Adam Kangiser, Iviry’s Compliance Analyst

The Department of Defense’s Cybersecurity Maturity Model Certification (CMMC) has undergone significant changes with the introduction of CMMC 2.0, which aims to strengthen the cybersecurity posture of defense contractors. A key aspect of this new model is the shift to allow some lower-tier contractors to self-attest to compliance with Level 2 requirements, rather than undergoing third-party assessments. While this may seem like a simplified approach, it raises serious concerns about the integrity and security of the entire supply chain.

The Risk of Self-Attestation

CMMC was originally designed to ensure that every contractor, no matter how small, adheres to cybersecurity best practices. In theory, self-attestation seems convenient, allowing contractors to certify their own compliance without the cost and time associated with third-party audits. However, the reality is that this model exposes organizations to significant risks.

Self-attestation relies heavily on the contractor’s internal understanding and enforcement of security measures, but not all contractors have the expertise or resources to fully implement or maintain proper cybersecurity controls. Without an external audit to verify compliance, there’s no guarantee that the contractor is meeting the necessary standards. This can create vulnerabilities that jeopardize not only the contractor but also the prime contractors and the broader supply chain.

A Wake-Up Call for the Defense Supply Chain

In the face of increasing cyber threats, such as the 2020 SolarWinds supply chain attack, where attackers compromised thousands of organizations, including U.S.

government agencies, the risk of vulnerabilities in the supply chain cannot be ignored. These attacks demonstrate the catastrophic consequences of overlooking weak links within the supply chain. If lower-tier contractors are allowed to self-attest to compliance without third-party verification, there’s a greater chance that critical weaknesses will go unnoticed until it’s too late.

Iviry understands the need for robust, third-party assessments. As an MSP/MSSP partner, we help defense contractors navigate the complexities of CMMC compliance, ensuring not only that they meet the necessary requirements but also that their cybersecurity frameworks are fully functional and resilient.

How Iviry Can Help Mitigate the Risks

At Iviry, we believe that compliance is more than just ticking boxes. We take a comprehensive approach to CMMC compliance, focusing on continuous monitoring and proactive management. Here’s how we help our clients safeguard their systems:

  1. Gap Analysis: We conduct thorough assessments to identify areas of vulnerability and non-compliance before they become problems.
  2. Remediation Support: Our team assists in implementing necessary cybersecurity measures and ensures that controls align with CMMC requirements.
  3. Sustainment: Compliance doesn’t end with a certification. We provide continuous monitoring to maintain a secure environment and ensure that our clients stay up-to-date with evolving standards.

By working with Iviry, defense contractors can avoid the risks associated with self-attestation, ensuring that their cybersecurity frameworks compliant and their business remains secure.

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