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Author: Raj Raghavan

Navigating CMMC: Overcoming Compliance Challenges

Posted on by Raj Raghavan

It should come as no surprise that the deadline for complying with the Cybersecurity Maturity Model Certification (CMMC) is fast approaching. The CMMC framework, a cornerstone in upholding rigorous cybersecurity standards, consists of a tiered framework from basic cyber hygiene at Level 1, maturing to highly sophisticated cybersecurity practices and processes at Level 5, such as NIST SP 800-171 guidelines.

While organizations in a variety of sectors must systematically complete each level and implement the appropriate controls, CMMC compliance also involves routine audits and assessments to demonstrate an organization’s commitment to safeguarding heightened security standards.

Common CMMC Compliance Challenges

While common CMMC compliance challenges vary from understanding the complex requirements to aligning existing processes with new standards, there are three main compliance challenges companies will face as they work to achieve their CMMC certification:

  1. Navigating the CMMC framework presents a significant challenge as it is designed to merge various cybersecurity standards and best practices, promoting a comprehensive approach to data protection. However, the complexity of understanding and implementing these standards also requires significant resources and robust planning to help ensure all necessary safeguards are correctly in place. To effectively advance through the CMMC levels, companies must fully understand the stipulations that come with the framework, such as the numerous control families that must be deployed progressively.
  1. Protecting Controlled Unclassified Information (CUI) remains a pivotal concern for companies, especially those working with the Department of Defense (DOD), given the sensitive nature of that data. The CMMC framework is built on stringent measures to safeguard CUI from unauthorized access, while also ensuring its integrity throughout business operations. But safeguarding CUI is not straightforward, as it involves understanding complex regulatory requirements that are integral to CMMC compliance. An essential part to achieving this standard is developing comprehensive data protection policies and utilizing advanced technological solutions, such as encryption and access controls to maintain compliance mandates and boost resilience against cyber threats.
  1. Addressing the cost of compliance is an essential step for companies striving to meet CMMC requirements. The implementation of the CMMC framework can be a costly endeavor, from investments in new software and training expenses to enhance workforce skills to the costs of operational downtime as businesses adjust their processes to incorporate new security protocols. Strategic financial planning is important for companies to allocate costs effectively and explore potential financial assistance or incentives that might be available to balance operational needs with compliance obligations.

Understanding the CMMC Compliance Process

A comprehensive understanding of each level’s expectations is crucial for ensuring implementation and achieving compliance. Each CMMC level embodies different criteria and enhanced cybersecurity practices, starting at Level 1, which is foundational for all organizations in any industry. As companies progress through Levels 2 to 5, they are required to adopt increasingly complex cybersecurity measures that address specific control families based largely on NIST SP 800-171 standards.

To adhere to the CMMC compliance process, companies must:

  • Perform a rigorous assessment of their current security posture relative to CMMC standards to identify existing gaps and implement any necessary enhancements.
  • Develop a detailed action plan tailored to address any deficiencies and align their security posture with regulatory mandates.
  • Review and update controls continuously to ensure sustained compliance and protection of sensitive information.

Preparing for the CMMC Compliance Deadline

Aligning organizational strategies with the rigorous demands of the CMMC framework is a step towards securing current operational resilience. To seamlessly transition and meet the CMMC deadline, companies must thoroughly analyze the modifications in the CMMC framework, focusing on changes in control specifications and reporting requirements, conduct an extensive gap analysis to ensure that all personnel are well-equipped to address any new criteria, and ensure that current cybersecurity infrastructure aligns with the updated standards.

Taking a proactive approach can mitigate potential operational disruptions and help organizations stay on track to meet the CMMC compliance deadline.

The Role of a Third-Party Assessment Organization

Engaging with certified Third-Party Assessment Organizations (C3PAOs) can play a pivotal role in helping organizations navigate the complexities of CMMC compliance. From providing critical insights and tailored guidance throughout the compliance journey to ensuring all security controls are correctly implemented. C3PAOs can help organizations streamline the path to achieving CMMC compliance and bolster their readiness to meet changing cybersecurity protocols.

The Future of CMMC Compliance

While the cybersecurity landscape will continue to evolve, so will the requirements associated with CMMC. To effectively address emerging threats and vulnerabilities, organizations must accept that compliance is not a static endpoint, but a dynamic process. Adopting new technological advancements in cybersecurity practices and remaining agile will be key for companies to continuously maintain CMMC compliance.

This involves not only keeping pace with the latest advancements in cybersecurity technologies, such as artificial intelligence, machine learning, and predictive analytics, but also anticipating how these technologies can be leveraged to address an increasingly complex threat environment.

Additionally, its crucial for companies to invest in their people through education and training to ensure they are proficient at deploying cybersecurity best practices and can effectively address any potential threats. Fostering an organizational culture of continuous learning and innovation, not only enhances an organizations cybersecurity resilience but positions them to face future challenges with confidence.   

Conclusion

To achieve CMMC compliances, companies must embrace an adaptive and proactive approach that ensures they are consistently meeting evolving cybersecurity standards, promoting a culture of ongoing learning to stay informed on the latest regulatory changes, and regularly reassess their cybersecurity strategies by integrating advanced technologies to enhance their protection capabilities.

Got CMMC compliance pains? Securitybricks is one of the few U.S. firms holding both FedRAMP 3PAO and CMMC C3PAO Accreditations. We offer a phased approach tailored to your security and compliance needs, ensuring you have the right information and tools for long-term success. Securitybricks is part of Aprio, a premier business advisory and CPA firm.

Need help navigating CMMC compliance? Connect with our team today.

Diving into CMMC Requirements: Essential Steps for Compliance Readiness

Posted on by Raj Raghavan

The Cybersecurity Maturity Model Certification (CMMC) Program is designed to ensure that defense contractors and subcontractors meet stringent information protection requirements to Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) against threats.

Achieving CMMC compliance is a prerequisite for securing contracts (excluding Commercial-Off-The-Shelf procurements) that support the Department of Defense (DoD). To win or maintain a contract with the DoD, you must meet the specific CMMC level that applies to the type of work you will be providing and the data involved. For existing DoD partners, CMMC compliance is required to renew contracts and remain competitive in the marketplace.

So—how can you prepare your company for a CMMC assessment?

Understanding the Different Levels of CMMC Compliance

The CMMC framework consists of three tiers, each with increasing requirements to protect FCI and CUI data.

The CMMC 2.0 model outlines three maturity levels (ML) of cyber hygiene:

  • Level 1: Ensures basic cybersecurity practices are in place for DoD contractors managing FCI.
  • Level 2: Introduces additional security measures to protect against more sophisticated threats.
    • If your organization handles CUI, Level 2 includes data protection practices that secures CUI and protects against threats.
  • Level 3: Implements the highest level of cybersecurity standards for the most sensitive government information.
    • Level 3 is reserved for highly sensitive contracts concerning national security, intelligence, or critical defense.

As a DoD contractor or subcontractor, achieving the specified CMMC level is mandatory for contract awards. Prime contractors must ensure that all subcontractors in their supply chain meet or exceed the required CMMC certification level. The contract flow-down requirement ensures that every tier maintains robust cybersecurity safeguards.

It’s also worth noting that under the revised CMMC rule, the DoD contract solicitation will specify the minimum CMMC level and assessment type required. In short: You won’t have the option to choose your level. The solicitation will dictate the cybersecurity maturity level you must achieve and whether it requires a self-assessment or an assessment from a CMMC Third-Party Assessor Organization (C3PAO). While you can aim for a higher level if it aligns with your strategic goals, you must at least meet the specified level to be eligible for the contract award.

Let’s delve deeper into each of the CMMC levels.

CMMC Level 1

At Level 1, your focus is on the basic protection of FCI. This level is intended for companies that handle FCI but not CUI. To achieve Level 1 compliance, you must adhere to 17 basic cyber hygiene practices and meet the 15 security requirements outlined in FAR clause 52.204-21.

You are required to perform an annual self-assessment and submit it to the DoD’s Supplier Performance Risk System (SPRS) before you can be awarded any CMMC Level 1 contracts or subcontracts. A company officer must also sign an annual affirmation of compliance, verifying that the self-assessment is accurate and complete. Bear in mind that all security requirements at this level must be fully met, and that you cannot submit a Plan of Action and Milestones (POA&M) with the Level 1 self-assessment.

CMMC Level 2

Level 2 hinges on the protection of CUI. Depending on the type of information processed, transmitted, or stored, you will need to undergo either a self-assessment or a C3PAO assessment every 3 years, as specified in the solicitation. You must also provide an annual affirmation attesting to your compliance with the 110 security requirements in NIST SP 800-171 Revision 2.

Additionally, Level 2 requires the submission of your SPRS score on an annual basis, similar to Level 1. Depending on certain objectives, contractors and subcontractors may have an open POA&M item.

Currently, there are over 80,000 contractors classified under Level 2.

CMMC Level 3

Level 3 is designed for the highest level of protection against advanced persistent threats. Companies at this level require a government-led certification by the Defense Contract Management Agency’s Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). While DIBCAC assessments are not always required immediately at contract award, contractors may receive conditional certification if certain controls are incomplete but have an approved POA&M.

This level applies to the most sensitive and high-risk DoD projects and includes an additional 24 requirements from NIST SP 800-172. Only about 1% of the Defense Industrial Base (DIB) is affected by Level 3 requirements. To maintain Level 3 status, you must achieve final Level 2 certification, undergo a DIBCAC assessment every 3 years, and provide an annual affirmation verifying compliance with the 24 identified requirements from NIST SP 800-172.

CMMC Readiness Best Practices

  • Develop a solid system security plan (SSP): Your SSP can make a strong first impression by demonstrating your understanding of the material, considering all requirements, and articulating how you satisfy them in your SSP.
  • Document policies and procedures—and execute them: Ensure your organization has policies and procedures for each control family. Review them regularly and document all third-party service providers used to process, store, or disseminate CUI. Don’t wait until your official assessment to compile the correct documentation.
  • Carry out an internal review or a third-party readiness assessment: You can utilize the DoD’s CMMC Assessment Guide to help conduct the internal review. However, often times organizations may think they fully understand the requirements but end up misinterpreting things, so having a trusted third-party do the audit helps avoid mistakes.
  • Engage a C3PAO: If your CMMC level involves third-party certification, building a relationship with a C3PAO is nonnegotiable. With 80,000 contractors and less than 60 C3PAOs, you may want to get your assessments scheduled sooner rather than later.

Conclusion

CMMC compliance is a prerequisite for winning and maintaining contracts with the DoD. Whether you are an existing DoD partner or new to DoD contracting, conducting a thorough self-assessment of your information systems is the best way to prepare. Review security requirements and implement relevant cybersecurity measures, as well as take corrective actions to meet any outstanding requirements.

Need help navigating CMMC compliance? Securitybricks is one of a select few firms holding both FedRAMP 3PAO and CMMC C3PAO accreditations. We offer a phased approach tailored to your security and compliance needs, ensuring you have the right information and tools for long-term success. Securitybricks is part of Aprio, a premier business advisory and CPA firm.

We help you navigate the complexities of CMMC compliance with confidence. Get in touch today.

Securitybricks Launches FedRAMP Accelerator on ServiceNow Platform

Posted on by Raj Raghavan

Securitybricks releases the first FedRAMP accelerator built on ServiceNow platform for the recently released FedRAMP Rev 5 controls.

SAN FRANCISCO, CA, UNITED STATES, July 25, 2023/EINPresswire.com/ — Securitybricks announced today that it has launched the first FedRAMP accelerator built on ServiceNow platform for the recently released FedRAMP Rev 5 controls. It is now available on ServiceNow Store as a free download.

As an authorized FedRAMP Third-Party Assessment Organization (3PAO) and a ServiceNow Build partner, Securitybricks combined its in-depth understanding of control testing by incorporating continuous monitoring capabilities with control automation for 80% of the FedRAMP controls. The accelerator will enable Cloud Service Providers (CSPs) to reduce time for FedRAMP Authority to Operate (ATO) assessment using various data elements within their ServiceNow platform.

The accelerator comes with 320+ controls needed for FedRAMP moderate assessment and questionnaire samples built on the ServiceNow CAM (continuous monitoring and authorization). Out of the box, the accelerator comes with FedRAMP Rev 5 control content along with ability to build authorization boundary, a SSP (system security plan) and POA&M management.

Securitybricks FedRAMP solution extends the free accelerator which includes:

– Complete citations and authority documents for FedRAMP Rev 5 controls
– Content for inherited controls from Azure and AWS
– Ability to build authorization boundary using cloud workload data
– SSP document along with required FedRAMP ATO artifacts
– Connectors to AWS Security Hub and Azure Defender for cloud configuration and vulnerability data
– Supply chain controls automation
– Continuous monitoring reporting including POA&M

“We are excited to bring the first automated FedRAMP ATO solution built on the ServiceNow platform. In addition, all our solution implementations are backed by a free ‘mock 3PAO audit’ to guarantee the ATO package meets FedRAMP PMO requirements.” stated Raj Raghavan, CEO of Securitybricks.

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About Securitybricks, Inc.

Securitybricks, Inc. is a cybersecurity consulting firm focused on cloud security and compliance. Based in the U.S., its team members are all U.S. Citizens, including military veterans, with over 15+ years of experience in implementing cybersecurity and regulatory compliance controls. https://securitybricks.io/.

About FedRAMP

The Federal Risk and Authorization Management Program (FedRAMP) is a United States federal government-wide compliance program that provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services. All Cloud Service Providers (CSPs) seeking to offer services to the Federal government are required to be assessed by a 3PAO.

Learn more about how Securitybricks can help you achieve FedRAMP Compliance at the FedRAMP Marketplace here.

Raj Raghavan
Securitybricks, Inc.
email us here

https://www.einpresswire.com/article/646297318/securitybricks-launches-fedramp-accelerator-on-servicenow-platform

Securitybricks Earns FedRAMP Third Party Organization Assessment (3PAO) Status

Posted on by Raj Raghavan

This accreditation enables Securitybricks to validate that service providers have implemented the required cloud security measures to protect government data.

SAN FRANCISCO, CA, UNITED STATES, April 18, 2023/EINPresswire.com/ — Securitybricks announced today that it has earned accreditation as a Third Party Assessment Organization (3PAO) under the Federal Risk and Authorization Management Program (FedRAMP). This accreditation authorizes Securitybricks to assess and certify cybersecurity controls for Cloud Service Providers looking to do business with any of 400+ US Federal agencies.

To earn the 3PAO accreditation, Securitybricks completed a comprehensive assessment conducted, over a span of 2 years, by the American Association for Laboratory Accreditation (A2LA), the FedRAMP 3PAO accreditation body to verify technical competence and quality management compliance to ISO/IEC 17020:202 standard.

Securitybricks will leverage its domain expertise in cloud security and control compliance, and its thorough understanding of NIST 800-53 control requirements to provide a suite of approved 3PAO services. In addition, Securitybricks has developed an automation approach that can shorten a CSP’s FedRAMP readiness timelines and reduce certification costs by 40%.

“FedRAMP is the first step in Securitybricks’ commitment to the Public Sector market. President Biden signed the FedRAMP Authorization Act in Dec. 2022, that aims to facilitate and accelerate secure cloud adoption by providing defined security authorizations, which opens the federal market to CSP’s of all sizes…” stated Raj Raghavan, CEO of Securitybricks.

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About Securitybricks, Inc.
Securitybricks, Inc., a firm focused on cloud security and compliance. Based in the U.S., its team members all US Citizens, including military veterans, have over 15+ years’ experience in implementing cybersecurity and regulatory compliance controls. https://securitybricks.io/.

About FedRAMP
The Federal Risk and Authorization Management Program (FedRAMP) is a United States federal government-wide compliance program that provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services. All Cloud Service Providers seeking to offer services to the Federal government are required to be assessed by a 3PAO.

Learn more about how Securitybricks can help you achieve FedRAMP Compliance at the FedRAMP Marketplace here.

Katalin Pesti
Securitybricks, Inc.
3PAO@securitybricks.io

The Cyber Compliance Market

Posted on by Raj Raghavan

Recently, someone asked me to quantify the federal cyber market. 

FedRAMP is now a law that underlines the Government’s Cloud first mandate. After years of ambiguity and excessive costs to become FedRAMP certified to demonstrate data protection controls based on agency’s needs, the law now sets a level playing field for mid-size service enterprises who want to tap into the Federal market. The new law puts a system of reciprocity which allows federal agencies to certify vendors and have the same level of data protection more easily. 

While this law is appealing, the certification rules have not changed. Readiness is still a mountain to climb even with an understanding of the intent of NIST 800-53 controls and the applicability to the service provider’s environment. While the NIST requirements are complex, the cloud security architects and DevOps ability to design and implement the service within an approved boundary with appropriate data controls is no small feat. The demand for these cloud security professionals is very high.

Once you are FedRAMP certified, the burden to provide continuous monitoring reports that include reporting on incidents, security events, and scan for vulnerabilities while ensuring the new product features don’t cause “significant change” is an ongoing program.  

“Let us do the numbers” from my favorite NPR show Marketplace by Kai Ryssdal.

  • While 2022 saw the federal government spend over $11B in cloud technologies, the new bill signed in Dec. 2022 increases the spending
  • The Federal market is a long-term revenue stream with a market of 440 agencies          
  • Government agencies in 10 states have adopted FedRAMP and renamed it StateRAMP
  • FedRAMP is the security gate that will open the gates to these agencies
  • FedRAMP requires validation from a pool of 40 3PAOs
  • The lack of cloud security and application security professionals will further strain service providers ability to get certified quickly

The numbers are interesting but, where do you start?

  • Does your compliance team or security team understand NIST security framework?
  • Is your commercial cloud deployment aligned to security benchmarks or regulations?
  • Don’t let 1000 controls of NIST intimidate you. These are common sense cyber hygiene controls that are broken into domains that your information security probably has implemented
  • 3PAOs can offer guidance, but your FedRAMP readiness team should have cloud security engineers who can map current security tools and processes to NIST requirements
  • While AWS, GCP and Azure offer “FedRAMP Ready” GovCloud, see if it makes sense to implement your cloud software in the GovCloud and continuously monitor it
  • This is not a security tool game or FedRAMP ready “blueprint” but an assessment of your security controls and process to meet a slightly higher security requirement

There is a small battalion of certified assessors who can provide guidance and certification. The shortage of certified auditors is increasing timelines as many of us are now getting ready for CMMC, a DoD mandate, that impacts 300,000+ DoD subcontractors in 2023.