What You Need to Know About 32 CFR Compliance as CMMC Nears Implementation

The Cybersecurity Maturity Model Certification (CMMC) program is about to take a significant step forward. The Office of Information and Regulatory Affairs (OIRA) has concluded its review of 32 CFR. This development brings us closer to the full implementation of CMMC, with potential enforcement as early as Q4 2024.

In this post, we’ll take a closer look at 32 CFR and what it means for defense contractors who have to demonstrate CMMC compliance if they hope to continue working with the Department of Defense (DoD).

The CMMC certification process is arduous but our CMMC compliance roadmap can help.

What is 32 CFR and Why Does It Matter?

32 CFR establishes the regulatory framework for the CMMC program. It defines three CMMC levels, each corresponding to increasing cybersecurity maturity for protecting Federal Contract Information (FCI) and Controlled Unclassified Information (CUI):

• CMMC Level 1: CMMC Level 1 focuses on basic cyber hygiene and requires organizations to implement 17 foundational cybersecurity practices. These practices align with Federal Acquisition Regulation (FAR) requirements and aim to protect Federal Contract Information (FCI) through simple security controls, including access management, physical protection, and basic monitoring, without formal documentation or process maturity.
• CMMC Level 2: CMMC Level 2 is designed for organizations handling CUI and requires compliance with 110 security practices based on NIST 800-171. This level emphasizes advanced cybersecurity hygiene with more stringent controls, including encryption, access management, and regular monitoring, while demonstrating process documentation and maturity through self-assessments or third-party audits.
• CMMC Level 3: CMMC Level 3 targets organizations managing highly sensitive CUI and critical national security information. It requires full compliance with NIST SP 800-172 and advanced cybersecurity measures, focusing on proactive threat detection and incident response. Level 3 demands ongoing assessments, detailed documentation, and third-party certifications to ensure top-tier security.

The 32 CFR regulation outlines specific security requirements for each level, drawing from established standards like NIST 800-171 and 800-172.

Key Takeaways

1. CMMC Implementation Nears
   

   With the review of 32 CFR complete, CMMC enforcement may begin as early as Q1 2025, requiring defense contractors to prepare now.

2. Three CMMC Levels
   

   32 CFR outlines three CMMC levels, with increasing cybersecurity requirements for protecting FCI and CUI, based on standards like NIST SP 800-171 and 800-172.

3. Engage C3PAOs Early
   

   Defense contractors should engage with Certified Third-Party Assessment Organizations (C3PAOs) early to secure their place for certification assessments.

4. Kiteworks’ Role in CMMC Compliance
   

   Solutions like Kiteworks can streamline CMMC compliance by supporting up to 90% of Level 2 requirements, offering secure file sharing, email protection, and comprehensive audit logging.

5. Proactive Preparation
   

   Companies must assess their current cybersecurity posture and implement the necessary controls to meet CMMC requirements, ensuring contract eligibility in the defense industrial base (DIB).

Importantly, 32 CFR transforms CMMC from a conceptual model into an enforceable set of requirements for the defense industrial base (DIB). It details the assessment and certification processes, including criteria for Certified Third-Party Assessment Organizations (C3PAOs) and procedures for conducting assessments.

The Clock is Ticking: CMMC Implementation Timeline

With OIRA’s review complete, we’ve entered a 60-day review period. This puts us on track for potential for CMMC to be in contracts as early as Q1 2025. For organizations in the DIB, this timeline is critical. The time to prepare is now.

Defense contractors in the DIB should immediately begin assessing their current cybersecurity posture against the anticipated CMMC requirements for their level. Engaging with C3PAOs early is crucial to secure a place in the assessment queue. This proactive approach will help ensure certification at the required compliance level before it becomes mandatory for contract eligibility.

Need to comply with CMMC? Here is your complete CMMC compliance checklist.

Streamlining CMMC Compliance: The Kiteworks Private Content Network

As organizations scramble to prepare for CMMC, comprehensive solutions like Kiteworks are becoming increasingly valuable. Kiteworks’ Private Content Network is FedRAMP Moderate Authorized and supports nearly 90% of CMMC Level 2 requirements out of the box.

Key features of the Kiteworks platform include:

• Secure file sharing: Kiteworks secure file sharing enables organizations to securely share sensitive files internally and externally, with advanced features like encryption, user access controls, audit logs, and regulatory compliance with FedRAMP, and, of course, CMMC.
• Email protection: Kiteworks email protection features end-to-end encryption for emails and attachments, in transit and at rest. Features include an email protection gateway, tracking for every file that’s sent, received, downloaded, or moved, audit logs that record file activity and can be fed through your SIEM solution or used to demonstrate regulatory compliance, and granular access controls for secure and compliant email exchanges.
• Managed file transfer: Kiteworks’ secure managed file transfer (MFT) solution provides enterprise-level security for transferring large or bulk sensitive files across networks. It offers end-to-end encryption, automation of workflows, and compliance with regulations like GDPR and HIPAA. With real-time tracking, access controls, and audit logs, organizations gain visibility and control over data transfers.
• Web forms: Kiteworks’ secure web forms solution enables organizations to collect sensitive data through encrypted, customizable web forms. It ensures data privacy with end-to-end encryption and access controls, while maintaining compliance with regulations like GDPR, PCI DSS, and HIPAA. Features include automated workflows, audit logs, and real-time tracking for secure data submission.
• Strong access controls: Kiteworks’ access controls enable organizations to manage and restrict access to sensitive data, ensuring that only authorized users can view, edit, or share personally identifiable and protected health information (PII/PHI), intellectual property (IP), and other confidential information. With granular permissions, multi-factor authentication (MFA), and role-based access, Kiteworks ensures access to sensitive content is restricted to only authorized users.
• Robust encryption capabilities: Kiteworks offers robust encryption capabilities that protect sensitive data both in transit and at rest. Kiteworks utilizes AES 256 encryption for content in transit and TLS 1.3 for content at rest. Utilizing end-to-end encryption, Kiteworks secures files, emails, and communications against unauthorized access. The solution complies with industry standards and regulations, ensuring data integrity and confidentiality while providing users with peace of mind in data protection.
• Comprehensive audit logging: Kiteworks provides comprehensive audit logging capabilities that track all user activities related to file sharing, email, and data transfers. These logs offer detailed insights into access, modifications, and sharing events, ensuring accountability and compliance with regulations like CMMC and IRAP. This feature enhances security by enabling proactive monitoring and forensic analysis.

These functionalities align closely with CMMC requirements across multiple domains, including Access Control, Audit and Accountability, and System and Communications Protection. By leveraging such a solution, organizations can significantly streamline their CMMC compliance efforts and reduce the risk of data breaches.

Kiteworks Helps Defense Contractors Demonstrate CMMC Compliance with a Private Content Network

The review of 32 CFR by OIRA marks a significant milestone in the journey towards full CMMC implementation. With CMMC certifications potentially included in DoD contracts as early as Q1 2025, organizations in the DIB need to act swiftly to assess their cybersecurity posture and begin the certification process. Solutions like Kiteworks can play a crucial role in this preparation, offering comprehensive tools to meet CMMC requirements and protect sensitive information. As we move closer to the implementation date, staying informed and proactive will be key to ensuring compliance and maintaining eligibility for DoD contracts.

The Kiteworks Private Content Network, a FIPS 140-2 Level validated secure file sharing and file transfer platform, consolidates email, file sharing, web forms, SFTP, managed file transfer, and next-generation digital rights management solution so organizations control, protect, and track every file as it enters and exits the organization.

Kiteworks supports nearly 90% of CMMC 2.0 Level 2 requirements out of the box. As a result, DoD contractors and subcontractors can accelerate their CMMC 2.0 Level 2 accreditation process by ensuring they have the right sensitive content communications platform in place.

With Kiteworks, DoD contractors and subcontractors unify their sensitive content communications into a dedicated Private Content Network, leveraging automated policy controls and tracking and cybersecurity protocols that align with CMMC 2.0 practices.

Kiteworks enables rapid CMMC 2.0 compliance with core capabilities and features including:

• Certification with key U.S. government compliance standards and requirements, including SSAE-16/SOC 2, NIST SP 800-171, and NIST SP 800-172
• FIPS 140-2 Level 1 validation
• FedRAMP Authorized for Moderate Impact Level CUI
• AES 256-bit encryption for data at rest, TLS 1.2 for data in transit, and sole encryption key ownership

Kiteworks deployment options include on-premises, hosted, private, hybrid, and FedRAMP virtual private cloud. With Kiteworks: control access to sensitive content; protect it when it’s shared externally using automated end-to-end encryption, multi-factor authentication, and security infrastructure integrations; see, track, and report all file activity, namely who sends what to whom, when, and how. Finally demonstrate compliance with regulations and standards like GDPR, HIPAA, CMMC, Cyber Essentials Plus, IRAP, and many more.

To learn more about Kiteworks, schedule a custom demo today.

Additional Resources

• Blog Post CMMC Compliance for Small Businesses: Challenges and Solutions
• Blog Post If You Need to Comply With CMMC 2.0, Here Is Your Complete CMMC Compliance Checklist
• Blog Post CMMC Audit Requirements: What Assessors Need to See When Gauging Your CMMC Readiness
• Guide  CMMC 2.0 Compliance Mapping for Sensitive Content Communications
• Blog Post 12 Things Defense Industrial Base Suppliers Need to Know When Preparing for CMMC 2.0 Compliance