Everything Defense Contractors Need to Know About CMMC 2.0

CMMC
CMMC

On November 4th, the Department of Defense (DoD) announced major revisions to the Cybersecurity Maturity Model Certification (CMMC). Since it first entered federal law in December of 2020, the CMMC has only undergone minor revisions, bringing it to version 1.02. Now the framework will jump ahead to version 2.0, with a streamlined system of security levels, introduction of a waiver process, and changes to the framework core.

While full details of the CMMC 2.0 update are still forthcoming, DoD officials have indicated that the update is intended to address longstanding concerns in the defense contracting community, especially among small-to-medium sized businesses (SMBs). Most significantly, the requirement for third-party assessment will be dropped for more than half of the defense industrial base, substantially reducing the compliance burden for many organizations.

While the new CMMC requirements will not show up on contracts for at least nine months, contractors who have been preparing for CMMC compliance will need that time to change their strategy and prepare for the new rule changes. In this article, we’ll explain what these rule changes are, and what they entail for your business.

New Direction for CMMC

Since it was first announced in 2019, the CMMC has provided a model for government agencies seeking to enforce better standards of cybersecurity compliance on their supply chain partners. After a historic year for cyberattacks that illustrates critical vulnerabilities among federal agencies and contractors, this goal has never been more important.

But – in the words of Deputy Assistant Secretary of Defense (DASD) for Industrial Policy, Jesse Salazar – the DoD has struggled to find a balance between “adopting the practices they need to thwart cyber threats” and “minimizing barriers to compliance”. Accordingly, lawmakers and industry leaders have expressed concerns that CMMC requirements are too onerous or costly for some defense contractors.

In its recent announcements, the DoD has signaled a new direction for CMMC that addresses these concerns: CMMC 2.0 will provide greater flexibility to small businesses in the defense contracting industry with less reliance on third-party assessment, and a more streamlined core framework.

CMMC 2.0 vs CMMC 1.02

As of November 29th 2021, the CMMC 2.0 framework is not publicly available, and while rules are expected to be made public in the near future – followed by a 60-day period for public comment – the rulemaking process may be extended through Fall of 2023.

Fortunately, the DoD has made some details available, primarily through the Office of the Under Secretary of Defense for Acquisition and Sustainment (OUSD A&S) website, and through a notice issued on the 17th. With these sources in mind, here are some major differences between CMMC 2.0 and 1.02:

Streamlined Level System

Under CMMC 1.02, defense contractors were evaluated under five levels of security, ranging from “Basic,” “Intermediate” and “Good” cyber hygiene at levels 1-3, to an “Advanced” security program at Level 5. CMMC 2.0 eliminates levels two and four, leaving only three levels that roughly correspond to the original Level 1, Level 3 and Level 5.

  1. Level 1 “Foundational” – like the original Level 1, this level will include 17 “basic” security controls derived from Federal Acquisition Regulation (FAR) rules 52.204-21
  2. Level 2 “Advanced” – like the original Level 3, this level will include the 110 controls in National Institute of Standards and Technology (NIST) special publication (SP) 800-171. However, 20 additional rules have been eliminated, leaving only NIST-derived security controls.
  3. Level 3 “Expert” – little was known about the additional cybersecurity controls at the original Level 5. The picture is more straightforward for Level 3 under CMMC 2.0: in addition to the controls from NIST SP 800-171, organizations will be required to follow a subset of controls derived from NIST SP 800-172.

Ultimately, any “CMMC unique security practices” appear to have been eliminated from CMMC 2.0, directly mapping the core framework to existing FAR and NIST legislation alone. Furthermore, organizations will no longer be evaluated for “Process Maturity” or “Institutionalization” as they were under previous versions of CMMC.

Reduction of Third-Party Assessment

Under CMMC 1.02, all defense contractors were required to undergo assessment by a third-party assessment organization (C3PAO) once every three years, whether or not they stored controlled unclassified information (CUI) considered critical to national security. Under CMMC 2.0, this requirement has changed substantially.

Of the roughly 220,000 companies in the defense industrial base, 140,000 will fall under Level 1 of CMMC 2.0, meaning they will only be required to undergo self-assessment once per year with the oversight of a senior level executive. The same will go for companies at Level 2 who do not hold “critical” CUI – or about half of them.

At Level 3, companies will be required to undergo a triennial governmental assessment, although details are not yet available. This leaves about 40,000 companies at Level 2 who will still have to undergo third-party assessment once every three years.

Expanded Exceptions and Leniencies

Under CMMC 1.02, the conditions for contract award were straightforward: companies needed to be compliant, or lose eligibility. Under CMMC 2.0, the DoD will be more lenient, awarding contracts to some organizations without CMMC implementation, provided they submit a Plan of Action and Milestones (POA&M) and agree to abide by a hard deadline.

CMMC 2.0 will also introduce a limited waiver process which would allow organizations to forego some CMMC requirements under special circumstances. While these allowances would likely not apply to mission-critical security controls, many details of the process and its scope have not been clarified yet. Even so, a waiver process represents a radical departure from CMMC 1.02.

Preparing for CMMC 2.0

In some ways, CMMC 2.0 maintains substantial continuity with existing security legislation and compliance processes. In other ways, it is a major step forward, holding defense contractors to a high standard of accountability and cyber-readiness. While many questions about the updated program remain unanswered, it is not too early to start preparing with a few simple steps:

  1. Install C-Level officers to approve annual assessments – many organizations are familiar with the current self-certification process for NIST SP 800-171. Under CMMC 2.0, much of this process will remain the same, but organizations under Level 1 and Level 2 who are not storing prioritized CUI will need an executive level officer to sign off on the self-assessment.
  2. Take advantage of DoD resources – with the new direction of CMMC 2.0, the DoD has committed to helping its partners in any way it can, with resources like Project Spectrum, providing organizations with free educational materials and a cyber readiness check.
  3. Get a readiness assessment – since it is based on existing NIST regulations, it’s possible to start preparing your organization for compliance with CMMC 2.0 right now. A professional readiness assessment will reveal gaps in your systems and networks, establishing a roadmap for CMMC 2.0 compliance individualized to your organization.

Based on our years of experiencing conducting assessments for compliance with NIST standards that form the basis of CMMC 2.0, Securicon can perform readiness assessments and mock audits to help your organization prepare for the real thing. With a DoD background, our world-class experts are ready to take stock of your IT assets and build a security response plan that is tailored to your organization’s needs. Contact us to learn more.

The IoT Security Problem in 2020: Taking a Deeper Look

Risk assessments, iot security
Risk assessments, iot security

In 2017, an unnamed casino found that its data servers had been compromised and called on the aid of a security firm to help them find the culprit. Shortly afterwards, the surprising results of this investigation were reported far and wide: like the plot of an ill-conceived James Bond story, hackers had entered the casino’s network through an Internet-connected thermostat in a decorative aquarium. Today’s organizations have a lot more to worry about than the old fish tank trick: this year, experts estimate that the number of devices connected to the Internet will reach 30.1 billion, setting a world record that will continue to climb for years to come. In our time, connected refrigerators, printers, TVs, and smart meters will provide points-of-entry for hackers with increasing frequency. In the past, we’ve written about the security problems plaguing the current generation of IoT devices: just two years ago, researchers at the Black Hat and DEFCON security conferences showed just how bad the problem is by hacking dozens of devices in unique and novel ways. This begs the question: how did we get here? Why is IoT so difficult to secure, and what can organizations do about it?

Why IoT is A Supply-Side Problem

To explain the IoT security problem, we have told ourselves a plausible story sometimes repeated on our website: IoT is an inherent security risk, because increasing the number of Internet-connected devices in an organization also expands the attack surface available to malicious actors. But – while there is truth to this story – it does not explain the sheer number of easily prevented security issues in business grade IoT. According to the Ponemon Institute, 51% of organizations acquire IoT products through a third party; meanwhile, 48% of organizations have been subject to at least one IoT attack, and that number is rising. As we will see, these two facts are not unrelated.

Manufacturing in the 21st Century

The way that technical products are developed today – especially technology based products – has evolved from a pure engineering perspective to a model based more on component-integration. Rather than manufacture a new TCP/IP network card for your new product, for instance, it’s quicker and less expensive to integrate one already produced by a third-party vendor. On the positive side, this means that your product can reach the marketplace quicker, or in manufacturing speak, “reduced time to market”. On the negative side, the same components may end up in hundreds of products from a variety of manufacturers, and – if one such component has a security flaw – it may end up in all those products at the same time.  This phenomenon is well-attested by the current state of IoT.

What This Means for Security

With a lack of industry regulations that encourage high security standards for IoT products, the incentive for vendors to make a quick profit by cutting corners can drive sloppy development, a lack of vulnerability testing and quality control issues galore. The IoT market is in its “wild west” phase, as the PC market was three decades ago, and organizations must be wary who they work with. The following tactics are some of the most common ways we find IoT vendors punting the responsibility for secure design from themselves to their customers:

  1. Quick Turnaround

The term “Internet of Things” has been around since the 1990s, and the basic premise has never changed: it promises to automate basic tasks, from turning on the lights in your home to adjusting the window shades in a conference room based on the level of ambient sunlight to measuring the temperature gradient over a pipeline in a refinery. At its most basic, IoT is simply the implementation of connected technology to solve a problem. But in order to drive IoT adoption, products must have a reasonable price-point. Consumers won’t pay excessive amounts of money to automate tasks they can easily do by themselves. Manufacturing costs have to be kept low enough that the final products will sell, and this is why manufacturers generally choose to integrate cheap and readily available components.

  1. No Vulnerability Testing

Vendors are not immune to the lack of security awareness which impacts their customers. While it may be in their best, long-term interest to offer products with a high bar for security, it’s all-too-easy for vendors to skip a comprehensive vulnerability testing phase, opting instead to run down a checklist of features, if even that. Many companies lack the capabilities to test their products for security issues in the first place, and without regulations forcing them to do so, they simply won’t bother.

  1. Convenience at the Cost of Risk

When it comes to ease-of-access, what benefits IoT customers also benefits hackers. For the sake of convenience, vendors make design choices that exacerbate the vulnerability of their products: web interfaces, for instance, are the biggest target of IoT attacks – even those behind a network address translation (NAT) firewall can be compromised. Likewise, the omission of two-factor authentication (2FA) and forced credential updates is a decision driven by form over function, when both features could thwart a huge number of IoT attacks. Rather than go to the trouble of building a dedicated customer support channel, vendors have even been known to add easily exploitable backdoors into a device’s firmware.

  1. Poor Firmware

Speaking of backdoors in IoT firmware, the design of firmware is a major contributing factor to IoT security issues: few vendors will dedicate the time it takes to work out all the kinks before release; debugging systems used in the staging system of a device are often left in, allowing hackers to dump a huge amount of useful information. Lack of testing may leave firmware vulnerable to buffer overflow, and the use of open-source platforms leaves a completely unprotected attack surface exposed to attackers. The best vendors update their firmware on a regular basis to patch for newly discovered vulnerabilities, but this is a rarity.

  1. API Flaws and External Threats

From the outside, IoT integration with third-party apps through an application programming interface (API) seems like a great idea, but API flaws left by vendors open the doorway to attacks from malicious code hidden within seemingly innocuous applications. Researchers have also proven the possibility of DNS-rebinding attacks on IoT through a website, infected link, advertisement or malicious redirect. In the future, organizations may have to worry that their network will be infected every time their employees browse the Internet.

How to Avoid Bad Vendors

The IoT security gap remains one of the greatest threats to security across federal agencies. In response, legislators have discussed the idea of enforcing IoT regulations for some time, and NIST has produced IR 8259, a draft of recommendations for IoT manufacturers. But until that happens, irresponsible IoT vendors will persist, and organizations must practice due diligence to protect themselves. Here’s how to do that:

  1. Take inventory of the IoT products throughout your organization, alongside any devices connected to the Internet (organizations should be keeping inventory of all their IT assets as part of a comprehensive security strategy).
  2. Conduct a vulnerability assessment to discover the devices that constitute a real threat to your organization, and remediate the issue. This will also give you an idea which vendors to avoid moving forward.
  3. Be careful who you do business with: vet your vendors during the product acquisition phase (industry reputation, quality control, customer testimonials and quality of business). Show an equal amount of caution when expanding the capabilities of IoT devices through third-party software vendors.

Prepare for the Future

While they have never been more serious than they are today, the risks of IoT and principles of supply chain security have been understood for over a decade. But sadly, it’s difficult to apply them, especially when the component integration strategy of many product developers depends on technology sourced from countries that are hostile to the U.S. The Department of Defense (DoD) believes that foreign espionage through IoT products purchased by government agencies in America will be a major issue in the near future, and soon it will require all DoD-partners to follow the policy and procedural controls in NIST 800-178 and to comply with the Cybersecurity Maturity Model Certification (CMMC). Until that happens, government contractors would do well to proactively adopt compliant security strategies, fortify their networks, and analyze their own IoT assets for vulnerabilities. The right time to beat hackers is before they strike.


Securicon Can Help

Securicon offers comprehensive IoT security and compliance solutions to organizations. Our services include penetration testing and social engineering assessments which are trusted by critical infrastructure companies across the U.S and other critical organizations to find vulnerabilities and maximize safety. In 2020, there’s no room to be lax about security – contact us today!

 

5 NIST Updates That Will Impact Security Professionals in 2020

NIST Updates, ics warning
NIST Updates, ics warning

It’s fair to say regulations from the National Institute of Standards and Technology (NIST) are a cornerstone to the security of our federal government: NIST documents set the standard for business operations in both the public and private sector, ranging from information security controls (SP 800-53) to cybersecurity practices (CSF). As time goes by, these documents are frequently updated, and keeping track of them can be difficult.

As we mentioned in a recent article, technology has a tendency to change faster than policy can keep up – but that doesn’t mean NIST won’t try. Every year, the agency works diligently to keep its standards current, seeking the advice of industry professionals to produce new documents ahead of future trends. With a new decade ahead of us, NIST is already hard at work, announcing new standards for IoT, privacy and much more.

To ensure your organization is prepared for the next generation of risk and compliance, keeping up with NIST’s activity is vitally important. Our staff is among the industry organizations that advise NIST, in this article, we’ll share five of the biggest updates to recently come from the nation’s foremost authority on Federal and commercial enterprise technology.

1. CMMC to Supplant SP 800-53 for DoD Contractors

The Cybersecurity Maturity Model Certification (CMMC) is by the far the biggest change to policy impacting federal partners in 2020. Although for now it mainly applies to contractors working with the DoD, that may change with time, and organizations should prepare before it goes into effect later this year.

CMMC has three major goals:

  • Consolidate – and therefore supersede – multiple cybersecurity standards, including NIST documents SP 800-53 and SP 800-171, and several international standards like ISO 27001
  • Prevent organizations from winning a contract until they can demonstrate cybersecurity preparedness
  • Gauge the maturity of a company’s cybersecurity practices and processes, as they have been institutionalized

With five gradually escalating certification tiers, in some ways the CMMC will ease the burden of compliance for federal contractors. In other ways, it will raise the bar for what it means to be “compliant,” forcing organizations to take responsibility for risk and adopt a mindset of cybersecurity across its departments. As a military contractor ourselves, we too are adapting to comply.

2. Draft for IoT Standards

The IoT security gap remains one of the greatest threats to security across federal agencies. Thanks to a lack of security controls from IoT vendors – and a lack of awareness from organizations – most IoT devices suffer from multiple vulnerabilities that can be used for espionage, data theft and much more.

In response, NIST has released a draft of IR 8259, titled Recommendations for IoT Device Manufacturers: Foundational Activities and Core Device Cybersecurity Capability Baseline. The document contains policies focused on bringing IoT vendors in line with the security needs of their customers with controls like data protection, authorized software updates, End-of-Life policies and – most importantly – secure firmware designed to prevent unauthorized device access.

While compliance with IR 8259 is completely voluntary for the time being, a proposal to put NIST in charge of IoT standards remains before the House of Representatives, and may be passed at any time.

3. Privacy Framework

Federal contractors handle a lot of sensitive information, ranging from the personal data of their employees, customers and clients to levels of classified information from government agencies. As emerging data privacy laws seek to mitigate the risk of data incidents across public organizations, NIST is doing its part to prevent them in a federal context with the Privacy Framework (PF).

While the PF is only 39 pages long, it is jam-packed with advice and procedures to defend data security from threats both inside and outside of an organization. Divided into five basic sections, it is also aimed at helping organizations stay prepared for technology advancements and new data use cases:

  • Identify risk to individuals
  • Govern risk management priorities
  • Control privacy risks at a granular level
  • Communicate with stakeholders
  • Protect data from “privacy events”

Version 1.0 of the PF was released at the end of last month, after being available for public comment since September of last year. It has already been adopted by organizations outside the government and should gain wider adoption in the coming months.

4. Supply Chain Risk Management Updates

Released in 2015, SP 800-161 has existed to mitigate risks in the information and communications technology (ICT) supply chain throughout federal organizations. Now, NIST seeks to update Supply Chain Risk Management Practices for Federal Information Systems and Organizations for a new decade, following changes in federal law regarding the acquisition of ICT products in 2019, especially from foreign vendors.

In its pre-draft call for comments, NIST stated its goal to “deliver a single set of cyber supply chain risk management practices to help Federal departments and agencies manage the risks associated with the acquisition and use of IT/operational technology products and services in a way that is functional and usable.”

The ICT supply chain can introduce risk to organizations through poor design, lack of security controls and even backdoors for espionage. Since changes to SP 800-161 will be accompanied by updates to NIST SP 800-37, and SP 800-53, all federal contractors will be affected, and they should stay informed as new information becomes available.

5. Standardization of Cybersecurity Regulations

Ever feel like there are just too many security regulations to keep up with? NIST agrees: in a draft report for the National Cybersecurity Online Informative References (OLIR) Program, it states “the fields of cybersecurity, privacy, and workforce have a large number of documents, such as standards, guidance, and regulations”.

Through the OLIR, NIST aims to simplify compliance procedures through a centralized online repository of cybersecurity legislation complete with cross-references between documents, and advice from subject matter experts. Depending on the extent of the OLIR, it could change the workflow of security professionals throughout the industry and make the adoption of new standards much easier.

NIST accepted public comments on its first draft until February 24th, but we don’t know how long it will be until OLIR goes into effect, but it’s safe to assume something will be up and running by the end of this year.

Taking Responsibility

Every new update from NIST points to developing trends in technology and legislation. While keeping up with them can be difficult, the best way to stay ahead of regulations is to stay on top of risk.

Don’t stop at checking off boxes: in 2020, organizations who take responsibility for their business processes, IT infrastructure and insider threats will be the most likely to succeed on the road to full compliance.


Take stock of your IT assets and fix vulnerabilities before NIST tells you to: with a DoD background, our world-class experts in governance, pen testing and ethical hacking can help through technical consulting and federal security services. Contact us today!

Why Crowd-sourced Pentesting Isn’t All it’s Cracked Up to Be

pentesting, Risk Requests, risk management framework
pentesting, Risk Requests, risk management framework

Crowds have always been a powerful thing, but before the Internet came along, it was difficult to harness them. Now things have changed: almost anything can be powered by crowds these days, from funding initiatives to news coverage, research and more. But is crowd-sourcing the right approach to penetration tests? Some people think so.

According to a report by Bugcrowd, there are literally thousands of crowd-sourced security programs today, attracting clients that range in size from small businesses to publicly traded enterprises like Motorola Mobility. And while these programs offer a number of services, the most popular one is “penetration testing” – or at least, something which goes by that name.

The fact is, crowd-sourced penetration testing isn’t like the non-crowd-sourced version at all. And while there are advantages to each approach, there are also good reasons to choose the latter over the former. To understand why, we have to start by explaining the differences between them.

Crowd-sourced vs. Traditional Pentesting

The goal of a penetration test (or pentest) is to find, document and score vulnerabilities in an information system before they are used by hackers or other malicious agents to gain unauthorized access. To do this, a pentester approaches a system just like a hacker would, from conducting reconnaissance to attempting simulated “attacks” that confirm whether a detected vulnerability is really exploitable.

Traditionally, an organization defines the goal of a pentest and hires a team of security professionals to conduct it over a limited period of time. During a crowd-sourced pentest, an organization offers a bounty to anyone who can discover a vulnerability on their systems, often through an agency with access to thousands of white-hat hackers who may or may not be professionals.

There are some advantages to the crowd-sourced model:

  • Timeframe – crowd-sourced pentests take place over an undefined timeframe and may carry on indefinitely. This allows new vulnerabilities to be discovered as an organization continues to develop and improve its systems.
  • Cost – a crowd-sourced pentest istypically cheaper than the traditional kind, since organizations are paying for each discovered vulnerability rather than for the test itself.

In many ways, crowd-sourced pentesting is similar to the bug bounty programs that companies have used for years to find flaws in their online platforms – and, in fact, many startups in the security industry started out as bug bounty agencies. But what works well in one context may not work well in another, and that brings us to the problems in the crowd-sourced model.

The Dangers of Crowd-sourced Pentesting

Crowd-sourced pentesting – no matter how it’s advertised – is the organized practice of inviting real hackers to hack your company and helping them to get started. Because websites are public-facing assets, offering a bug bounty does not expose them to any vulnerabilities they didn’t face before. Meanwhile, crowd-sourced pentesting requires organizations to actually connect internal systems with public channels, potentially exposing sensitive data and intellectual property to a group of individuals who suffer from:

  • A lack of ethical obligations – traditional pentesters are held to a high ethical standard because their careers depend on it. They cannot hide from suspicion or blame when something goes wrong. Meanwhile, crowd-sourced hackers are often anonymous to their clients, and – while they may be required to sign a contract – in practice nothing can stop them from hiding their discoveries, or using what they find in a malicious way.
  • A lack of professionalism – since crowd-sourced pentesting agencies require a large volume of talent, the quality and experience of the “hackers” they contract is wildly inconsistent. Moreover, today’s hackers often work in groups, and that’s why traditional pentesters do likewise; crowd-sourced pentesters may be lone-wolves that compete with one another for profit, generating conflict when two individuals find one vulnerability at the same time.
  • A lack of focus – when an organization defines a pentest engagement they typically have a clear view of what they want to address in the test and have defined rules-of-engagement.  The crowd-sourced approach tends to lack that focus and the results may be very inconsistent with the organization’s objectives.

In short, crowd-sourced pentesting removes the vital element of control that organizations normally exercise over their security operations. For this reason, companies who do invest in crowd-sourced programs – including Google, Mozilla and Facebook – also retain traditional pentesters to protect their most vital internal systems, and only use crowds where the danger does not outweigh the cost savings.

Why Crowd-sourcing is Really Popular

Aside from the low cost and flexibility that it provides, crowd-sourced pentesting is gaining in popularity due to a perception that professional pentesters aren’t “real hackers”. It is an understandable assumption: as time goes by, pentesting as a field has become dominated by automation which simply cannot rise to the human capacity for creativity and disruption.

We’re not here to deconstruct the term “real hacker” or call it a meaningless construct, because it’s not.

Hackers are not predictable. Unlike security professionals in many other fields, they do not take a linear or hierarchical view of information systems. They do not work from a CVE list, manual or rule book. Therefore, hiring a company that claims to provide “real hackers” might seem like a good solution. But real hackers are also as likely to be found working as traditional pentesters as they are anywhere else.

A Better Solution

The best hackers in the world know how to use their talents to make a sustained and comfortable living. They neither spend their days running from the law, nor do they troll the web looking for quick profit or glory. The best hackers are genuinely invisible, hiding in the very places where many assume they can’t be found.

At Securicon, we take pride in our exclusive team of bright-minded hackers from commercial, DoD and federal security backgrounds. We turn down 90% of applicants, because our pentesting program is reserved for the best and brightest in the business. We only accept talents with the right mindset for this unique occupation: they can find windows of opportunity where scanners and lesser minds see a blank wall.

The Bottom Line

At best, crowd-sourced pentesting works in a limited range of scenarios. It can help to secure production systems and other addresses that are not directly linked with your organization. However, it’s far from the best way to find vulnerabilities in your vital assets: trained penetration testers are hackers who have the intelligence, experience and creativity that it takes to find problems by working together, and the ethics to report them responsibly.


Securicon’s risk management solutions are based on industry standards for safety and professionalism. With years of experience in cybersecurity, we are here to help you manage the risks for Industrial Control Systems. Contact us for more information.