Does your organization have a methodical way to manage IT assets in your (Controlled Unclassified Information) CUI environment? Failing to properly implement the asset management controls below can expose an organization to several risks:

  • Unauthorized Access and Transactions: Without proper controls, there is a higher likelihood of unauthorized transactions, insider threats, and lack of accountability. This can lead to potential fraud and data breaches.
  • Data Leakage: Inadequate media marking can result in mishandling or inappropriate distribution of sensitive information, increasing the risk of data leakage.
  • Non-Compliance: Organizations may face regulatory penalties and loss of contracts if they fail to comply with CMMC 2.0 requirements.
  • Compromised Data Security: Insufficient control over media containing CUI can lead to unauthorized access, especially during transport, resulting in data breaches and compromised confidentiality.
  • Financial and Reputational Damage: Security incidents can lead to significant financial losses and damage to the organization’s reputation.

The CMMC 2.0 framework is designed to protect sensitive unclassified information shared between the Department of Defense (DoD), its contractors, and subcontractors. Ensuring compliance with CMMC is crucial for maintaining cybersecurity within the defense industrial base. Asset management controls can be found in the Access Control (AC) and Media Protection (MP) families.

AC.L1-3.1.20 requires organizations to implement transaction control techniques (e.g., separation of duties) to prevent unauthorized transactions or operations. Proper implementation of this control includes the following components:

  1. Segregation of Duties (SoD): Divide critical tasks among different employees.
  2. Access Reviews: Regularly audit and review user access rights.
  3. Multi-factor Authentication (MFA): Implement MFA for all sensitive system access.

MP.L1-3.8.3 requires that media is marked with necessary distribution limitations, handling caveats, and applicable security markings. Suggested administrative and procedural controls include the following:

  1. Labeling System: Develop a consistent labeling system for all media.
  2. Training: Regularly train employees on proper media marking procedures.
  3. Automated Tools: Use tools like data loss prevention (DLP) software for consistent tagging.

MP.L2-3.8.4 states that organizations must control access to media containing CUI and maintain accountability for media during transport outside controlled areas. In order to satisfy this control, organizations must follow the following requirements:

  1. Media Inventory: Maintain an up-to-date inventory of all media containing CUI.
  2. Media Encryption: Encrypt CUI on media to protect it during transport.
  3. Secure Transport Procedures: Use secure methods and tracking mechanisms for transporting media.

MP.L2-3.8.5 amplifies MP.L2-3.8.4 by defining what cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport are acceptable. These include:

  1. Encryption Standards: Use strong encryption standards like AES-256.
  2. Key Management: Implement robust key management practices.
  3. Regular Audits: Conduct regular audits to ensure encryption mechanisms are effective.

Proper implementation of these controls will ensure that your organization controls each of its CUI assets. Ultimately helping to ensure data security, regulatory compliance, and protection against unauthorized access and data breaches. Investing in cybersecurity infrastructure today is not just about securing your role in the DoD supply chain. It’s about enhancing resilience against cyber threats. By prioritizing CMMC compliance, you’re not just safeguarding your organization’s future – you’re showcasing a genuine commitment to cybersecurity excellence.

For assistance with your CMMC efforts, contact DTC’s C3PAO team.