Ethan Cudzilo

Key quotes from the new 48CFR Rule for #CMMC. This rule is the one that goes into new and renewing contracts and requires having a CMMC certificate or self-assessment upon contract award. They tightened up the language quite a bit. On quick scan, it looks well done. The first 40 pages give a lot of information about the DoD's thought process on CMMC, including some technical clarifications like whether joint ventures need to be individually certified, and whether talking about CUI over the phone is in scope.

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It's here - CRQ Training! If you're a CISO, risk analyst or assessor interested in quantifying cyber risk don't miss this CRQ Mastery Workshop. Learn basic and advanced method. Hands-on exercises. Full toolkit and risk models. ISC2 and ISACA Chapters save and additional 20% for their members. 20 CPEs. More info and registration https://lnkd.in/ecVj8V5N #ISC2, #ISACA, #Training, CyberRiskQuantification, #CISO, #Cybersecurity

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This could be the source of your "aha" moment with CMMC. Trust me when I say that there's a lot of FUD and myths in the marketplace, and there's a lot of sleight of hand being performed by people who really are not the experts they pretend to be in the CMMC echo system. Here's a few quick screening questions to ask. 1. Is CUI classified information? 2. Did DoD develop the requirements for protecting my sensitive information? 3. If I don't meet a particular control, I can always get an extension of up to a year to do so, correct? 4. Do I just have to meet 80% of the assessment objectives in each control to be certified? 5. Do I pass the assessment and receive a CMMC Level 2 certification if I meet 75% of the requirements? If you encounter hesitation on any of these questions by any company you're asking to help you comply with CMMC, I would suggest you keep looking. Better yet, go the NCMBC web site and pay the admission. It's $130 per person, and you get food, entertainment and fellowship with other managers and subject matter experts as you plot your journey through the CMMC echo system. Hope to see you there. It's an in person event at McKimmon Center of North Carolina State University. (https://lnkd.in/eitYSGUf, McKimmon Conference and Training Center at NC State University, 1101 Gorman St, Raleigh, NC 27606 (919) 515-2277). Registration link is in Laura's post.

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ECS selected #Axonius to support DHS's CDM program. Axonius will provide comprehensive #Cybersecurity asset visibility and vulnerability management, enabling efficient risk management: https://dy.si/m5nFJ

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Thoughts on Just-In-Time procedures and NIST SP 800-171 / #CMMC compliance... At Kieri Solutions - Authorized C3PAO , we figured out that people follow procedures best when they 𝘢𝘳𝘦𝘯'𝘵 𝘱𝘳𝘰𝘤𝘦𝘥𝘶𝘳𝘦𝘴. ??? Let me explain. You're onboarding a new user. To be compliant with #CMMC, your onboarding team needs to go through a convoluted process involving getting details about the new user, verifying NDA, background checks, training, requesting permissions, justifying permissions, reviewing permissions, authorizing permissions, creating accounts, creating records of the accounts, creating records of the permissions for the accounts, assigning expiration dates for each account, setting up a laptop, authorizing the laptop...!!! It goes on and on. If your strategy is to tell your HR and IT team that they need to perfectly follow a 70 step process on page 19 of ye old 𝐈𝐓_𝐏𝐫𝐨𝐜𝐞𝐝𝐮𝐫𝐞𝐬_𝐌𝐚𝐧𝐮𝐚𝐥, 𝘺𝘰𝘶 𝘮𝘪𝘨𝘩𝘵 𝘢𝘴 𝘸𝘦𝘭𝘭 𝘱𝘢𝘤𝘬 𝘶𝘱 𝘺𝘰𝘶𝘳 𝘣𝘢𝘨𝘴 𝘳𝘪𝘨𝘩𝘵 𝘯𝘰𝘸. The error rate will be upwards of 80%, unless you nag and threaten 😡 everyone constantly, in which case you might get down to an error rate of 30% (and your team will quit). Instead, if you use a combination of a well-designed Access Request Form and an Account Management database, all your team needs to do is remember to start with the correct form. 📝 The form should have fields and just-in-time instructions for each step of the process between HR and your IT Department. All your team needs to do is fill out each field in the form and they will complete the background screening, training, permissions, justifications, etc. naturally without nagging. Then, a well designed Account Management database helps your team manage the accounts long-term by including checks ◻️ for commonly-forgotten steps (like user agreements), next-review dates, annual training refresher dates, mapping the user to their supervisor, granular "should-be" permissions for both digital systems and facilities, and historic authorization notes. The last step for perfect procedures is a regular review to look for and fix errors. But again, if you want to be successful, don't expect your team to remember your dusty policies and procedures book in the corner. Instead, use a scheduled task, a ticket, or a checklist with just-in-time instructions to make sure that the review gets done. Pro-tip: next-review-dates are an excellent way to spread this task across time, instead of trying to do it all in one lump. Are your compliance policies and processes working for you, or against you? There is a better way. Use thoughtful design in your compliance system to reduce errors and streamline functionality. Screenshot below is from the Kieri Compliance Documentation's Account Management Database, showing some of the magic of our full-featured 800-171 / CMMC Level 2 compliance program. I'll put the link in comments, for anyone that is interested.

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ISC2's CISSP: Is the Certification Broken? David Malachow interviews Ira Winkler on the Professional CISO Show, discussing Ira's open letter to ISC2 and its implications for CISSP certification. A must-watch for cybersecurity professionals! #ProfessionalCISO ['#ProfessionalCISO', '#Cybersecurity', '#CISSP', '#InfoSec', '#ISC2', '#CybersecurityPodcast', '#InformationSecurity', '#DataSecurity', '#ITSecurity', '#CyberRisk']

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CMMC Level 2 Assessment Objective: Alternative Work Sites PRACTICE: Organizations must enforce safeguarding measures for containing controlled unclassified information (CUI) at alternative work sites. ASSESSMENT: Alternative work sites may include government facilities or the private residences of employees. Organizations must define and implement safeguards to account for protection of CUI beyond the enterprise perimeter. Safeguards may include physical protections, such as locked file drawers, as well as electronic protections such as encryption, audit logging, and proper access controls. Be prepared! Your assessor could ask to: 🔍 EXAMINE a list of safeguards required for alternative work sites 🗣 INTERVIEW personnel approving use of alternative work sites 📝 TEST organizational processes for security at alternative work sites (CMMC Assessment Guide: Level 2 Version 2.11, page 186) #CMMC #DoD #cybersecurity #NIST #InformationSecurity

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The PCI DSS v4.0.1 update provides much-needed clarifications that can help us all strengthen our cybersecurity measures. With clearer guidelines on MFA and payment scripts, we can better protect sensitive data. How is your organization adapting to these changes? Reach out to Arbure for a deep dive into these updates. #PCIDSS #Cybersecurity #Compliance #PCIUpdate

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Check out this podcast interview with me just after my TribalNet keynote in Vegas recently. I was asked a random question at the end about the first concert I attended that you might find interesting (and it's not just what's listed in the podcast description). #infosec #CISO #CIO #businessleaders #cybersecurity #podcast #keynotespeaker #backtobasics #rockconcerts #ISAC

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ECS selected #Axonius to support DHS's CDM program. Axonius will provide comprehensive #Cybersecurity asset visibility and vulnerability management, enabling efficient risk management: https://dy.si/okAJaf2

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My book 📚 "Incident Response with Threat Intelligence" is also included in this promotion 🤓

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In this article for the IACP's Police Chief Magazine, PenLink's Johnmichael O'Hare and our own Trey Amick talk about how digital forensics and open-source intelligence (#OSINT) are playing crucial roles in modernizing police investigations: https://ow.ly/UH9O50SUg9q #DFIR

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I often hear the question "Where/What are our biggest security exposures?" Cyentia Institute recently had the opportunity to explore this question using data from hundreds of thousands of attack path assessments conducted through the XM Cyber Continuous Exposure Management (CEM) platform. The attached figure gives a categorical breakdown of what we observed based on all entities (digital assets), total security exposures, and exposures affecting critical assets. . The left-most chart represents the attack surface based on broad categories of digital entities discovered during attack path assessments. Active Directory constitutes just over half of entities identified across all environments. On-premises IT and network devices account for another 31% of entities and cloud environments house the remaining 17%. Not all entities, however, are exposed via attack paths. If we change the scope of the attack surface to include only vetted exposures (entities susceptible to attack techniques), things look different. The middle chart captures this perspective and Active Directory exposures dominate the attack surface. But not all of those exposures affect critical assets. To be truly effective, Exposure Management must encompass all environments and account for where critical assets are most at risk. If we once again rescope the attack surface to focus on exposures to critical assets, a very different picture emerges, which is captured in the rightmost chart. Cloud environments now encompass over half of all critical asset exposures, followed by AD at 33% and IT/Network devices at 11%. Does this sync with exposures across your attack surface? Which perspective/view/chart is your primary guide for managing exposures? The full report contains tons of additional insights on exposure management. Download here: https://lnkd.in/dPfqXG7y #cybersecurity #exposuremanagement #cyberrisk

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Heads up on this once in 5 years opportunity to sponsor Cyentia Institute research into the largest #cybersecurity incidents. See the call for sponsors for the 2025 "Xtreme" edition of the Information Risk Insights Study at the link below. #cyberrisk #cyberresilience #cyberattacks https://lnkd.in/etc6FjsY

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CISA released two Industrial Control Systems (ICS) advisories on January 7, 2025. These advisories provide timely information about current security issues, vulnerabilities, and exploits surrounding ICS. · ICSA-25-007-01 ABB ASPECT-Enterprise, NEXUS, and MATRIX Series Products · ICSA-25-007-02 Nedap Librix Ecoreader CISA encourages users and administrators to review newly released ICS advisories for technical details and mitigations. https://lnkd.in/eG9pyRD8

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*WiCyS Delaware Valley EVENT ALERT!* Join us for Offensive Security War Stories on Tuesday, November 19th. This is a great event for security practitioners looking to improve their ethical hacking skills/knowledge and security leaders who want to understand the innerworkings of penetration testing and real-life tactics that can be used to compromise your organization. #wicys #cybersecurity #informationsecurity #penetrationtesting #ethicalhacking

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By the end of 2024, the MVP Enclave and 800-171 Compliance Program will have undergone four intense Joint Surveillance Voluntary Assessments within a 12-month period by four distinct DIBCAC teams with four separate small businesses. Building enclaves and 800-171 Compliance Programs correctly is a challenging task. Who is guiding your company towards early assessment and beyond? You deserve to move forward with confidence. You deserve to win in 2025. #DIB #InformationSecurity #CMMC #CCA #CCP #ENCLAVE #JSVA #GOVCON #HAMPTONROADSDIB

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