32CFR Final Rule Published – CMMC goes live!

On October 15, 2024, the Federal Register was updated with the CMMC Final Rule (32CFR). This rule will be fully effective on December 15, 2024. Link to Federal Register for CMMC This link goes to the U.S. Government’s Federal Register Read More

CMMC Final Rule moves to OIRA review

Exciting morning in Defense Contractor land! The CMMC Final Rule (32 CFR) has moved to its last phase before publication. It is in OIRA review (Office of Information and Regulatory Affairs – the technical editors/reviewers for government regulations). All the Read More

DoD estimates CMMC paperwork burden

“OSCs must retain artifacts used as evidence for the assessment for the duration of the validity period of the certificate of assessment, and at minimum, for six years from the date of certification assessment as addressed in 32 CFR 170.17(c)(4). Read More

C3PAO Shopping Guide

The National Defense Information Sharing & Analysis Center (ND-ISAC) is pleased to announce the release of a “C3PAO Shopping Guide for Small & Medium-Sized Businesses.”  The guide was created through a team effort among participants in ND-ISAC’s Small & Medium-Sized Business Read More

When do you need a new assessment? What can change?

Information systems are constantly changing. Especially if they are functional, production systems, supporting real use. Workstations and servers break. Technology becomes obsolete. New solutions are implemented in response to changing functional requirements. One thing we don’t know, in the CMMC Read More

What is “Certified” as the result of assessment??

What exactly is “certified” when you go through a CMMC or Joint Surveillance assessment, or when you self-assess your environment and report it to the DoD? What does it mean when you want to bid on contracts using this certification? Read More

CISA Proposed Rule – Mandatory Reporting of Cyber Incidents

CISA releases proposed rule for mandatory reporting of cyber incidents by Critical Infrastructure and State, Local, Territorial Governments. To my understanding, this will affect all DoD contractors with DFARS 252.204-7012 in their contracts, as well as most Federal Contractors. For Read More

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 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 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! 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 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 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 “𝘚𝘢𝘧𝘦𝘨𝘶𝘢𝘳𝘥𝘪𝘯𝘨 𝘮𝘦𝘢𝘴𝘶𝘳𝘦𝘴 𝘧𝘰𝘳 𝘊𝘜𝘐 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 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 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 Read More

Why so few Defense contractors are compliant

𝐇𝐨𝐰 𝐥𝐨𝐧𝐠 𝐝𝐨𝐞𝐬 𝐢𝐭 𝐭𝐚𝐤𝐞 𝐚 𝐜𝐨𝐦𝐩𝐚𝐧𝐲 𝐭𝐨 𝐠𝐨 𝐛𝐚𝐧𝐤𝐫𝐮𝐩𝐭 𝐢𝐭 𝐰𝐡𝐞𝐧 𝐜𝐚𝐧’𝐭 𝐰𝐢𝐧 𝐰𝐨𝐫𝐤? 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 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 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. 😱 💥 💥 𝐅𝐈𝐏𝐒 140-2 𝐕𝐚𝐥𝐢𝐝𝐚𝐭𝐞𝐝 𝐌𝐨𝐝𝐮𝐥𝐞𝐬 💥 💥 😱 Listen up – I’m going to tell you how to succeed Read More

3.5.3 Multifactor Authentication

Multifactor Authentication: #2 of the top 10 “Other than Satisfied Requirements” for 800-171 assessments by DIBCAC. 𝐔𝐬𝐞 𝐦𝐮𝐥𝐭𝐢𝐟𝐚𝐜𝐭𝐨𝐫 𝐚𝐮𝐭𝐡𝐞𝐧𝐭𝐢𝐜𝐚𝐭𝐢𝐨𝐧 𝐟𝐨𝐫 𝐥𝐨𝐜𝐚𝐥 𝐚𝐧𝐝 𝐧𝐞𝐭𝐰𝐨𝐫𝐤 𝐚𝐜𝐜𝐞𝐬𝐬 𝐭𝐨 𝐩𝐫𝐢𝐯𝐢𝐥𝐞𝐠𝐞𝐝 𝐚𝐜𝐜𝐨𝐮𝐧𝐭𝐬 𝐚𝐧𝐝 𝐟𝐨𝐫 𝐧𝐞𝐭𝐰𝐨𝐫𝐤 𝐚𝐜𝐜𝐞𝐬𝐬 𝐭𝐨 𝐧𝐨𝐧-𝐩𝐫𝐢𝐯𝐢𝐥𝐞𝐠𝐞𝐝 𝐚𝐜𝐜𝐨𝐮𝐧𝐭𝐬. My theory is that most of Read More