Eric Noonan

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What to Do if Your Prime is Asking You Demonstrate Compliance with DFARS 252.204-7012 and NIST 800-171?

Lockheed Martin and other prime contractors are contacting their suppliers and requesting a security status update; in many cases requesting a demonstration of compliance before the DOD November 30th deadline.  If you’ve received this request, you’re not alone. We’re helping

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DOD Released a New Interim Final DFARS Rule Covering CMMC and NIST 800-171

Defense Federal Acquisition Regulation Supplement: Assessing Contractor Implementation of Cybersecurity Requirements (DFARS Case 2019-D041) is here. Often referred to as CMMC this long-awaited and hotly debated Interim Rule harmonizes legacy (DFARS clause 252.204-7012) and future (CMMC) requirements with the following

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Calling Industries Bluff: The DOD Emergency Action on NIST 800-171 Compliance

The Department of Defense (DOD) has instituted an emergency action, possibly to confirm what is widely already known on cybersecurity compliance among the defense industrial base (DIB). Self-certification for defense contractors has enabled “barely there” cybersecurity unless you are one

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Recent DOD Audit on Controlled Unclassified Information Finds Contractors Not Secure

Have contractors implemented the NIST 800-171 controls? DOD Inspector General (IG) audit suggests not, recommends third-party audits. Are you ready?

A recent audit conducted in response to a request from the Secretary of Defense determined that DOD contractors did not consistently implement DOD‑mandated system security controls for safeguarding Defense information. Specifically, Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012 requires contractors that maintain Controlled Unclassified Information (CUI) to implement security controls specified in National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171, which lists security requirements for safeguarding sensitive information on non-Federal information systems. The requirements include controls for user authentication, user access, media protection, incident response, vulnerability management, and confidentiality of information.

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Everything You Should Do to Effectively Prepare for Cybersecurity Maturity Model Certification (CMMC)

CyberSheath has attended multiple listening sessions and events with DOD leadership revealing more information regarding the DOD Cybersecurity Maturity Model Certification (CMMC).  I want to expand on our previous blog with the additional details and actionable plans on what DOD contractors need to do to prepare for the changes.

What We Understand about CMMC so Far

CMMC stands for “Cybersecurity Maturity Model Certification” and will encompass multiple maturity levels that range from “Basic Cybersecurity Hygiene” to “Advanced”. The intent is to identify the required CMMC level in Request for Proposals (RFP) sections L and M to be used as a “go / no go decision.” This means that instead of the ability to bid and win a contract and then comply post-award with cybersecurity requirements, DOD contractors will have to be certified to the CMMC level required in advance, pre-bid, to even be eligible to bid.

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