Almost every defense contractor makes one or more of these design errors when they start building their CMMC Level 3 network
Author: Amira Armond
DFARS 252.204-7012 controls discussion for CMMC
Why is there a page for DFARS 252.204-7012 on a CMMC website? DFARS 252.204-7012 is a contract requirement for defense contractors that handle or might handle Controlled Unclassified Information (CUI). Unlike the CMMC, DFARS 7012 is currently required and should be a priority for DoD contractors that deal with CUI. You can tell if your Read More
How to submit a NIST SP 800-171 self assessment to SPRS
Answers to common questions about how to submit your NIST SP 800-171 self assessment to SPRS. Register an account, how to handle multiple…
FedRAMP “Equivalent” Memo released
Must read for anyone with DFARS 252.204-7012 in their contract! FedRAMP equivalent is defined for DFARS 252.204-7012 Summary: FedRAMP Equivalency, as used in DFARS 252.204-7012, means that the cloud provider has been third-party-validated, with a full audit, by a FedRAMP Third Party Assessment Organization, to have implemented every control from the FedRAMP Moderate baseline. How Read More
CMMC Level 2 Self-Assessment Analysis
Our sponsor, Kieri Solutions, has released an in-depth review and analysis of CMMC Level 2 Self-Assessments according to the CMMC Proposed Rule. Not official guidance for CMMC Proposed Rule This paper is for educational purposes and is not authoritative in any way for the CMMC Program. Includes instructions to comment on CMMC Proposed Rule Towards Read More
Webinar – CMMC Proposed Rule Review
Our sponsor, Kieri Solutions, produced this webinar to review the hottest topics of the CMMC Proposed Rule. Thanks to Vincent Scott, Brian Hubbard, Jil Wright, and Amira Armond (all Certified CMMC Assessors and Instructors) for providing insightful review and commentary! 32CFR CMMC Proposed Rule Webinar What are your thoughts? Do you think Certification Assessments will Read More
CMMC Rule links to text (with December 26 content)!
Here are links to the text of the CMMC Proposed Rule: 32 CFR (CMMC Program) Downloadable PDF of Federal Register text (this version has page numbers): https://public-inspection.federalregister.gov/2023-27280.pdf Federal Register home page for CMMC and comments: https://www.federalregister.gov/documents/2023/12/26/2023-27280/cybersecurity-maturity-model-certification-cmmc-program Docket Information (the rule agenda): https://www.regulations.gov/docket/DOD-2023-OS-0063 Public comments posted regarding rule: https://www.regulations.gov/document/DOD-2023-OS-0063-0001 Regulatory Impact Analysis 32 CFR Part 170 Read More
Is GCC-High required to pass CMMC?
Amira Armond (CMMC Instructor, Certified CMMC Assessor, President Kieri Solutions) answers the question “Is GCC-High required to pass a CMMC assessment?” This is actually an explanation of what the FedRAMP program is and is not. This video is meant for educational and entertainment purposes only. These are opinions presented in a purposefully simplified format. Enjoy, Read More
How the secret sauce is made – one practice, one hour
How does a defense contractor create a plan to perform each requirement in CMMC and NIST SP 800-171? Will you fail if you don’t write policy statements which regurgitate each requirement in a ‘shall” form? AKA “???????????? ???????? ??? ??? ?? ??????????? ???? ????? ????? ?? ????????.” The answer is no. You don’t need to Read More
Joint Surveillance Assessment – what is it like?
This is an interview with Jose Rojas (TTC) and Ozzie Saeed (IntelliGRC) about their experience being assessed by Kieri Solutions, an Authorized C3PAO, as part of the Joint Surveillance Voluntary assessment program. Other than the obvious congratulations to both of them for helping TTC achieve a perfect “110” score on their assessment, we discuss what Read More
CMMC News – October 2023 – the DFARS Rule
Rulemaking Timeline for CMMC DFARS Rule The proposed CMMC Rule has been submitted to the Office of Information and Regulatory Affairs. Several groups (mostly cybersecurity professionals) have met with DoD CIO and OIRA to give recommendations for the rule. Most of them submitted documents with their feedback which can be downloaded from the EO 12866 Read More
What does “monitor” mean in CMMC?
Logan Therrien and Amira Armond from Kieri Solutions (an Authorized C3PAO) discuss the concept of monitoring and how it is evaluated by CMMC assessors. Several assessment objectives in CMMC Level 2 require monitoring. ? the physical facility where organizational systems reside is monitored;? the support infrastructure for organizational systems is monitored.? visitor activity is monitored.? Read More
Why so few Defense contractors are compliant
??? ???? ???? ?? ???? ? ??????? ?? ?? ???????? ?? ???? ???’? ??? ????? One year? Two? Three? Let me tell you a story about how a system of perverse incentives caused our current cybersecurity situation in the Defense Industrial Base. Back in 2017 (six years ago), new and renewing DoD contracts started including Read More
Podcast – increasing the likelihood of passing CMMC assessments
This podcast by Omnistruct features Amira Armond, John Riley, and George Usi. Recorded in May-June 2023. They discuss the basics of CMMC, the “hardest” requirement (FIPS of course), the aspects that contractors have the most difficulty with, and the status of the roll-out. Check it out! The link below has the full text transcript: Omnistruct: Read More
CMMC Breaking News – July 25, 2023
Today we had two big events in #CMMC and US Federal Contractor Cybersecurity. The Rule for CMMC moved to the Office of Management and Budget. That means a timer has started, 90 days or less, for the review to complete. Expect the text to be published by mid-October. There is still a possibility that it will come Read More
3.13.11 FIPS 140-2 Validated Cryptography
It is time, finally, to talk about the #1 “Other than Satisfied” requirement in 800-171, per historic DIBCAC assessments. ? ? ? ???? 140-2 ????????? ??????? ? ? ? Listen up – I’m going to tell you how to succeed at this requirement. It might take money, it might take time, but it CAN be Read More
3.5.3 Multifactor Authentication
Multifactor Authentication: #2 of the top 10 “Other than Satisfied Requirements” for 800-171 assessments by DIBCAC. ??? ??????????? ?????????????? ??? ????? ??? ??????? ?????? ?? ?????????? ???????? ??? ??? ??????? ?????? ?? ???-?????????? ????????. My theory is that most of the time when this requirement is failed, it is because the IT department didn’t know Read More
What are Spot Checks for?
???? ?????????? ???? ?????? “?? ??????????’? ????-????? ???????? ????????, ??????????, ??? ????????? ????????????? ?? ????? ???????? ????? ????????? ????? ????? ??????, ??? ???????? ??? ??????? ? ??????? ???? ????? ?? ???????? ?????. ??? ??????? ???? ?????(?) ????? ??? ?????????? ???????? ??? ?????????? ???????? ??? ??? ?????????? ????. ??? ??????? ???? ?????(?) ???? ?? ?????? ??? ??????? Read More
3.14.1 Identify, report, correct system flaws
Continuing the Top 10 “Other than Satisfied Requirements” for 800-171 assessments by DIBCAC. “????????, ??????, ??? ??????? ??????????? ??? ??????????? ?????? ????? ?? ? ?????? ??????.” This is the third most “Other than Satisfied” requirement. 3.14.1 is both misunderstood and very hard to implement. Both problems cause failures. ??? ?? 3.14.1 ?????????????? Most people read the Read More
3.11.1 Periodically assess the risk to organizational operations
3.11.1 ???????????? ?????? ????…This is the fourth-most “Other than satisfied” #CMMC requirement. 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. Not hard to do, but often misunderstood. Let’s break it down. ???????????? Read More
3.11.2 Scan for Vulnerabilities
Scan for vulnerabilities….This the fifth-most “Other than satisfied” #CMMC requirement with an 18% fail rate. 3.11.2 ???? ??? ??????????????? ?? ?????????????? ??????? ??? ???????????? ???????????? ??? ???? ??? ??????????????? ????????? ????? ??????? ??? ???????????? ??? ??????????. “?????????????? ???????”…This is an example of a broadly-applicable requirement – something that is expected to be applied ???????????? from boundary to Read More
3.3.3 Review and Update Logged Events
This is #6 in the series of most common failed requirements as assessed by the DoD’s Cyber Assessment Center. This requirement is another example of misunderstanding == failing (alongside the other top 10 requirements). Most people do not understand what is expected for 3.3.3. To “review and update logged events”, you must consider ????? ?????? Read More
3.3.4 Audit Logging Process Failure
Continuing the Top 10 Failed Requirements for 800-171! Onward to #7: 3.3.4 “????? ?? ??? ????? ?? ?? ????? ??????? ??????? ???????.” Sit with me while I tell a story… ?? ???????????? ????????? ???? ???? ???? ???????? ??????? ?????????? ??????? ??? ????? ???? ?? ??? ???? ???. ??3 ???????? ???????? ????? ??? ??????; ???? ????? Read More
3.3.5 Correlate Audit Processes
NIST SP 800-171 3.3.5 ????????? ????? ?????? ??????, ????????, ??? ????????? ????????? ??? ????????????? ??? ???????? ?? ??????????? ?? ????????, ????????????, ??????????, ?? ??????? ????????. This is the 8th most likely requirement to be “other than satisfied” by defense contractors, according to the DoD’s Cybersecurity Assessment Center. The problem is that this requirement can be read Read More
C3PAO CMMC Level 2 Assessments
On behalf of CMMCAudit.org, I’m excited to share this interview with Kyle Lai about his lessons learned from the CMMC Level 2 assessment performed by DCMA DIBCAC against his C3PAO: KLC Consulting. This video is packed with actionable information about how CMMC Level 2 assessments are performed. We compared and contrasted between the assessment that Read More
CMMC Scoping for Level 2
This video is provided by Amira Armond and Jil Wright (CMMC Provisional Assessors and Provisional Instructors) from Kieri Solutions, an Authorized C3PAO. Topics discussed in the video are: This content is way more than the CCP course blueprint covers and more in-depth than what is normally covered in CCA courses! If you haven’t seen it yet, go watch the CMMC Read More
CMMC Scoping for Level 1
This video is provided by Amira Armond and Jil Wright (CMMC Provisional Assessors and Provisional Instructors) from Kieri Solutions, an Authorized C3PAO. Topics included are: Enjoy, and don’t forget to subscribe to our YouTube channel for lots of other CMMC training content. Kieri Solutions is an Authorized C3PAO providing CMMC and 800-171 assessment and preparation Read More
3.6.3 Test the Organizational Incident Response Capability
This was originally posted on LinkedIn. Check the original post and community discussion here! On to the next requirement! 3.6.3 ???? ??? ?????????????? ???????? ???????? ??????????. This is post #5 in my series analyzing the top ten failed / misunderstood NIST SP 800-171 and #CMMC requirements according to DIBCAC. Incident response testing is the 9th most “other Read More
3.4.1 Establish / Maintain Baseline Configurations
This series reviews the top failed (misunderstood) 800-171 and CMMC requirements. Originally posted on LinkedIn – check the start of series here for community conversation and thoughts! 3.4.1 ?????????/???????? ???????? ?????????????? This one is both commonly misunderstood and difficult to implement, even though it can be 100% a manual process. First, the requirement language is split into two Read More
Excuses that won’t work for your CMMC assessment
Public Safety Announcement for #CMMC and DIBCAC assessments of 800-171 compliance. “My _________ is scheduled to occur in January and we haven’t reached January yet.” – said too many Organizations Seeking Certification Do not try to use this excuse to explain why you lack evidence for performing an 800-171 requirement! Your assessor will not be sympathetic. What Read More