When is CUI not CUI?

Imagine the following scenario: As part of Project Road Runner, a new initiative, the United States Army, a portion of the Department of Defense (“DoD”) wants to purchase three dozen anvils. The anvils must meet specific size, strength, and weight requirements. DoD has already performed a search and is not able to find a COTS (more…)

CMMC 2.0 Model and Scoping Guide Now Available

The US Department of Defense updated their main website (OUSD A&S – Cybersecurity Maturity Model Certification (CMMC) (osd.mil)) to include an updated CMMC Model consistent with the information released on Nov. 4 about CMMC 2.0. They also released scoping guidance for CMMC 2.0 Levels 1 and 2, and a hashing approach for preserving evidence. Among (more…)

On NIST SP 800-171, NFO Controls and Polices, Procedures, and Plans

With CMMC 2.0, DoD removed process maturity as an assessed requirement. Some commentators are suggesting that NIST 800-171’s “NFO” controls inherently require policies. We explore the requirement in this article.

Analysis of CMMC 2.0

Former CMMC-AB board of directors James Goepel, Mark Berman, and Ben Tchoubineh authored a letter to the President which analyzes why CMMC 2.0 is inconsistent with the President’s recent Executive Order and is harmful to our national security.