Call us now:
One cannot underestimate the degree of change that has been proposed by the U.S Executive Office through the March release of its ONCD cyber strategy and the subsequent implementation plan (July 2023) Ted Dziekanowski. The implementation plan pulls together many aspects of what one has been saying over the past 18 months. Namely that change requires a strong framework of accountability and responsibility, aligned to legislative powers and enforcement regimes.
One believes the drive for cybersecuirty is stronger today than it has historically been. As those with the accountability and responsibility to make change, are starting to understand the effects of cybersecurity on national and economic security.
The implementation plan aligns with several aspects of EU cyber regulation such as NIS 2 and the CRA. It clearly seeks to align cybersecurity through Federal Procurement processes and binds existing enforcement regimes under the DoJ and the False Claims Act to enforce cybersecurity compliance.
It raises a short term question. As one who has been involved in the U.S DoD CMMC program. With the lead in cyber from the Executive Office, recent announcements by DHS and FISMA. Is CMMC actually needed, if it is how will it align to ONCD. Or is there enough authoritative alignment under ONCD for cyber regulation, that encompasses enforcement of DFARS 252.204-7012 through the ONCD plan?
One can see the tools are already in the tool box, but they have never been used. That does not mean that more tools are needed, just a refocus of existing ones, as one example the recent update to FISMA 2023. Another tool that has never been used, yet.
#cybersecurity #cyberriskmanagement #cmmc #dfars #cyberlegal
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