Smithers CMMC and Cybersecurity Resource Library
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Recently, an state institution's audit uncovered that the organization had mistakenly transferred $400,000 to a fraudulent vendor. Although the institution is not part of the DIB, this case is illustrative of why, in the CMMC ecosystem, a C3PAO (CMMC Third-Party Assessor Organization) is required to certify a contractor's compliance with CMMC for Level 2 and above.
In the case of this institution, a fraudulent vendor approached and said that they needed the organization to change bank accounts. The institution made the change, but the alleged new banking account was just a scam. There was no process in place to vet either the new vendor or the bank account they wanted the institution to use. To put it more simply, there was no protective process to prevent this kind of event.
Most cybersecurity frameworks, like the NIST CSF, ISO 27001, or CMMC will stress the importance of a few key factors.
As Defense Contractors face CMMC compliance, it is important to remember that passing the 110 NIST SP 800-171 controls is just the beginning of the security journey. Processes need to be tested constantly, employees from top to bottom need to be trained constantly, and the organization must update documentation and tactics as threats evolve and change.