Security is on everyone's mind, what with the upcoming Q2 CMMC compliance requirements for businesses working with the government about to drop. However, the world's digital landscape is already facing a significant threat as machine learning (ML) continues to empower malicious actors to be more brazen. So much so that Investopedia reports AI-driven phishing and deep-fake fraud are currently the two biggest security threats that security systems face.

So, how do you comply with the federal government's requirements and safeguard any controlled unclassified information (CUI) you use?

Below, we offer a comprehensive CMMC compliance checklist designed to ensure that you can:

Meet the DoD's CMMC requirements
Avoid making the process more complicated
Discover how ML systems can help with cybersecurity
Reduce costs without compromising security
Maintain your reputation for security

So, read on to learn your next steps in fulfilling the CMMC certification process.

1. Determine Your Required CMMC Level

First, you must familiarize yourself with CMMC's various maturity levels. These address progressively more advanced cybersecurity needs, aligning the protection needed with the sensitivity of the data you need to manage.

You should also identify whether your contract requires safeguarding federal contact information (FCI) or the aforementioned CUI. If they do, this will more clearly define your CMMC needs.

If using FCI, you must use more basic cybersecurity practices defined by FAR 52.204-21. These are by no means insecure, but the requirements are lower.

However, using CUI data means you must comply with more stringent requirements. NIST SP 800-171's list of clearly defined security controls to ensure the data's confidentiality while maintaining its availability.

2. Identify and Categorize CUI Data

Once you know you are handling CUI data, you should use the National Archives CUI registry to identify data types specific to your internal needs and complete a risk assessment of handling and storing them. Review your existing workflows to ensure you continually account for sensitive data, and work to mitigate the risks involved in these processes by:

Encrypting the data when it sits or moves
Monitoring and auditing access to the data
Implementing machine-learning-based security and threat detection
Incorporating secure storage protocols into your processes

3. Review the 110 Security Controls in NIST SP 800-171

As a part of your CUI data security checks, you should work with your security departments to review the list of security controls. Update your internal policies to exceed or meet these requirements, focusing on areas such as:

Access control
Incident response
Configuration management
Compliance weaknesses
Internal security

As there has been an average of a 28% increase in insider-driven data breaches since 2021 (according to CSO Online) you should ensure you focus on both internal and external threats. Enact methods of detecting malicious internal access, using machine learning to follow the access habits of your team and watch for any unexpected patterns that may suggest problematic behavior. Then, shore up as many of these areas as possible and respond to internal problems on a case-by-case basis, recording the incidents for transparency and showing a culture of improvement.

4. Conduct a Cybersecurity Gap Analysis

Evaluate your current cybersecurity framework and the policies you have in place to determine if there are locations where you could improve your cybersecurity maturity. To help with this:

Leverage automation to streamline security processes
Analyze potential system vulnerabilities using machine learning
Test your team to learn if training is necessary
Compare your current security to the requirements of the CMMC
Take direct action to close the security gap

Compile any findings into a report you can move forward with, turning any setbacks in the gap analysis into a report presenting how serious you are about meeting CMMC security requirements.

5. Develop a System Security Plan (SSP)

Once you have completed all preparatory steps, create a clear SSP outlining how your organization already meets CMMC requirements. This document will act as a critical tool both when you apply for certification and during audits.

You will want to include information on all components in your system, including:

Systems
Personnel
Processes
Hardware and software inventories
Network components
Security controls used to protect CUI

Leverage graphics such as diagrams and flowcharts to make it easy to understand how you manage and protect CUI. Doing this will reduce the number of questions a third-party auditor will ask, speeding up your CMMC process.

6. Secure Stored and Transmitted Data

Use AES-256 encryption for both data at rest and in transit, implementing TLS protocols for secure communication over any network. You should also encrypt your backup data and ensure your recovery process adheres to the same encryption standards to prevent a malicious actor from accessing data through a restoration process.

Also, make sure to regularly update and audit your encryption methods to address emerging threats that may overcome your methods.

Available Cybersecurity Tools

You should leverage the best tools available to monitor and control both incoming and outgoing network traffic, including:

Machine learning-powered firewalls to continually improve security
Intrusion detection and prevention systems to automatically block unauthorized access
Role-based access controls (RBAC) to limit access based on responsibilities
Using automated systems to revoke access to terminated or suspended employees
Leveraging access logs to detect and respond to unusual activity

Also, audit them over time and document every clear benefit they offer you.

7. Leverage Secure Cloud Enclaves

If you use cloud storage, it is essential to note that it is not inherently more secure than other environments. TechNewsWorld even recently reported that 40% of the files checked on Google Drive contained personally identifiable information (PII), putting businesses at risk of data breaches. As such, make sure you go the extra mile to prevent data from leaving a controlled environment, such as by using a secure cloud enclave, and ensure a higher level of security for any data you use.

Select enclaves that meet or exceed the regulations you need to follow, whether that means FAR 52.204-21, NIST SP 800-171, or another standard. As such, evaluate cloud service vendors based on their ability to:

Secure CUI
Seamlessly integrate with your existing systems
Encrypt data
Control and monitor access
Scale as your business grows

Also, train your IT staff to manage and monitor the areas of the cloud system they have responsibility for to ensure clear authority and responsibility.

8. Regularly Review Your RBAC and MFA Policies

Create detailed role definitions that outline precisely who can access specific data types and when. Over time, audit these to reduce the amount of CUI data anyone can access.

Enforce the "least privilege" principle, offering only a minimum level of access to allow someone to perform their role. This step makes it harder for malicious actors to access data they could use to cause harm. At the same time, allowing access to the data someone needs to complete their role avoids issues regarding hindered performance or bottlenecks.

Users should also require multi-factor authentication (MFA) before handling CUI to ensure the right person accesses the data. This requirement should also be mandatory for the following:

Remote access
Admin roles
Access to critical systems
Requests for additional access

If someone fails to pass MFA, flag it on the system and ensure that you follow up with the user so you can check whether they intended to attempt a login. Then, much like with other security systems, regularly test and update these to prevent malign actors from bypassing them using older methods.

9. Implement Employee Training Focused on Cybersecurity Practices

Employees are often the first line of defense against cybersecurity threats. Conversely, they are also one of the most common areas of security failure due to human error. Cybersecurity training can thus ensure they understand how to resolve issues such as:

Secure data handling
Incident reporting
Possible phishing attempts
Department-specific risks
CMMC standards and compliance
Secure cloud enclave operations
What counts as CUI
Audit requirements

You should also provide resources to allow employees to review CMMC practices and requirements independently, allowing them to ensure they keep their systems up-to-date at all times.

10. Monitor Systems Continuously Using AI Tools

With ongoing monitoring, you can take proactive steps to detect and respond to cybersecurity threats as they appear. While (in theory) human action could perform a similar role, it would not be able to work to the same level as an always-on, AI-based cybersecurity tool. For example:

Machine learning algorithms can identify anomalous behavior and flag it
AI intrusion detection systems can monitor network traffic and update settings in response to system threats
Use AI to continually track compliance with CMMC controls and highlight areas to respond to
Analyze historical security data and look for trends that indicate potential vulnerabilities
Automatically prioritize resource allocation to address areas of greatest risk

With such a tool, it will be much easier to follow and adhere to the requirements of CMMC controls.

Beyond the CMMC Compliance Checklist

Using everything from CUI protection, training, and AI-driven system monitoring, you can better comply with the DoD's updated 2025 cybersecurity requirements. However, the above CMMC compliance checklist is only the start of the process.

If you want further assistance, Hermathena Labs can offer you pre-configured and secure cloud enclaves that we tailor specifically to meet your compliance needs. So, save time and resources and ensure your cybersecurity stays top-notch. Contact us today to book a demo and learn more about what we can do for you.

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