Author: Jillian Wright (Jillian Wright)

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When ITAR Data Is CUI and When It Is Not
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When ITAR Data Is CUI and When It Is Not

If you handle defense work, you already know that ITAR (International Traffic in Arms Regulations) and CUI (Controlled Unclassified Information) often come up in the same conversation. They overlap, but they are not the same thing. This post explains when ITAR-controlled information must also be handled as CUI and when it stands alone under export control. Oh yeah — I...

Oh Shit, I Need CMMC – A Subcontractor’s Survival Guide
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Oh Shit, I Need CMMC – A Subcontractor’s Survival Guide

If you are reading this, you are probably a subcontractor in the Defense Industrial Base (DIB), and there is a good chance your prime contractor has dropped a bombshell: you need to be compliant with CMMC. Maybe they asked for your System Security Plan (SSP). Maybe they requested your Supplier Performance Risk System (SPRS) score....

CMMC IS a Real Boy!
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CMMC IS a Real Boy!

What Contractors Need to Know About the 48 CFR Final Rule On November 10, 2025, the Department of Defense will cross the line from policy to enforcement. The 48 CFR Final Rule will go into effect, and the Cybersecurity Maturity Model Certification (CMMC) will be a contractual requirement. If you want to win or extend...

Signal, Not Noise:  AU 3.3.3
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Signal, Not Noise: AU 3.3.3

Let’s talk about practice 3.3.3. – Review and update logged events. [a] Determine if a process for determining when to review logged events is defined. [b] Determine if event types being logged are reviewed in accordance with the defined review process. [c] Determine if event types being logged are updated based on the review.  ...

Security Protection Assets and Security Protection Data in CMMC
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Security Protection Assets and Security Protection Data in CMMC

What Are Security Protection Assets (SPAs)? SPAs are the tools, systems, and personnel that provide security functions or capabilities within the CMMC assessment scope of an Organization Seeking Certification (OSC). They protect CUI assets and the broader infrastructure that supports them. A Few Examples of SPAs: Firewalls: Devices or software that regulate network traffic, blocking...

Ports, Protocols, Programs Functions, and Services
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CMMC Practice 3.4.7 – Ports, Protocols, Programs Functions, and Services

TL;DR: Simplifying Essential Features for Compliance The Goal: Restrict and disable nonessential programs, ports, protocols, functions, and services to reduce your system’s attack surface and improve security. Challenges: Documentation—not implementation—is where most companies fall short. You must define “essential” clearly and apply it consistently. What to Do: • Inventory: Identify everything running on your systems....

The CMMC Rule and Plans of Action & Milestones (POA&M)
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The CMMC Rule and Plans of Action & Milestones (POA&M)

One of the things that I wanted to see in the CMMC Rule was more clarity on utilizing Plans of Action and Milestones (POA&M) for companies that do not fully meet all 110 requirements during their assessment. I’m continuing to dive into the CMMC rule…it’s freaking long. Here is what it says about POA&Ms, the...

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