The Schellman Blog

With the introduction of the Cybersecurity Maturity Model Certification (CMMC) program, contractors working with the U.S. Department of Defense (DoD) will be required to meet a certain level of cybersecurity maturity ensuring the protection of the involved sensitive information and data, specifically controlled unclassified information (CUI) and federal contract information (FCI).

On October 27, 2023, the Office of Management and Budget (OMB) released a draft memorandum titled Modernizing the Federal Risk Authorization Management Program (FedRAMP). Savvy readers may have noticed the parallelism of the 2011 and 2023 FedRAMP memorandums to those for FISMA in 2002 and FISMA 2014—for FISMA, the latter memo focused on "Modernization" in comparison with the former one regarding "Management."

Back in August 2022—while rulemaking for the Cybersecurity Maturity Model Certification (CMMC) was ongoing (as it still is)—the Joint Surveillance Program (JSP) was sanctioned by the DoD and CyberAB as an interim step in the CMMC program that allowed organizations to pursue a formal DIBCAC High (NIST 800-171) assessment.

The Cybersecurity Maturity Model Certification (CMMC) is a new framework that aims to better secure federal contract information (FCI) and controlled unclassified information (CUI) that is stored, processed, or transmitted by defense contractors and the entire defense industrial base (DIB).

To become FedRAMP authorized, you must pass the initial, rigorous FedRAMP assessment. But in the following years, you’ll also need to complete Annual Assessments performed by a third-party assessment organization (3PAO) if you’re interested in maintaining that compliance.

With the new SEC Cybersecurity Disclosure Rule requiring both the reporting of material cybersecurity events and the disclosure of cybersecurity programs for public companies, those affected are taking a closer look at cybersecurity frameworks that—while previously considered optional or “nice to have”—could help their organization meet the new regulatory requirements.

The National Institute of Standards and Technology (NIST) has made a significant move in introducing its groundbreaking AI Risk Management Framework (AI RMF). Designed to empower organizations and individuals with comprehensive risk management guidance, the AI RMF aims to create a world where AI can thrive responsibly.

In May of 2021, President Biden issued Executive Order on Improving the Nation’s Cybersecurity (E0 14028), an EO that took specific and significant aim at federal IT systems as well as the private sector technology and software providers that support it.