There is allot of criticism abound about the US DoD CMMC program.

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There is allot of criticism abound about the US DoD CMMC program. But its not levelled at the need to implement cybersecurity across the global DIB. It is invariable focused upon the way the proposed CMMC program has been developed and how it will be deployed. All of which is pending DoD and GAO reviews and congressional oversight.

One suspects following the recent unilateral decisions made by the US to pull out of Afghanistan a precedent for future actions has been set. Which may impact CMMC, in as much as the DoD is the customer and it rightly expects US National interests and its IP to be secured. We are all aware DFARS 252.204-7012 and the implementation of NIST SP 800-171 was not implemented by many companies in the DIB. Room for negotiating CMMC compliance by Nation States and across the international DIB maybe small.

With this in mind. We created the enclosed video, discussing a little known DoD Instruction (DoDi 5000.90), published in December 2020. It outlines the requirements for DoD procurement Managers and ATO Officers to adopt the RMF as part of the DoD Adaptive Acquisition Framework and decision making processed. Processes aligned to FISMA requiring an assessment of cyber-risk of the procured weapon system. The DoDi provides the tools for DoD procurement to request Cyber related assessments across the procurement life cycle.

My Colleague Ted Dziekanowski, who teaches CAP and RMF for Federal government including the DoD, outlines the DoDi and why it matters for DoD procurement, primes and subcontractors.

Jason Spezzano‚ Brian McCarthy

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Cybersecurity, National Security & Defence, Regulation & Compliance

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