of security technologies. 

One view of the Cybersecurity Ecosystem[ii] has eight areas supporting Cybersecurity, Privacy, and Trust: Security Operations; Data Security; Application Security; Physical Security; Infrastructure Security; Governance, Risk, and Compliance; Fraud and Transaction Security; Identity Security, and (general) Services.  One or more of these perspectives best aligned to client priorities should be included in the roadmap.

The roadmap simplifies decision-making, and highlights when tasks are needed within that calendar year.  A given technology may need to be in one of four states:

1. CONTAIN: Further investment in a previous mainstream product may be contained.
2. RETIRE: Some contained technologies may be end-of-life and need to be retired. 
3. EMERGING – Emerging technologies may be researched in support of future planning. 
4. MAINSTREAM – A green light may be given to previously defined emerging technologies.

Several factors go into the performance of a given technology.  For example, Gartner demystifies the market hype in the Gartner Hype Cycle[iii].  Products may be On the Rise, At the Peak, Sliding into the Trough, Climbing the Slope, or Entering the Plateau.  The annual update to the roadmap should highlight where the technologies are.  Return on investment will vary based on the product’s maturity and market acceptance. 

Let’s look at an example using the Governance, Risk, and Compliance part of the Cybersecurity Ecosystem and the Gartner Hype Cycle for Cyber Risk Management.[iv]  Depending on client input, the roadmap might include up to 6 product categories to be Mainstream in less than 2 years or 13 to be Mainstream in 2-5 years.  Business impact will also be highlighted for each category selected.  Adoption prior to Mainstream has value when Transformational benefits could be realized!

While the cybersecurity market dictates the Emerging and Mainstream technologies, other factors determine what is placed in Contain or Retire.  Input is solicited from the client and their cybersecurity vendors to make these determinations.  Product categories become Contained when newer approaches are being adopted and dependencies still exist.  Contained categories are moved to Retire when dependencies have been eliminated and/or the product is end of life. 

As a result of applying this Commonsense Planning of Security Technologies, your current and near-term cybersecurity technologies in your Cybersecurity Ecosystem are defined, benefits highlighted, and next step actions are easily identified.  Let Securitybeat Advisors assist with your IT Security Roadmap!

---

[i] The Value of BMIS ISACA – https://www.isaca.org/isaca-digital-videos/archive/the-value-of-bmis–isaca

[ii] Strategy of Security, The Ecosystem Explained – https://strategyofsecurity.com/cybersecurity-ecosystem/

[iii] Gartner Hype Cycle – https://www.gartner.com/en/research/methodologies/gartner-hype-cycle

[iv] Gartner Hype Cycle for Cyber Risk Management, 2023 – https://www.gartner.com/en/documents/4564900

The NIST Cybersecurity Framework provides an easy-to-use governance process for managing cyber risk.  Organizations should consider the NIST Cybersecurity Framework if they are just forming a Cybersecurity program or have no immediate need for an independent audit/certification.  CISA puts CSF into practice with free public resources and services.  CSF and CISA is the 1-2 punch to get Cybersecurity programs initiated!

The stakeholders of your organization expect visible due diligence in protecting your assets as well as steps to address the liabilities of doing business.  Many regulations and state laws also require a formal Cybersecurity program where management sets the direction for control objectives through policy and measures control implementation using baseline standards.  Management’s part is to establish their framework for deciding upon the policies and controls to get the ball rolling.  In the Security 360^o Perspective, this practice area is called Risk Governance.

In 2014, the National Institute of Standards and Technology (NIST) offered its first non-government option for Risk Governance – The Cybersecurity Framework.[i]  CSF gave an option for municipalities, local government, schools, and the private sector to define business requirements in Organizational Profiles, set baselines in performance Tiers, and work from one common Core of cybersecurity functions to build Cybersecurity capability.

With its 2.0 release this past month, CSF is a must have Cybersecurity Risk Governance![ii]  Most notably, CSF 2.0 has added the Govern Core function, strengthening the cohesion between senior management in their leadership and support of the program, and their involvement in risk management activities.  Re-usable Profiles exist for many of the sixteen Critical Infrastructure sectors that use CSF.  CSF 2.0 directly supports the US National Cybersecurity Strategy and takes advantage of recently developed guidance on supply chain security and small business security. 

The flexibility of choosing Organizational Profiles and performance Tiers gives the option to establish a solid foundation and then build capability on that solid footing.  Organizations should start with an Organizational Profile and performance Tier closest to their demonstratable compliance.  Establish a stable, verifiable Current Profile before chasing capabilities well beyond your reach!  You can start with Tier 1 – Partial to assess your capabilities but still need to get to Tier 2 – Risk Informed – to truly Risk Govern any gaps discovered.  The payback to the business is when Tier 3 – Repeatable – establishes operational effectiveness.  Organizations with high-risk will eventually want to achieve Tier 4 – Adaptive – in select profiles associated with that risk.

The Cybersecurity and Infrastructure Security Agency (CISA) provides several free resources and tools that complement CSF.   One resource is the Cyber Security Evaluation Tool (CSET) which supports several security assessments, including the NIST Cybersecurity Framework.[iii]  Use CSET to assess against the profiles and performance tiers discussed earlier.  Organizations with limited resources might consider establishing Cross-Sector Cybersecurity Performance Goals to tailor their initial CSF implementation.[iv]

Cybersecurity capability is subdivided into 6 functional areas covering 22 categories.  Govern includes the Organizational Context, Risk Management Strategy, Roles and Responsibilities, Policy, Oversight, and Cybersecurity Supply Chain Risk Management.   Identify creates the focus of your program with Asset Management, Risk Assessment, and Improvement.  The remaining functions Protect, Detect, Respond, and Recover within that area of focus.

Mappings bring other standards into CSF, either manually using NIST documentation, or automatically using CSET.  Mappings exist for COBIT 5, CIS CCS, ISO 27001, and ISA 62443.  Vendors also offer mappings to SOC2!

At the end of the day, remember that stakeholders of your organization expect visible due diligence in protecting your assets as well as steps to address the liabilities of doing business.  Don’t bury them in the weeds.  Proudly demonstrate your Risk Governance strategy.  Let CSF and CISA get you started!

---

[i] NIST Releases Cybersecurity Framework Version 1.0 – https://www.nist.gov/news-events/news/2014/02/nist-releases-cybersecurity-framewortk-version-10

[ii] NIST Releases Version 2.0 of Landmark Cybersecurity Framework – https://www.nist.gov/news-events/news/2024/02/nist-releases-version-20-landmark-cybersecurity-framework

[iii] NIST Cyber Security Evaluation Tool – https://www.cisa.gov/downloading-and-installing-cset

[iv] Cross-Sector Cybersecurity Performance Goals – https://www.cisa.gov/cross-sector-cybersecurity-performance-goals