With a goal of strengthening the overall security posture of the Defense Industrial Base, the U.S. Defense Department in January 2020 released the inaugural version of its Cybersecurity Maturity Model Certification (CMMC), which defines the five levels of cyber maturity that will be incorporated into a limited number of contracts ("Path Finders") for Defense Department procurements in Fall 2020, then gradually rolled out to a broader scope of contracts over the next several years.
The CMMC cyber maturity levels range from Level 1: Basic Cyber Hygiene to Level 5: Advanced/Progressive Cyber Hygiene. For the more than 350,000 entities that make up the Defense Industrial Base, it will require significant effort to comply with these cyber maturity level requirements, which will require validation by an accredited CMMC Third Party Assessment Organization (C3PAO).
While this compliance may seem challenging, your company can be ready. In fact, there are four best practices that an organization within the Defense Industrial Base can use to prepare for and ultimately achieve their level of CMMC maturity.
Select the CMMC level that is right for your organization – for now and in the future
If your company does business with the Department of Defense (DoD), you must comply with some level of CMMC maturity. Each of the five levels will require a different level of investment, policy development, and security controls – so it is critical that you decide which level fits your business.
How? Assess your current portfolio of DoD contracts, and if your contracts do not require you to maintain Controlled Unclassified Information (CUI), you may want to limit your compliance efforts to Level 1 or 2. But if you do hold CUI and other sensitive data, you should plan to select Level 3 or higher.
You should also consider your business strategy as you make your CMMC compliance decisions. If you have future plans to move into the CUI environment, a CMMC investment in a Level 3 or higher may offer you a competitive advantage that will open the door to future DoD opportunities.
Evaluate your business relationships with subcontractors – this involves them, too
It is important to remember that compliance with CMMC flows down to your subcontractors, so as the prime contractor, it is your responsibility to ensure that you and all of your subcontractors achieve the right level of CMMC compliance.
To do this, evaluate your subcontractor agreements and include compliance agreements in any agreements you enter into with potential partners. Request compliance certification from members of your supply chain, and if subcontractors are not certified, take steps to ensure they only work with data and equipment that resides within a CMMC enclave. Don't forget that contractor teaming agreements will require each team member to be CMMC certified to the appropriate level of the contract.
Define your system boundaries to minimize threat surface
Your system boundaries should be properly defined and segmented. Similar to other compliance mandates, the goal should be to minimize the threat surface and designate a defined enclave that can hold CMMC relevant data.
Equally important is establishing and enforcing a strong Data Classification and Management Policy that ensures that new data is routed to the appropriate segment of the IT environment. And don't forget another critical element – identifying, defining and documenting the inbound and outbound connections of the CMMC enclave, as well as the associated interface security protocols.
Approach CMMC as an enterprise-wide initiative – not just a security challenge
Achieving CMMC compliance is an effort that will cut across all levels of your organization, requiring the attention of your CEO, CIO, General Counsel, Privacy Officer and other senior level officers.
While some controls can be addressed by relatively simple updates to policies and procedures, or minor adjustments to configuration settings and architecture, other controls will require an investment in technology or significant changes to business protocols. Some of the bigger challenges you should prepare to encounter include encryption of data (at rest and in transit); CUI marking procedures; multi-factor authentication; audit logging and activity reviews; threat intelligence and continuous monitoring; mobile device policies; and awareness and training.
Given the level of investment and impact of some of these initiatives, it is critical to get stakeholder buy-in and continue to engage decision-makers from across your organization as you work to achieve CMMC compliance.
Despite current disruptions to the work environment due to the coronavirus, the CMMC requirements are expected, for now, to go into place in the fall. Regardless of whether that deadline may be pushed back, organizations within the Defense Industrial Base should be thinking now about how they can implement the changes they need to make to achieve CMMC compliance. These best practices are an excellent place to start.
This article was originally published in FCW on August 7, 2020
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