What to Expect Ahead of Your CMMC 2.0 Level 2 Audit
CMMC compliance involves undergoing (and passing) a rigorous CMMC compliance audit. In this webinar, a panel of CMMC compliance experts offer best practices for successfully completing the CMMC audit. Recommendations include where to find and how to effectively vet a certified third-party assessor organization (C3PAO), how to develop and use a plan of action and milestones (POA&M), and many other strategies to help defense contractors achieve CMMC compliance.
CMMC Compliance Challenges for Defense Contractors
CMMC compliance requires defense contractors to ensure the security and proper handling of sensitive information like controlled unclassified information (CUI) and federal contract information (FCI). Below are some of the biggest challenges contractors in the defense industrial base (DIB) face when exchanging sensitive data in the context of CMMC compliance.
Secure Email Communications
Email is a common method of communication, but it is also vulnerable to interception and unauthorized access. To mitigate this risk and stay on the right side of CMMC compliance, DIB contractors must implement secure email protocols, such as encryption and digital signatures, to protect and verify the integrity of sensitive information transmitted via email. Additionally, contractors should consider using email solutions that have achieved FedRAMP Moderate authorization, which ensures that the service provider has met stringent security requirements set by the U.S. government.
CUI Identification and Labeling
Controlled Unclassified Information (CUI) encompasses a wide range of sensitive information that must be protected, a requirement for CMMC compliance. Defense contractors therefore must develop and implement processes to correctly identify and label CUI across various formats, including digital and physical documents, emails, and digital assets. Properly identifying and labelling CUI facilitates CMMC compliance by ensuring that sensitive information receives the appropriate level of protection and is only shared with authorized individuals.
Access Control and Permission Management
As part of CMMC compliance, DIB contractors must establish strict access controls to ensure that only authorized personnel can access sensitive information. This involves implementing role-based access control (RBAC) systems, regularly reviewing and updating user permissions, and promptly revoking access when an employee’s role changes. Contractors must also maintain detailed audit logs that keep a record of access to sensitive data and detect any unauthorized access attempts.
Secure File Sharing and Collaboration
DIB contractors collaborate daily on CUI and FCI with their DoD colleagues. CMMC compliance requires these collaborations to be secure. DIB contractors therefore must use secure file-sharing solutions that provide end-to-end encryption, access controls, and auditing capabilities. When selecting a file-sharing platform, contractors should choose solutions that are FedRAMP authorized for Moderate Impact Level information or higher. This ensures the protections in place adhere to some of the highest levels of security and compliance standards.
Managed File Transfer for Large or Bulk Files
CMMC compliance mandates the secure transfer of large or bulk files containing CUI and FCI between between DIB contractors and their DoD clients. A secure managed file transfer solution should contain features like encryption of data in transit and at rest, access controls, granular permissions, and detailed audit logs. Ideally, managed file transfer solutions should be FedRAMP authorized for Moderate Impact Level information to ensure they meet the highest levels of security and compliance.
Demonstrating Compliance Efficiently
Most communication tools, like email, SFTP, and file-sharing platforms, reside in silos and therefore generate separate audit logs. Aggregating and reconciling these logs as part of a CMMC compliance audit can be, if not virtually impossible, an excruciating and time-consuming task. By contrast, a consolidated, comprehensive audit log that tracks all files containing CUI and FCI that enter and leave the organization can save valuable time and money.
Accelerate Your CMMC 2.0 Compliance Journey With Kiteworks
Control, Protect, and Track Your Sensitive DoD Communications
Demonstrate CMMC compliance whenever you send, share, receive, or store CUI and FCI. Granular access controls, multi-factor authentication, end-to-end encryption, and secure links ensure only authorized users have access to this sensitive data. Consolidate secure email, secure file sharing, secure managed file transfer, secure web forms, and APIs into one platform to unify metadata and standardize security policies and controls. Finally, a single point of integration for security investments like ATP, DLP, CDR, LDAP/AD, and SIEM let defense contractors and subcontractors protect sensitive data for CMMC compliance.
Learn more about Kiteworks security capabilities for protecting FCI and CUI
Fast Track CMMC Compliance With a FedRAMP Deployment
Avoid the time and cost of proving your cloud platform meets 325 NIST 800-53 security controls—critical for CMMC compliance—by adopting one the U.S. federal government has already approved: Kiteworks’ FedRAMP Moderate Authorized Private Data Network. Unlike “FedRAMP equivalent” vendors, Kiteworks undergoes regular pen tests and employee screening, and is backed by strong encryption, physical security, incident response plans, and more. A FedRAMP Moderate Authorization equips defense contractors with genuine evidence of security controls, so they meet a critical CMMC requirement and accelerate CMMC compliance.
Safeguard CUI With Comprehensive Access Controls
Centrally administer a single set of user roles and policies to protect the CUI that flows through all the communication channels the Kiteworks platform consolidates. Mitigate the risk of inadvertent or malicious CUI exposure with default least-privilege access controls over folders, emails, SFTP, managed file transfer flows, and web forms, as well as clients, functions, repositories, and domains. With Kiteworks, administrators apply granular policy controls and role-based permissions for external users to protect CUI from unauthorized access, a critical requirement for CMMC compliance.
Learn more about Kiteworks unified security for protecting sensitive data
Protect CUI With Seamless End-to-End Email Encryption
Safeguard the CUI you share via email with your DoD stakeholders with strong encryption ciphers. Apply your security policies to your email encryption to automate the decision of whether or not to encrypt each email. Automated key exchange ensures user simplicity so your employees work with their normal email standard clients without the need for plugins or training. With end-to-end encryption, you ensure email data and attachments are encrypted from sending client to receiving client while the private decryption key stays in receiving client so neither server-side vendors or attackers can decrypt. Finally, apply your DLP to outbound traffic and your anti-malware and anti-phishing to inbound traffic. You’ll look great in front of your C3PAO and take another step toward CMMC compliance.
Track All File Activity and Simplify Your CMMC Compliance Audit
See who sent CUI or FCI to whom, when, and how so you can track this and other sensitive data entering and leaving your organization, detect suspicious activity, and take action on anomalies. Accelerate CMMC compliance audits with comprehensive, immutable audit logs for all user, automated, and admin activities, including all actions on data, permissions, and configuration. Analyze, alert, and report on the events using built-in tools, or forward to your SIEM via syslog or the Splunk Forwarder for deeper analysis.
Maintain Maximum Security With Tightly Managed Configurations
Adhere to the principle of least functionality required for CMMC compliance by exposing only a few essential ports, with all nonessential services disabled. Protected by a hardened virtual appliance, Kiteworks prevents users and administrators from accessing the operating system or installing software, enforces strict separation of duties, and logs every configuration change. And when you prepare for your CMMC compliance audit, it provides the reporting you need to validate configurations and documented controls.
LEARN MORE ABOUT PROTECTING YOUR SENSITIVE DATA WITH KITEWORKS SECURITY INTEGRATIONS
Enable Productivity Without Compromising Data Custody
Protect CUI and demonstrate CMMC compliance by enabling secure external collaboration on sensitive files without relinquishing control over the original source documents. With Kiteworks SafeEDIT next-generation DRM, CUI and FCI remain safely stored within your environment. By streaming an editable video rendition of files rather than transferring possession, CUI never leaves your security perimeter, providing the highest level of security, control and tracking. Enjoy seamless remote workflows while maintaining strict data protection with a native application experience for editing and collaborating on the streamed file renditions.
LEARN MORE ABOUT PROTECTING SENSITIVE DATA WITH KITEWORKS SAFEEDIT DRM
CMMC Compliance FAQs
CMMC Level 1 (Foundational): Focuses on the protection of Federal Contract Information (FCI) and consists of 15 basic safeguarding requirements from FAR Clause 52.204-21. CMMC Level 2 (Advanced): Focuses on the protection of Controlled Unclassified Information (CUI) and incorporates all 110 security requirements from NIST 800-171 Rev 2. CMMC Level 3 (Expert): Focuses on protecting CUI with enhanced requirements, encompassing a subset of 24 NIST 800-172 security requirements with DoD-approved parameters
CMMC 2.0 implementation begins with Phase 1 (Initial Implementation), which starts when the 48 CFR Rule becomes effective and requires CMMC Level 1 or CMMC Level 2 self-assessment requirements. Phase 2 commences 12 months after Phase 1 begins and introduces the requirement for CMMC Level 2 Certification. Next, Phase 3 starts 24 months after Phase 1 and adds the requirement for CMMC Level 3 Certification. The final stage, Phase 4 (Full Implementation), begins 36 months after Phase 1 and represents complete implementation, where all solicitations and contracts must include applicable CMMC Level requirements. The DoD maintains the flexibility to implement CMMC requirements ahead of these planned phases for specific procurements as needed.
Organizations in the Defense Industrial Base (DIB) sector that process, store, or transmit Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) must comply with CMMC. This includes over 220,000 product and service providers that support the Department of Defense (DoD) supply chain – from prime contractors to subcontractors. These organizations contribute to DoD systems, networks, installations, capabilities, and services, and must meet CMMC requirements to protect sensitive defense information.
CMMC 2.0 prohibits POA&Ms for CMMC Level 1 but allows them for CMMC Level 2 and CMMC Level 3. Organizations must close POA&Ms within 180 days of assessment completion. While POA&Ms enable Conditional status, all items must be closed to achieve Final status. Requirements are defined in § 170.21 of the CMMC Program final rule.
CMMC Level 2 focuses on protecting Controlled Unclassified Information (CUI) and incorporates 110 security requirements specified in NIST 800-171 Rev 2. This level covers key domains like access controls, incident response, security assessment, and system integrity.
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