Rethinking the Role of Compliance

Continuous Compliance Steps Cybersecurity Departments Should Be Taking to Prepare for CMMC 2.0

By: Igor Volovich, VP, Compliance Strategy

Historically, compliance has been seen as a box one could check, a milestone to achieve, an administrative task to cross off our list, and put in the rearview mirror; but alas, in today’s continuously evolving cybersecurity landscape, the only way to elevate and sustain an organization’s security posture is continuous compliance. According to ISACA, “continuous compliance is a proactive approach to maintaining the requirements set by frameworks and regulations across a business environment on an ongoing basis.” The proactive approach ensures that requirements are met not just at one moment in time (an audit), but as part of ongoing, continuous operations. And, the requirement at the top of mind for most federal contractors is CMMC.

The Cybersecurity Maturity Model Certification (CMMC), published on January 31, 2020, introduces new standards of accountability and security in the defense industry and is designed to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) that is shared with contractors and subcontractors of the Department through acquisition programs. The program was built to protect the defense industrial base (DIB) from increasingly frequent and complex cyber-attacks. An estimated 200,000-350,000 contractors, including custodial companies, bookkeepers, caterers, and small IT firms, will need to hold a CMMC certification to demonstrate the maturity of their cybersecurity processes and practices.

The DOD released the final proposed rule in Dec 2023, which informed defense contractors exactly how the newly defined CMMC 2.0 assessment process will be used to validate the practices and controls deployed to safeguard the government’s sensitive data entrusted to the Defense Industrial Base. Below are seven continuous compliance steps federal civilian agencies should be taking now (if not already underway) to prepare for CMMC 2.0.

  1. Invest in technical evidence: CMMC 2.0 requires the demonstration of technical evidence to show compliance. Invest in compliance automation technology that enables the continuous collection and analysis of technical evidence to streamline compliance efforts. From data validation, control state analysis, creation of POA&Ms and SSPs, reporting, dashboarding, audit and assessment support, look for a technology provider that automates every phase of the compliance workflow and maps data to specific controls as outlined in the latest CMMC assessment standard.

  2. Build a culture of risk management: CMMC 2.0 requires a shift in culture towards a more risk-focused approach. This requires leadership buy-in, employee education and training, and a clear understanding of the risk landscape. True cybersecurity cannot be achieved when risk, security, and compliance are considered separate domains and functions. Rather than confining the security, risk, and compliance work to siloed departments, stakeholders from all levels and functions need to integrate to drive true enterprise-wide risk visibility and management maturity
  3. Establish a clear governance framework: Governance requires current and accurate knowledge of one’s operating environment and its risk posture. Establish a governance model that defines roles and responsibilities for compliance and risk management. This model should be well-communicated and understood throughout the organization. Organizations should continuously assess their governance maturity, their capacity to manage their environment, to maintain visibility to security controls, and demonstrate a credible ability to influence risk outcomes across the enterprise.

  4. Build a compliance program that is agile and flexible: Compliance is not a box to be checked – it requires continuous monitoring, agility, and flexibility as new standards and frameworks emerge. Build a compliance program that can quickly adapt to new and emerging regulatory requirements. This requires a commitment to ongoing education and training, as well as investment in technology that enables automation and real-time monitoring.

  5. Develop a strong incident response plan: Incident response is a critical component of nearly every compliance standard and framework to prevent panic and poor decisions when emotions are high. Develop a strong incident response plan that includes clear escalation procedures and an identified rapid response team equipped and enabled to access real-time data about your enterprise assets, infrastructure, and security controls. Ask the following:
    • Who at the organization is responsible for what action
    • What steps to take to mitigate an attack
    • How to share internal and external communications
    • Lessons learned to improve future responses

  6. Partner with an experienced compliance automation provider: CMMC compliance can be complex and time-consuming. Partner with an experienced cybersecurity compliance automation provider that can offer guidance and support throughout the compliance process, while strategically leveraging technology to transform manual processes and augment human assets across the compliance management lifecycle. An integrated approach to cybersecurity and risk transformation – what we call Converged Continuous Compliance – allows enterprises to discover untapped potential in their existing investments in compliance and security.

  7. Understand the CMMC timeline: The CMMC timeline has been evolving since the announcement of CMMC 2.0. Since the publication of the proposed rule by the DoD on December 26, 2023, the target date for requiring CMMC 2.0 certification as a condition of contract award has been established as October 1, 2025. This timeline leaves a little over 20 months for members of the defense industrial base to assess their compliance posture, identify and remediate any control deficiencies, and prepare and undergo the certification process. It’s important to understand that the new CMMC certification model requires annual affirmation of continuous compliance posture as a condition of contract award, which means that enterprises must not only achieve but sustain their security control posture on an ongoing basis.

  8. Compliance Readiness as Competitive Advantage: Another factor is the notion of compliance readiness and agility emerging as a matter of competitive advantage: firms capable of achieving and demonstrating their compliance posture at an accelerated pace ahead of their competitors may enjoy advantages during the bid process. Conversely, firms unable to readily demonstrate their CMMC 2.0 compliance may be prohibited from bidding altogether. Continuous monitoring and risk assessment is essential to identify and mitigate potential cyber threats. Stay up to date with the latest CMMC developments and ensure your organization is prepared for any changes in requirements or timelines.

To learn more about how Qmulos can help you and your organization, contact us today.

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