MFT for CMMC: Ensure Your Managed File Transfer Solution is CMMC Compliant

Is your managed file transfer solution CMMC compliant? If isn’t, and it’s required to be, non-compliance can cost you current or future department of defense (DoD) contracts.

To whom does CMMC apply? CMMC, or Cybersecurity Maturity Model Certification, applies to anyone who works with the U.S. Department of Defense, including contractors and subcontractors. When initially launched, CMMC implementation affected over 300,000 organizations.

The CMMC certification process is arduous but our CMMC 2.0 compliance roadmap can help.

What Is CMMC and How Does It Impact My Business?

CMMC is a relatively new body of cybersecurity regulations rolling out in the Department of Defense (DoD) supply chain. Based on Special Publication 800-171, Federal Information Processing Standard (FIPS) 200, and other documents published by the National Institute of Standards and Technology (NIST), CMMC provides contractors in the supply chain with a maturity model that determines their capability to handle Controlled Unclassified Information (CUI).

CUI is a unique designation for data. Created in 2010 through an Executive Order by then-President Barack Obama, CUI defines a category of information that, while not classified (and thus subject to military or federal law as such), still serves an essential purpose in the operation of defense or executive agencies. NIST 800-171 and CMMC outline the requirements necessary for protecting CUI.

To gauge cyber contractor maturity, CMMC provides a tiered approach based on five levels determined by cybersecurity hygiene (which includes the number of technical security practices implemented) and processes (the  capability to manage organizational security).

There are three CMMC maturity levels in the CMMC 2.0 framework:

1. CMMC Level 1 (Foundational): CMMC Level 1 requires annual self-assessment that has attestation from a corporate executive. This level encompasses the basic safeguarding requirements for FCI specified in FAR Clause 52.204-21.
2. CMMC 2.0 Level 2 (Advanced): CMMC Level 2 is aligned with NIST SP 800-171. It requires triennial third-party assessments for contractors that send, share, receive, and store critical national security information. These third-party assessments are conducted by C3PAOs. Select contractors that fall into Level 2 only require annual self-assessments with corporate attestation.
   This level encompasses the security requirements for CUI specified in NIST SP 800-171 Rev 2 per DFARS Clause 252.204-7012 [3, 4, 5].
3. CMMC 2.0 Level 3 (Expert): CMMC Level 3 is aligned with NIST 800-172 and will require triennial government-led assessments. Level 3 will contain 24 requirements from NIST SP 800-172.

It is certainly the case that when it comes to transferring files within a context where CUI is involved, any file transfer solution would need to meet minimum security requirements for at least CMMC Level 2.

How Can an MFT Solution Affect CMMC Compliance?

Because CMMC regulations require much more than simple technical security measures to protect data, a compliant managed file transfer (MFT) solution provides numerous data control, security, and auditing capabilities. This is why many contractors opt for managed file transfer solutions like Kiteworks Secure MFT to handle enterprise file transfer.

Consider CMMC Level 2, the minimum level needed to handle CUI. At this level, a managed file transfer solution would need to include the following features:

• Encryption for all data at rest and data in transit: Typical encryption algorithms at this level include AES-128 or AES-256 (for data at rest) and TLS 1.2 or higher (for data in transit).
• Sufficient Access Controls: An MFT solution that maintains compliance will include robust access controls—ways to limit system access to authorized users, place access limits based on transaction type, limit login attempts, strictly control user privileges, and verify or control the number of transactions on the system.
• Audit Logs: CMMC calls for IT systems that provide audit logs for the actions of users on the system. This includes the capacity to uniquely trace steps across the system, maintain immutable logs for forensic analytics, accurately timestamp logs, create alerts based on logged events, protect audit information from tampering or corruption, and generate reports based on audit logs.
• Reporting and Documentation: MFTs should include ways to report activity in the system, typically through a dashboard that supports reporting and documentation efforts. These documents will often be needed to address audit requests, but they also inform important and necessary practices like risk management.

Additionally, compliant MFTs must still serve high-performance enterprise workloads:

• Scheduled and Batch Transfers: Handling large file transfers or high-volume batch transfers while maintaining speed and agility are the primary reasons for using file transfers like MFT. An MFT also allows for scheduling these transfers, which can serve an essential purpose of offloading network-intensive transfers after hours.
• Scalability: An MFT provides a solid backbone for scalable file transfer schemas where strategic transfers and data monitoring can flex larger or smaller depending on an organization’s needs.
• Enterprise Integration: An MFT with the right integrations is worth its weight in gold. An MFT that can incorporate functionality with productivity tools, security information and event management (SIEM) solutions, cloud platforms, and cloud computing applications extends how an organization can use that data effectively.

How CMMC Controls Apply to File Transfer Operations

Several CMMC 2.0 control families, or domains, directly impact how organizations manage file transfers, particularly when handling CUI. Key domains include Access Control (AC), Audit and Accountability (AU), and System & Communications Protection (SC).

For a CMMC-compliant managed file transfer solution, AC controls dictate the need for strong authentication (like MFA), least privilege principles via role-based permissions, and controls over information flow. For instance, ensuring only authorized personnel can upload or download specific CUI files aligns with AC requirements.

AU controls mandate detailed, immutable audit logs of all file transfer activities—who accessed what, when, and from where—which is crucial for monitoring and forensic analysis. A practical example is logging every SFTP connection attempt and file transfer event. SC controls require robust data protection, primarily through encryption. This means employing FIPS-validated encryption like AES 256 encryption for CUI at rest within the MFT server and TLS 1.2 or higher for data in transit during transfers.

Configuration Management (CM) also plays a role, ensuring the MFT system is securely configured and changes are tracked. Neglecting any of these areas in your MFT solution significantly increases the risk of non-compliance and potential CUI exposure, making a compliant file transfer process impossible.

What Should Defense Contractors Look For in a CMMC-compliant Managed File Transfer Solution?

When it comes to MFT and compliance, organizations are going to assess any solution based on two criteria:

• Features and Enterprise Tools: What does this tool bring to my business? How does it help leverage our data meaningfully? What can it bring in terms of intelligence and insights, and flexibility and scalability?
• Compliance and Security: How does this MFT provide security measures in line with CMMC? Does it provide technical measures, administrative controls, physical security, or some combination of those three?

With that in mind, an MFT solution should check all the following boxes:

1. The technology meets the minimum desired CMMC maturity level.
2. The technology provides extensive auditing and logging.
3. The technology includes productivity integrations or other features like built-in dashboards that provide more with control over how the system is used.
4. The technology supports robust MFT controls like detailed scheduling and tracking and high-volume transfers.

Key CMMC Requirements for File and Data Transfers

To meet CMMC requirements for handling Controlled Unclassified Information (CUI), a Managed File Transfer (MFT) solution must incorporate key security controls. The following capabilities ensure confidentiality, integrity, and accountability across the system—supporting compliance and strengthening your organization’s cyber resilience.

• Encryption At Rest: Utilize FIPS 140-2 validated cryptography, typically AES-256, to protect all CUI stored within the MFT system’s repositories.
• Encryption In Transit: Employ robust protocols like TLS 1.2 or higher (with secure cipher suites) for all data transfers, including SFTP, FTPS, HTTPS, and secure email gateways integrated with the MFT.
• Multi-Factor Authentication (MFA): Implement MFA for all users accessing the MFT system, especially administrators and those handling CUI, to prevent unauthorized access.
• Immutable Audit Logging: Generate comprehensive, tamper-proof logs for all system events, including user logins, file accesses, transfers, configuration changes, and administrative actions. Ensure logs are centrally stored and protected.
• Role-Based Access Control (RBAC): Enforce the principle of least privilege by assigning permissions based on user roles and responsibilities, limiting access to CUI and system functions strictly on a need-to-know basis. This is core to a cmmc compliant mft setup.
• Session Controls: Implement session timeout mechanisms, concurrent session limits, and secure session termination protocols to mitigate risks associated with unattended or hijacked sessions. This is often overlooked but critical for mft cmmc compliance.
• System Hardening and Vulnerability Management: Regularly scan the MFT environment for vulnerabilities and apply necessary patches promptly. Securely configure the underlying operating systems and applications according to security best practices (e.g., DISA STIGs where applicable).
• Incident Response Capabilities: Ensure the MFT system supports incident detection and response, including alerting mechanisms for suspicious activities identified in audit logs.

Strategies to Exceed CMMC File Transfer Requirements

Going beyond baseline CMMC controls, these advanced strategies elevate your Managed File Transfer (MFT) environment to meet higher maturity levels. From Zero Trust to automated compliance and incident response, each measure strengthens your defense posture while streamlining secure, compliant file exchange.

• Adopt Zero Trust Principles: Move beyond perimeter security. Implement micro-segmentation for your MFT environment and enforce strict user/device verification for every access request, regardless of network location. This significantly hardens your managed file transfer cmmc posture.
• Integrate Advanced Threat Detection: Feed MFT logs into a sophisticated SIEM and User and Entity Behavior Analytics (UEBA) solution. This allows for proactive identification of anomalous transfer patterns or potential insider threats beyond basic CMMC log review requirements.
• Implement Data Loss Prevention (DLP): Integrate your MFT solution with DLP tools to automatically scan outbound files for CUI markings or sensitive keywords, preventing accidental or malicious data exfiltration before the transfer completes.
• Automate Compliance Reporting: Configure your MFT platform and SIEM to generate compliance reports automatically, mapping system configurations and audit logs directly to specific CMMC controls. This drastically reduces audit preparation time and effort.
• Conduct Rigorous Penetration Testing: Schedule regular, independent penetration tests specifically targeting your MFT infrastructure and workflows. Use findings to identify and remediate vulnerabilities proactively, demonstrating a mature security practice suitable for higher CMMC levels.
• Develop and Rehearse MFT-Specific Incident Response Plans: Create detailed playbooks for handling security incidents involving the MFT system (e.g., CUI breach via file transfer). Regularly test these plans through tabletop exercises or simulations to ensure readiness.

Step-by-Step Roadmap to Implement CMMC 2.0 in Your MFT Environment

This phased approach provides a practical timeline for aligning your Managed File Transfer (MFT) environment with CMMC Level 3 requirements. From scoping and control mapping to hardening, testing, and evidence prep, each step builds toward a secure, auditable, and fully compliant file transfer framework.

• Phase 1: Gap Analysis & Scoping (Weeks 1-4): Identify all MFT systems and workflows handling CUI. Perform a detailed gap analysis comparing your current MFT configurations, policies, and procedures against the specific CMMC Level 3 controls (derived from NIST SP 800-171). Document all deficiencies. Tip: Clearly define the scope – which servers, users, and data flows are subject to CMMC requirements.
• Phase 2: Control Mapping & Solution Selection (Weeks 5-8): Map each relevant CMMC control to specific features and settings within your existing or potential MFT solution. If gaps exist that current technology cannot fill, research and select a CMMC compliant MFT platform that meets the requirements, paying close attention to FIPS 140-2 validation for cryptography.
• Phase 3: Technology Configuration & Hardening (Weeks 9-16): Implement and configure the chosen MFT solution according to CMMC requirements. This includes setting up encryption (AES-256 at rest, TLS 1.2+ in transit), MFA, RBAC, audit logging configurations, session controls, and system hardening based on security benchmarks. Ensure your cmmc mft setup aligns with vendor best practices and CMMC guidance.
• Phase 4: Policy & Procedure Documentation (Weeks 17-20): Develop or update policies and standard operating procedures (SOPs) specifically for the MFT environment. These should cover CUI handling rules, access management processes, incident response steps for MFT, log review procedures, and configuration management. Tip: Ensure documentation is clear, accessible, and aligns with implemented controls.
• Phase 5: Internal Testing & Validation (Weeks 21-24): Conduct thorough internal testing to validate that all implemented controls are working as intended. This includes testing user access scenarios, checking log outputs, verifying encryption, and running vulnerability scans. Remediate any findings.
• Phase 6: Evidence Gathering & Assessment Preparation (Weeks 25+): Compile all documentation, configuration evidence, log samples, and test results required for a CMMC assessment. Organize evidence according to CMMC control families. Consider a readiness assessment by a third party before engaging a C3PAO (CMMC Third-Party Assessment Organization). Resource: Refer to the official CMMC Assessment Guides available on the DoD’s Cyber AB website. Remember, achieving a compliant file transfer system under CMMC is an ongoing process, not a one-time project.

CMMC and FedRAMP Moderate Equivalency for File Transfer

There is significant overlap between CMMC Level 3 requirements and the controls specified for FedRAMP Moderate authorization, as both frameworks heavily rely on NIST 800-171 and NIST 800-53.

While CMMC Level 3 focuses specifically on protecting CUI within the Defense Industrial Base (DIB) and includes process maturity aspects, FedRAMP Moderate provides a standardized security framework for cloud services used by federal agencies. Achieving FedRAMP Moderate authorization for a cloud-based managed file transfer CMMC solution demonstrates adherence to a large majority of the technical controls required for CMMC Level 3.

Organizations can leverage a vendor’s FedRAMP Moderate Attestation of Compliance (AoC) or full Authorization package as substantial evidence when preparing for a CMMC assessment, potentially accelerating the compliance process for their file transfer operations. However, it’s crucial to remember they are not identical; organizations must still perform a mapping exercise to identify and address any CMMC-specific controls or practices not fully covered by FedRAMP Moderate, particularly around CMMC processes. Utilizing a FedRAMP Moderate Authorized platform provides a strong foundation for establishing a compliant file transfer environment suitable for handling DoD-related CUI.

Kiteworks MFT for CMMC Compliance

When it comes to CMMC, defense contractors and subcontractors must work with an MFT provider that meets CMMC requirements without sacrificing enterprise usability and functionality. The Kiteworks Private Content Network helps organizations leverage cutting-edge MFT features with secure, compliant technology.

With Kiteworks, defense contractors get the following:

• Security and Compliance: Kiteworks utilizes AES-256 encryption for data at rest and TLS 1.3 for data in transit. Its hardened virtual appliance, granular controls, authentication, and other security stack integrations, along with comprehensive logging and audit, enable organizations to achieve compliance efficiently.
• Audit Logging: With Kiteworks immutable audit logs, organizations can trust that they can detect attacks sooner and maintain the correct chain of evidence to perform forensics. Since the system merges and standardizes entries from all the components, its unified Syslog and alerts save security operations center (SOC) team crucial time and help a compliance team prepare for audits.
• Single-tenant Private Cloud: File transfers, file storage, and access will occur on a dedicated Kiteworks instance, deployed on-premises, on Infrastructure-as-a-Service (IaaS) resources, or hosted in the cloud by the Kiteworks Cloud server. That means no shared runtime, databases or repositories, resources, or potential for cross-cloud breaches or attacks. Kiteworks is also FedRAMP authorized for Moderate Impact Level information; FedRAMP compliance streamlines the CMMC compliance process as it satisfies requirements for NIST 800-171, a foundation for CMMC Level 2.
• Scalability and Cost Consolidation: Centralized governance, logging, and administration will also save administrative time and costs. All Kiteworks servers come seamlessly equipped with secure, best-of-breed file sharing and secure email.
• Seamless Automation: The Kiteworks platform supports MFT automation to facilitate content transfer into and out of SFTP and other repositories like file shares and AWS S3.
• Self-service Ease of Use: Business users access the back end of the Kiteworks SFTP server through familiar web file-sharing folders. Employees who are delegated by the administrators manage the folders to create new folder trees for new partners or nest new folders for new data subjects.
• Data Visibility and Management: Our CISO Dashboard gives organizations an overview of their data: where it is, who is accessing it, how it is being used, and if it complies with CMMC. The CISO Dashboard empowers business leaders to make informed decisions about security and regulatory requirements.

To learn more about CMMC compliance and managed file transfer, schedule a custom demo of Kiteworks today.

MFT for CMMC FAQs

Additional Resources

• Brochure Automate Your Business with Security and Compliance First
• Blog Post 11 Requirements for Secure Managed File Transfer
• White Paper Securing Content Communications for CMMC 2.0