RESOLVED: Start now to prepare for CMMC in 2020

There is no need to delay. Here is how you can make your CMMC New Year's Resolution become a reality.

Cybersecurity continued to be front-page news in 2019, as ransomware threats rose and government systems nationwide were increasingly targeted. From the largest hospital in New Jersey to some of the nation’s most prominent cities, cyber systems that deliver essential services were subjected to disruptions and losses caused by adversaries wielding sophisticated ransomware such as Ryuk, REvil, BitPaymer, etc.

The Department of Defense is adding some muscle to the fight. In recognition of growing threats and increasing weaknesses in its supply chain, the DoD has published draft guidelines, the Cybersecurity Maturity Model Certification 0.7 (CMMC), for its more than 300,000 defense contractors - before full implementation in January. Every contractor, large and small – prime and sub – will be required to be CMMC-certified in 2020. Cybersecurity maturity will be the fourth critical measurement along with cost, quality, and schedule. This compliance model will ultimately define cyber standards across several maturity levels that range from basic cyber hygiene to advanced cyber maturity.

What does this mean for defense contractors aiming to meet CMMC criteria in the new year? Simply put - start now.

Forward-leaning defense contractors who prioritize cybersecurity readiness should initiate these three preparatory steps even before year-end:

  1. Inventory current cybersecurity practices and protocols against the CMMC 0.7 version that spells out criteria for Levels 1-5 certification.

Level 1 is the foundational layer that sets out the basic cyber hygiene practices that contractors must meet, and which upon all other Levels are built.

Beginning at Level 2, intermediate cyber hygiene practices are established, allowing the organization to more effectively respond to cyber threats. Additionally, level 2 introduces the process maturity dimension of the framework, requiring organizations to have standard operating procedures, policies, and plans for all practices.

To achieve Level 3 and beyond, contractors must implement effective controls that meet many of the security requirements of NIST SP 800-171 Rev 1, including for contracts that require access to or generate controlled unclassified information (CUI). Proper endpoint detection and response capabilities, antivirus software, and overall good IT hygiene will help achieve this status. 

The new NIST SP 800-171b draft will help address levels 4 and 5. However, even at Level 5, the DoD model indicates that companies will only then have the capability to optimize capabilities in “an attempt to repel” advanced persistent threats (APTs). Clearly, today’s threat environment is rapidly evolving and growing more sophisticated. Maturity frameworks like the CMMC must evolve as well.

  1. Identify gaps and plan improvements in processes and practices to achieve readiness for third-party CMMC assessment.

This step means looking across every company platform for material weaknesses that can be exploited by bad actors. Oftentimes, this can begin with auditing past security missteps and holes in protection from legacy systems. The methods to protect networks that agencies have employed in the past may no longer serve their intended purpose - now is the time to implement a fresh approach to improving organizational security posture.

Research shows that attackers are quick to target smartphones and endpoint devices – in short any connected devices that are generally less protected than government computers. CrowdStrike’s 2019 Mobile Threat Report found a diverse array of adversary groups are increasing attacks on mobile platforms.

  1. Last, and most important, evaluate where your company is on the road to process maturity in each of the CMMC domains.

Each domain requires meeting the appropriate process maturity standards for every level beyond basic cyber hygiene. Most domains are familiar and range from access control, risk management, awareness and training, asset management, recovery, and situational awareness.

Establishing readiness in each of the domains, however, means taking a comprehensive approach to tasks your organization will be carrying out as part of a federal contract.

CrowdStrike studies show that organizations are largely underprepared for new cyber threats. In a recent survey of 1,900 senior IT decision-makers, analysis found U.S. organizations take an average of 101 hours to detect, triage, and contain a data breach. This translates into over four days of round-the-clock work. Remember, the gold standard to combat sophisticated cyber threats is the 1-10-60 benchmark: detect an intrusion in under one minute; perform a full investigation in under 10 minutes; and, remove the adversary in under 60 minutes.

The adoption of frameworks like 1-10-60 and other proactive security technologies, processes, and techniques are critical to getting in front of the ever-changing cyber landscape.

Cybersecurity technologies that harness the power of the cloud, machine learning and artificial intelligence to rapidly detect, prevent, and remediate threats are all critical to shutting down today’s stealthy adversaries. Leveraging these modern tools will also help to achieve the level of cybersecurity maturity that will soon be mandated by the DoD via the CMMC standards.

The bottom line is that CMMC is a vital new DoD initiative, one that is essential to carrying out the important work of the defense industrial base, who in partnership with the government are charged with carrying out a very complex and extremely important mission.

Resolve to start now on a New Year’s resolution to achieve CMMC readiness.

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