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Cybersecurity Maturity Model Certification (CMMC) Compliance

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The U.S. Department of Defense (DoD) released the first version of the Cybersecurity Maturity Model Certification (CMMC) in January 2020. It was part of an effort to secure the DoD’s supply chain and the Defense Industrial Base (DIB). The CMMC was created to protect DIB contractors (i.e., the worldwide industrial complex that enables research and development, as well as design, production, delivery, and maintenance of military weapons systems, subsystems, and components or parts, to meet U.S. military requirements) from cybersecurity threats.

The effort to achieve CMMC compliance provides significant benefits to an organization from a security perspective.

The CMMC represents the amalgamation of multiple frameworks and standards, such as NIST SP 800-171, the NIST Cybersecurity Framework, and ISO 27001. The DoD partnered with experts in academia from Carnegie Mellon and Johns Hopkins Universities to develop the CMMC.

What is CMMC Compliance?

CMMC Levels

CMMC measures cybersecurity maturity, or capability and progression within an organization's security program, with five levels. Each level has detailed processes and practices required for CMMC compliance.

To meet CMMC compliance requirements at one of the five levels, contractors must demonstrate achievement in the desired level as well as the lower levels. In addition, contractors “must demonstrate both the requisite institutionalization of process and the implementation of practice” (see diagram below).

Five levels of CMMC compliance

Recognizing that there needed to be more structure than with Defense Federal Acquisition Regulation Supplement (DFARS), the DoD enhanced the compliance requirements. With DFARS, contractors could “self-attest” to compliance after the contract was won. CMMC compliance must be verified before a contract can be won.

Because all contractors do not need the same level of security, CMMC compliance requirements are in levels. DoD requests for information (RFIs) and requests for proposal (RFPs) include which CMMC compliance level is required for a given contract. Before consideration, a contractor will be audited by a third party and given a score based on the assessment.

CMMC compliance levels take into account the form and caliber of controlled unclassified information (CUI) that contractors work with and require them to adhere to the level assigned to a project. The CMMC compliance levels range from basic cyber hygiene performed to advanced / progressive optimized.

CMMC compliance levels align with contractors’ cybersecurity practices and the sensitivity of information as well as the types and consequences of potential threats. The five CMMC compliance levels are:

  • Level 1: Safeguard federal contract information (FCI)
  • Level 2: Serve as a transition step in cybersecurity maturity progression to protect CUI
  • Level 3: Protect CUI
  • Level 4-5: Protect CUI and reduce risk of advanced persistent threats (APT)
CMMC compliance levels and associated focus

Level One
Processes:  Performed - Required processes are performed ad hoc, sometimes without formal documentation.
Practices: Basic cyber hygiene - Basic safeguard requirements are met for the protection of FCI according to minimum CMMC compliance requirements.

Level Two
Processes: Documented - Requires that practices and policies be established and documented to guide CMMC compliance. Practices are performed in a repeatable manner.
Practices: Intermediate cyber hygiene - Serving as a progression between levels one and three, it includes managing the hygiene and security of CUI.

Level Three
Processes:  Managed - Requires demonstration that a plan has been developed, is being maintained, and has been provided the resources needed to manage CMMC compliance. Items in this plan may include goals, resources, training activities, and roles of stakeholders.
Practices:  Good cyber hygiene - This includes all security requirements specified in NIST SP 800-171 and the additional safeguards cited in DFARS clause 252-0204-7012.

Level Four
Processes: Reviewed - CMMC compliance practices must be reviewed and measured for efficacy. Steps must be taken to remediate deficiencies or issues. If an issue is recurring, it must be reported to higher management.
Practices: Proactive - Cybersecurity practices are in place to detect and respond to threats with a focus on protecting CUI from APTs. Tactics and techniques are modified to adapt to changing APTs.

Level Five
Processes: Optimizing - CMMC compliance process implementation is standardized across the organization with ongoing corrective actions and improvements.
Practices: Advanced / proactive - Focus on proactive protection of CUI from APTs. The depth and sophistication of cybersecurity measures are increased.

Who Must Comply with CMMC?

Any organization in the defense contract supply chain must comply with CMMC requirements and have them audited and signed off by a certified independent third-party assessment organization (3PAO).  Organizations that satisfy CMMC compliance will be listed in the DoD database along with the level of their certification.

CMMC compliance includes contractors who engage directly with the DoD and their subcontractors—hundreds of thousands of organizations. These include contractors in areas such as:

  • Critical infrastructure
  • Defense
  • Export control
  • Financial
  • Immigration
  • Intelligence
  • International agreements
  • Law enforcement
  • Legal
  • Natural and cultural resources
  • NATO
  • Nuclear
  • Privacy
  • Procurement and acquisition
  • Proprietary business information
  • Provisional
  • Statistical
  • Tax

The reach of CMMC is expansive. A DIB organization with FCI, even if it does not have or produce CUI, must meet the requirements for CMMC compliance at level one. The only exception to CMMC compliance requirements within the DIB sector is companies that solely produce commercial-off-the-shelf (COTS) products.

DoD gave contractors five years to meet the requirements set forth in the five levels for CMMC compliance. Since 2020, thousands of vendors have worked to understand just what is required of businesses to meet CMMC compliance requirements. Contractors that have not met the CMMC compliance requirements by 2025 risk not having DoD contracts renewed.

What is Required of Businesses?

CMMC compliance requirements are based on the certification level being sought. Each level builds on the previous one, meaning that level five must achieve the most stringent requirements as well as all of those set forth in levels one through four.

The level of certification required for a contractor to meet CMMC compliance requirements will be specified in the DoD’s RFIs and RFPs. The higher a contractor’s CMMC level, the more DOD contracts that are available.

DoD subcontractors are subject to the same CMMC compliance level as prime contractors. The level of CMMC compliance is dictated by the level specified in the contract and the information that is shared with subcontractors. For instance, a subcontract may only have to meet CMMC compliance requirements for a lower-level if their work is registered as less sensitive.

The CMMC compliance requirements are broken into 17 capability domains, each with specific capabilities, practices, and processes. The CMMC compliance capability domains are:

  1. 1. Access Control (AC)
  2. 2. Asset Management (AM)
  3. 3. Audit and Accountability (AU)
  4. 4. Awareness and Training (AT)
  5. 5. Configuration Management (CM)
  6. 6. Identification and Authentication (IA)
  7. 7. Incident Response (IR)
  8. 8. Maintenance (MA)
  9. 9. Media Protection (MP)
  10. 10. Personnel Security (PS)
  11. 11. Physical Protection (PE)
  12. 12. Recovery (RE)
  13. 13. Risk Management (RM)
  14. 14. Security Assessment (CA)
  15. 15. Situational Awareness (SA)
  16. 16. System and Communications Protection (SC)
  17. 17. System and Information Integrity (SI)

Understanding CMMC Requirements

The CMMC requirements include:

  • 17 domains
    • 43 capabilities
      • 171 practices

CMMC Level 1 Domains, Capabilities, and Practices Requirements

At base, CMMC compliance requires basic cyber hygiene and that security processes are performed — documentation is not required. Most of these standards are already met by existing federal contractors.

There are 17 practices required for CMMC compliance at level one:

  • Access Control (AC)
    • Establish system access capabilities
      • AC.1.001 – Limit information system access to authorized users, processes acting on behalf of authorized users, or devices, including other information systems
    • Control internal system access
      • AC.1.002 – Limit information system access to the types of transactions and functions that authorized users are permitted to execute
      • AC.1.003 – Verify and control and/or limit connections to and use of external information systems
    • Limit data access to authorized users and processes
      • AC.1.004 – Control information posted or processed on publicly accessible information systems
  • Identification and Authentication (IA)
    • Grant access to authenticated entities
      • IA.1.076 – Identify information system users, processes acting on behalf of users and devices
      • IA.1.077 – Authenticate (or verify) the identities of those users, processes, or devices as a prerequisite to allowing access to organizational information systems
  • Media Protection (MP)
    • Sanitize media
      • MP.1.118 – Sanitize or destroy information system media containing Federal contract information before disposal or release for reuse
  • Physical Protection (PE)
    • Limit physical access
      • PE.1.131 – Limit physical access to organizational information systems, equipment, and the respective operating environments to authorized individuals
      • PE.1.132 – Escort visitors and monitor visitor activity
      • PE.1.133 – Maintain audit logs of physical access
      • PE.1.134 – Control and manage physical access devices
  • System and Communication Protections (SC)
    • Control communications at system boundaries
      • SC.1.175 – Monitor, control, and protect organizational communications (i.e., information transmitted or received by organizational information systems) at the external boundaries and key internal boundaries of information systems
      • SC.1.176 – Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks
  • System and Information Integrity (SI)
    • Identify and manage information system flaws
      • SI.1.210 – Identify, report and correct information and information flows in a timely manner
    • Identify malicious content
      • SI.1.211 – Provide protection from malicious code at appropriate locations within organizational information systems
      • SI.1.212 – Update malicious code protection mechanisms when new releases are available
      • SI.1.213 – Perform periodic scans of information systems and real-time scans of files from external sources as files are downloaded, opened, or executed

CMMC Level 2 Domains, Capabilities, and Practices Requirements

To achieve CMMC compliance at the second level, intermediate cyber hygiene is required along with documentation of all CMMC practices and policies.

There are 72 practices to achieve CMMC compliance at level two:

  • Access Control (AC)
    • Establish system access capabilities
      • AC.2.005 – Provide privacy and security notices consistent with applicable CUI rules
      • AC.2.006 – Limit use of portable storage devices on external systems
    • Control internal system access
      • AC.2.007 – Employ the principle of least privilege, including for specific security functions and privileged accounts
      • AC.2.008 – Use non-privileged accounts or roles when accessing non-security functions
      • AC.2.009 – Limit unsuccessful logon attempts
      • AC.2.010 – Use session lock with pattern-hiding displays to prevent access and viewing of data after a period of inactivity
      • AC.2.011 – Authorize wireless access prior to allowing such connections
    • Control remote system access
      • AC.2.013 – Monitor and control remote access sessions
      • AC.2.015 – Route remote access via managed access control points
    • Limit data access to authorized users and processes
      • AC.2.016 – Control the flow of CUI in accordance with approved authorizations
  • Audit and Accountability (AU)
    • Define audit requirements
      • AU.2.041 – Ensure that the actions of individual system users can be uniquely traced to those users so they can be held accountable for their actions
    • Perform auditing
      • AU2.042 – Create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity
      • AU2.043 – Provide a system capability that compares and synchronizes internal system clocks with an authoritative source to generate timestamps for audit records
    • Review and manage audit logs
      • AU.2.044 – Review audit logs
  • Awareness and Training (AT)
    • Conduct security awareness activities
      • AT.2.056 – Ensure that managers, system administrators, and users of organizational systems are made aware of the security risks associated with their activities and of the applicable policies, standards, and procedures related to the security of those systems
    • Conduct training
      • AT.2.057 – Ensure that personnel are trained to carry out their assigned information security-related duties and responsibilities
  • Configuration management (CM)
    • Establish configuration baselines
      • CM.2.061 – Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, firmware, and documentation) throughout the respective system development lifecycles
      • CM.2.062 – Employ the principle of least functionality by configuring organizational systems to provide only essential capabilities
      • CM.2.063 – Control and monitor user-installed software
    • Perform configuration management and change management
      • CM.2.064 – Establish and enforce security configuration settings for information technology products employed in organizational systems
      • CM.2.065 – Track, review, approve or disapprove, and log changes to organizational systems
      • CM.2.066 – Analyze the security impact of changes prior to implementation
  • Identification and Authentication (IA)
    • Grant access to authenticated entities
      • IA.2.078 – Enforce a minimum password complexity and change of characters when new passwords are created
      • IA.2.079 – Prohibit password reuse for a specified number of generations
      • IA.2.080 – Allow temporary password use for system logons with an immediate change to a permanent password
      • IA.2.081 – Store and transmit only cryptographically-protected passwords
      • IA.2.082 – Obscure feedback of authentication information
  • Incident Response (IR)
    • Plan incident response
      • IR.2.092 – Establish an operational incident-handling capability for organizational systems that includes preparation, detection, analysis, containment, recovery, and user response activities
    • Detect and report events
      • IR.2.093 – Detect and report events
      • IR.2.094 – Analyze and triage events to support event resolution and incident declaration
    • Develop and implement a response to a declared incident (C018)
      • IR.2.096 – Develop and implement responses to declared incidents according to pre-defined procedures
    • Perform post-incident reviews (C019)
      • IR.2.097 – Perform root cause analysis on incidents to determine underlying causes
  • Maintenance (MA)
    • Manage maintenance
      • MA.2.111 – Perform maintenance on organizational systems
      • MA.2.112 – Provide controls on the tools, techniques, mechanisms, and personnel used to conduct system maintenance
      • MA.2.113 – Require multifactor authentication to establish nonlocal maintenance sessions via external network connections and terminate such connections when nonlocal maintenance is complete
      • MA.2.114 – Supervise the maintenance activities of personnel without required access authorization
  • Media Protection (MP)
    • Identify and mark media
      • MP.2.119 – Protect (i.e., physically control and securely store) system media containing CUI, both paper and digital
      • MP.2.120 – Limit access to CUI on system media to authorized users
      • MP.2.121 – Control the use of removable media on system components
  • Personnel Security (PS)
    • Screen personnel
      • PS.2.127 – Screen individuals prior to authorizing access to organizational systems containing CUI
    • Protect CUI during personnel actions
      • PS.2.128 – Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers
  • Physical Protection (PE)
    • Limited physical access
      • PE.2.135 – Protect and monitor the physical facility and support infrastructure for organizational systems
  • Recovery (RE)
    • Manage backups
      • RE.2.137 – Regularly perform and test data backups
      • RE.2.138 – Protect the confidentiality of backup CUI at storage locations
  • Risk Management (RM)
    • Identify and evaluate risk
      • RM.2.141 – Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI
      • RM.2.142 – Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting those systems and applications are identified
    • Manage risk
      • RM.2.143 – Remediate vulnerabilities in accordance with risk assessments
  • Security Assessment (CA)
    • Develop and manage a system security plan
      • CA.2.157 – Develop, document, and periodically update system security plans that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems
    • Define and manage controls
      • CA.2.158 – Periodically assess the security controls in organizational systems to determine if the controls are effective in their application
      • CA.2.159 – Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational systems
  • System and Communication Protections (SC)
    • Define security requirements for systems and communications
      • SC.2.178 – Prohibit remote activation of collaborative computing devices and provide an indication of devices in use to users present at the device
      • SC.2.179 – Use encrypted sessions for the management of network devices
  • System and Information Integrity (SI)
    • Identify and manage information system flaws
      • SC.2.178 – Prohibit remote activation of collaborative computing devices and provide an indication of devices in use to users present at the device
    • Perform network and system monitoring
      • SI.2.216 – Monitor organizational systems, including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks
      • SI.2.217 – Identify unauthorized use of organizational systems

CMMC Level 3 Domains, Capabilities, and Practices Requirements

Meeting CMMC compliance requirements at level three requires good cyber hygiene practices, documentation of practices and policies as well as maintaining and providing resources for a plan that encompasses all activities.

There are 130 practices to achieve for level three CMMC compliance:

  • Access Control (AC)
    • Control internal system access
      • AC.3.012 – Protect wireless access using authentication and encryption
      • AC.3.017 – Separate the duties of individuals to reduce the risk of malevolent activity without collusion
      • AC.3.018 – Prevent non-privileged users from executing privileged functions and capture the execution of such functions in audit logs
      • AC.3.019 – Terminate (automatically) user sessions after a defined condition
      • A.C.3.020- Control connection of mobile devices
    • Control remote system access
      • AC.3.014 – Employ cryptographic mechanisms to protect the confidentiality of remote access sessions
      • AC.3.021 – Authorize remote execution of privileged commands and remote access to security-relevant information
    • Limit data access to authorized users and processes
      • AC.3.022 – Encrypt CUI on mobile devices and mobile computing platforms
  • Asset Management (AM)
    • Identify and document assets
      • AM.3.036 – Define procedures for the handling of CUI data
  • Audit and Accountability (AU)
    • Define audit requirements
      • AU.3.045 – Review and update logged events
      • AU.3.046 – Alert in the event of an audit logging process failure
    • Perform auditing
      • AU.3.048 – Collect audit information (e.g., logs) into one or more central repositories
    • Identify and protect audit information
      • AU.3.049 – Protect audit information and audit logging tools from unauthorized access, modification, and deletion
      • AU.3.050 – Limit management of audit logging functionality to a subset of privileged users
    • Review and manage audit logs
      • AU.3.051 – Correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity
      • AU.3.052 – Provide audit record reduction and report generation to support on-demand analysis and reporting
  • Awareness and Training (AT)
    • Conduct security awareness activities
      • AT.3.058 – Provide security awareness training on recognizing and reporting potential indicators of insider threat
  • Configuration management (CM)
    • Perform configuration and change management
      • CM.3.067 – Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems
      • CM.3.068 -Restrict, disable, or prevent the use of nonessential programs, functions, ports, protocols, and services
      • CM.3.069 – Apply deny-by-exception (blacklisting) policy to prevent the use of unauthorized software or deny-all, permit-by-exception (whitelisting) policy to allow the execution of authorized software
  • Identification and Authentication (IA)
    • Grant access to authenticated entities
      • IA.3.083 – Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts
      • IA.3.084 – Employ replay-resistant authentication mechanisms for network access to privileged and non-privileged accounts
      • IA.3.085 – Prevent the reuse of identifiers for a defined period
      • IA.3.086 – Disable identifiers after a defined period of inactivity
  • Incident Response (IR)
    • Develop and implement a response to a declared incident
      • IR.3.098 – Track, document, and report incidents to designated officials and/or authorities both internal and external to the organization
    • Test incident response
      • IR.3.099 – Test the organizational incident response capability
  • Maintenance (MA)
    • Manage maintenance
      • MA.3.115 – Ensure equipment removed for off-site maintenance is sanitized of any CUI
      • MA.3.116 – Check media containing diagnostic and test programs for malicious code before the media are used in organizational systems
  • Media Protection (MP)
    • Identify and mark media
      • MP.3.122 – Mark media with necessary CUI markings and distribution limitations
    • Protect and control media
      • MP.3.123 – Prohibit the use of portable storage devices when such devices have no identifiable owner
    • Protect media during transport
      • MP.3.124 – Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas
  • Physical Protection (PE)
    • Limit physical access
      • PE.3.136 – Enforce safeguarding measures for CUI at alternate work sites
  • Recovery (RE)
    • Manage backups
      • RE.3.139 – Regularly perform complete, comprehensive, and resilient data backups as organizationally defined
  • Risk Management (RM)
    • Manage risk
      • RM.3.144 – Periodically perform risk assessments to identify and prioritize risks according to the defined risk categories, risk sources, and risk measurement criteria
      • RM.3.146 – Develop and implement risk mitigation plans
      • RM.3.147 – Manage non-vendor- supported products (e.g., end of life) separately and restrict as necessary to reduce risk
  • Security Assessment (CA)
    • Define and manage controls
      • CA.3.161 – Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls
    • Perform code reviews
      • CA.3.162 – Employ a security assessment of enterprise software that has been developed internally for internal use and that has been organizationally defined as an area of risk
  • Situational Awareness (SA)
    • Implement threat monitoring
      • SA.3.169 – Receive and respond to cyber threat intelligence from information sharing forums and sources and communicate to stakeholders
  • System and Communication Protections (SC)
    • Define security requirements for systems and communications
      • SC.3.177 – Employ FIPS-validated cryptography when used to protect the confidentiality of CUI
      • SC.3.180 – Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security within organizational systems
      • SC.3.181 – Separate user functionality from system management functionality
      • SC.3.182 – Prevent unauthorized and unintended information transfer via shared system resources
      • SC.3.183 – Deny network communications traffic by default and allow network communications traffic by exception (i.e., deny all, permit by exception)
      • SC.3.184 – Prevent remote devices from simultaneously establishing non-remote connections with organizational systems and communicating via some other connection to resources in external networks (i.e., split tunneling)
      • SC.3.185 – Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards
      • SC.3.186 – Terminate network connections associated with communications sessions at the end of the sessions or after a defined period of inactivity
      • SC.3.187 – Establish and manage cryptographic keys for cryptography employed in organizational systems
      • SC.3.188 – Control and monitor the use of mobile code
      • SC.3.189 – Control and monitor the use of Voice over Internet Protocol (VoIP) technologies
      • SC.3.190 – Protect the authenticity of communications sessions
      • SC.3.191 – Protect the confidentiality of CUI at rest
    • Control communications at system boundaries
      • SC.3.192 – Implement Domain Name System (DNS) filtering services
      • SC.3.193 – Implement a policy restricting the publication of CUI on externally owned, publicly accessible websites (e.g., forums, LinkedIn, Facebook, Twitter)
  • System and Information Integrity (SI)
    • Implement advanced email protections
      • SI.3.219 – Implement email forgery protections
      • SI.3.220 – Utilize sandboxing to detect or block potentially malicious email

CMMC Level 4 Domains, Capabilities, and Practices Requirements

The second-highest requirement level for CMMC compliance is level four. Level four CMMC adds proactive practices to enhance detection and response capabilities and requires a 3POA to regularly review and measure its efficacy and compliance practices. The results of the reviews are shared with higher-level management.

At level four, there are 156 practices to meet CMMC compliance requirements:

  • Access Control (AC)
    • Control internal system access
      • AC.4.023 – Control information flows between security domains on connected systems
      • AC.4.025 – Periodically review and update CUI program access permissions
    • Control remote system access
      • AC.4.032 – Restrict remote network access based on organizationally defined risk factors such as time of day, location of access, physical location, network connection state, and measured properties of the current user and role
  • Asset Management (AM)
    • Review and manage audit logs
      • AM.4.226 – Employ a capability to discover and identify systems with specific component attributes (e.g., firmware level, O.S. type) within your inventory
  • Audit and Accountability (AU)
    • Review and manage audit logs
      • AU.4.053 – Automate the analysis of audit logs to identify and act on critical indicators (TTPs) and/or organizationally defined suspicious activity
      • AU.4.054 – Review audit information for broad activity in addition to per-machine activity
  • Awareness and Training (AT)
    • Conduct security
      • AT.4.059 – Provide awareness training focused on recognizing and responding to threats from social engineering, advanced persistent threat actors, breaches, and suspicious behaviors; update the training at least annually or when there are significant changes to the threat
      • AT.4.060 – Include practical exercises in awareness training that are aligned with current threat scenarios and provide feedback to individuals involved in the training
  • Configuration management (CM)
    • Perform configuration and change management
      • CM.4.073 – Employ application whitelisting and an application vetting process for systems identified by the organization
  • Incident Response (IR)
    • Plan incident response
      • IR.4.100 – Use knowledge of attacker tactics, techniques, and procedures in incident response planning and execution
    • Develop and implement a response to a declared incident
      • IR.4.101 – Establish and maintain a security operations center capability that facilitates a 24/7 response capability
  • Risk Management (RM)
    • Identify and evaluate risk
      • RM.4.149 – Catalog and periodically update threat profiles and adversary TTPs
      • RM.4.150 – Employ threat intelligence to inform the development of the system and security architectures, selection of security solutions, monitoring, threat hunting, and response and recovery activities
      • RM.4.151 – Perform scans for unauthorized ports available across perimeter network boundaries over the organization's Internet network boundaries and other organizationally defined boundaries
    • Manage supply chain risk
      • RM.4.148 – Develop and update as required a plan for managing supply chain risks associated with the I.T. supply chain
  • Security Assessment (CA)
    • Develop and manage a system security plan
      • CA.4.163 – Create, maintain, and leverage a security strategy and roadmap for organizational cybersecurity improvement
    • Define and manage controls
      • CA.4.164 – Conduct penetration testing periodically, leveraging automated scanning tools and ad hoc using human experts
      • CA.4.227 – Periodically perform red teaming against organizational assets in order to validate defensive capabilities
  • Situational Awareness (SA)
    • Implement threat monitoring
      • SA.4.171 – Establish and maintain a cyber-threat hunting capability to search for indicators of compromise in organizational systems and detect, track and disrupt threats that evade existing controls
      • SA.4.173 – Design network and system security capabilities to leverage, integrate, and share indicators of compromise
  • System and Communication Protection
    • Define security requirements for systems and communications
      • SC.4.197 – Employ physical and logical isolation techniques in the system and security architecture and/or where deemed appropriate by the organization
      • SC.4.228 – Isolate administration of organizationally defined high-value critical network components and servers
    • Control communications at system boundaries
      • SC.4.199 – Utilize threat intelligence to proactively block DNS requests from reaching malicious domains
      • SC.4.202 – Employ mechanisms to analyze executable code and scripts (e.g., sandbox) traversing Internet network boundaries or other organizationally defined boundaries
      • SC.4.229 – Utilize a URL categorization service and implement techniques to enforce URL filtering of websites that are not approved by the organization
  • System and Information Integrity (SI)
    • Identify and manage information system flaws
      • SI.4.221 – Use threat indicator information relevant to the information and systems being protected and effective mitigations obtained from external organizations to inform intrusion detection and threat hunting

CMMC Level 5 Domains, Capabilities, and Practices Requirements

At Level 5, Advanced / Progressive cybersecurity practices and a process maturity status of Optimizing have been achieved.  In this highest certification level, a company has a standardized, documented approach to process optimization that covers the entire organization.

At the most stringent level, five, CMMC compliance means that 171 practices are met:

  • Access Control (AC)
    • Control internal system access
      • AC.5.0024 – Identify and mitigate risk associated with unidentified wireless access points connected to the network
  • Audit and Accountability (AU)
    • Perform auditing
      • AU.5.055 – Identify assets not reporting audit logs and assure appropriate organizationally defined systems are logging
  • Configuration management (CM)
    • Perform configuration and change management
      • CM.5.074 – Verify the integrity and correctness of security critical or essential software as defined by the organization (e.g., roots of trust, formal verification or cryptographic signatures)
  • Incident Response (IR)
    • Plan incident response
      • IR.5.106 – In response to cyber incidents, utilize forensic data gathering across impacted systems, ensuring the secure transfer and protection of forensic data
    • Develop and implement a response to a declared incident
      • IR.5.102 – Use a combination of manual and automated, real-time responses to anomalous activities that match incident patterns
      • IR.5.108 – Establish and maintain a cyber incident response team that can investigate an issue physically or virtually at any location within 24 hours
      • IR.5.110 – Perform unannounced operational exercises to demonstrate technical and procedural responses
  • Recovery (RE)
    • Manage information security continuity
      • RE.5.140 – Ensure that information processing facilities meet organizationally defined information security, continuity, redundancy, and availability requirements
  • Risk Management (RM)
    • Manage information security continuity
      • RM.5.152 – Utilize an exception process for non-allow listed software that includes mitigation techniques
      • RM.5.155 – Analyze the effectiveness of security solutions at least annually to address the anticipated risk to the system and the organization based on current and accumulated threat intelligence
  • System Communications and Protection (SC)
    • Define security requirements for systems and communications
      • SC.5.198 – Configure monitoring systems to record packets passing through the organization’s Internet network boundaries and other organizational-defined boundaries
      • SC.5.230 – Enforce port and protocol compliance
    • Control communications at system boundaries
      • SC.5.208 – Employ organizationally defined and tailored boundary protections in addition to commercially available solutions
  • System and Information Integrity (SI)
    • Identify malicious content
      • SI.5.222 – Analyze system behavior to detect and mitigate the execution of normal system commands and scripts that indicate malicious actions
    • Perform network and system monitoring
      • SI.5.223 – Monitor individuals and system components on an ongoing basis for anomalous or suspicious behavior

CMMC Implications

CMMC implications for DoD contracts include:

  • Compliance with NIST regulations for a baseline level of cybersecurity is only a minimum requirement for consideration of a bid.
  • CMMC compliance is a “Go / No-Go” proposal evaluation criterion.
  • CMMC Level 3 is required for most contracts.
  • Primes are contractually responsible for the supply chain’s cybersecurity hygiene.
  • Subcontractors must be certified.

Preparing for a CMMC Audit

  • Assess the CUI Environment
    Determine which assets and systems are in scope, including all assets that directly or indirectly come into contact with Controlled Unclassified Information (CUI).
  • Determine the Certification Level Required for CMMC Compliance
    Levels 1 and 2 are for DoD contractors that do not generally deal with CUI. Levels 3 and 4 apply to DoD contractors that handle CUI. Levels 4 and 5 are at the high end and apply to contractors that need to protect CUI targeted by cyber adversaries or advanced persistent threats (APTs).
  • Readiness Assessment
    Determine which aspects of the cybersecurity program need work, with a focus on how CUI is stored, processed, and transmitted.
  • Identify Remediation Steps
    Assess risks associated with security gaps and quantify the steps needed to achieve compliance at the appropriate level.
  • Create a Compliance Roadmap
    Develop a plan to remediate security gaps based on priorities and resources.
  • Implement and Maintain Ongoing Monitoring
    The DoD requires contractors to monitor systems on an ongoing basis and report incidents.

Win-Win with CMMC Compliance

CMMC compliance is an option for any contractor or subcontractor that works with the DoD, and the tiered approach makes it achievable for most contractors. The effort to achieve CMMC compliance will also provide significant benefits to the organization from a security perspective.

Egnyte has experts ready to answer your questions. For more than a decade, Egnyte has helped more than 16,000 customers with millions of customers worldwide.

Last Updated: 3rd August, 2021

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