Chris Nolke

A little late, but here's the next #cmmc entry for level 2: https://lnkd.in/gKpkbpBp This one was a bit more difficult to decide what to write, as I did not want it to be a long boring read. There are almost 100 additional requirements above level 1, so I just tried to give some highlights by sections. Level 2 is where you start seeing more technical requirements that will be much more likely to start requiring outside assistance, but it also will likely greatly enhance most company's security postures.

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I hope everyone is having a good Friday. Time for some Sa(a)S. We're continuing the CMMC series with a more detailed breakdown of the 3 levels. The full post can be seen here: https://lnkd.in/g-DCGGi2 For a quick summary, all 3 levels are from NIST SP 800 171 (and 172 for level 3), so it's at least not completely new standards. And why the standards are still in the rule-making process, we have a good idea what the final requirements will be. Level 1 will have 17 requirements and is intended for the least sensitive DoD contracts. This certification will be based off of a self assessment. Level 2 has a big jump to 110 total requirements as more national security implications are expected with the associated contracts. This is expected to be the most common level, and in most cases will require a 3rd party assessment every 3 years with an annual self assessment. Level 3 is for the most sensitive contracts that don't involve classified (or greater) designations and will add up to an additional 35 requirements above level two. For this, companies will need to have Federal officials perform the assessment every three years. Please reach out with any questions and have a great weekend! #cmmc #cybersecurity #securityawareness

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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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Read this important advisory from CISA regarding Operational Technology and Industrial Control Systems vulnerabilities. #ICSsecurity #OTsecurity

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VM remains a cornerstone of preventive cybersecurity, but organizations still struggle with vulnerability overload and sophisticated threats. Tenable’s new Exposure Signals gives security teams comprehensive context, so they can shift from VM to exposure management and effectively prioritize high-risk exposures across their complex attack surface. http://ow.ly/oGFk105PbnX

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In a recent conversation a cyber assessor asked me how they could get leadership buy-in to using risk quantification. Here are 3 ways I'd suggest doing this. Let me know what you think in the comments. 1. Use Industry Profiles for Context : Show how your organization compares to others in your industry in terms of risk exposure by using industry data. This helps highlight where your organization stands and can spark interest in exploring risk quantification further. 2. Highlight a Recent Attack : Use a recent cyber attack that affected your industry as an example. Show the potential financial impact and likelihood of such an attack on your organization. This makes the concept of risk quantification more real and urgent, helping leaders understand its importance. 3. Clarify Risk Levels : When discussing risk, push for clear definitions of what “high,” “moderate,” or “low” risk means by advocating for a quantified approach. This can help uncover inconsistencies in how risk is evaluated and emphasize the need for a standardized risk assessment method. Have you had success getting leadership buy-in to using risk quantification?

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Take a few minutes to watch the video on NIST 2.0. It's very insightful. I can only recommend it. 🔍 Besides, you'll have the chance to meet these guys at RISK 2024, so if you still haven't registered, you can do that at www.risk-conference.com 🚀 #cybersecurity #hacking #security #technology #hacker #infosec #ethicalhacking #cybercrime #tech #linux #cyber #hackers #informationsecurity #cyberattack #programming #malware #kalilinux #privacy #cybersecurityawareness #coding #datasecurity #dataprotection #python #ethicalhacker #hack #it #computerscience #pentesting #informationtechnology #business

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I think a lot about securing critical infrastructure and operational technology (OT) environments. A few months ago, I saw a post from Andy Hollingsworth about cybersec ops training from the Idaho National Lab/CISA. I found a collection of training they have online for the Cyber-CHAMP framework. It is taught from an OT operator perspective and highlights the challenges that come with the IT/OT convergence. Cyber-CHAMP is a structured framework to help organizations assess their cybersecurity posture, align security initiatives with business goals, and develop a roadmap for building a cyber-ready workforce. What makes Cyber-CHAMP so powerful is that it looks at #cybersecurity from both the organizational and individual level. It's not just about implementing the latest technologies - it's about ensuring your people have the right skills, roles, and responsibilities to be an effective line of defense. Cyber security for OT environments used to be accomplished by creating separate networks. But that strategy doesn't hold up as more and more devices demand connectivity - including things like coffee pots which the instructors share in a memorable example during the class. Cyber-CHAMP provides a way to assess gaps and develop a tailored plan for upskilling the workforce. I am encouraging everyone on my team to take these classes. The instructors are practical and experienced. The content is up to date, relevant, and vendor agnostic. And, it is free. What's not to like? #aws AWS for Energy & Utilities #timeseries #businessanalytics

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Jay Jacobs and I have been working a lot this week on the inaugural study of EPSS performance. Thought I'd share a pretty chart that Jay churned out yesterday. It addresses the question "What’s the typical pattern of exploitation activity?" As you may suspect, the answer depends on the vulnerability in question. Some vulns are continuously exploited for long periods of time. Some are just a flash in the pan. Exploits of others come in fits and starts. Some real-world examples of these patterns are demonstrated in the chart below, which depicts observed exploitation activity for five CVEs over the course of 2023. #vulnerabilitymanagement #vulnerabilities #vulnerabilityexploitation #cyberattacks

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Incident reporting is really important at all levels. End user self reporting is crucial and often overlooked. https://lnkd.in/dgVj5hZa

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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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As you've probably heard by now, Verizon's 2024 Data Breach Investigations Report (DBIR) just dropped. I'm proud to say that Cyentia Institute was a contributor again this year. I should say "one of the many, many data contributors." I know most people focus on the findings from the DBIR - and they should. But to me, this is the most remarkable and important aspect of the DBIR. I can't think of any other report/project in the #cybersecurity field that can unite all these logos in a common effort of data sharing and analysis. And do it for 15 years! Yes - I know the DBIR first published more than 15 years ago (I was there). But 2010 was the first time we included non-Verizon data from the U.S. Secret Service. That initial step took quite a bit of effort, but then they introduced us to the Dutch High Tech Crime Unit, the Australian Federal Police, London Metropolitan Police...and the dominos kept going. I clearly remember when I got a "yes" from the first private sector IR service provider that was a competitor of Verizon at the time. The execs HATED the idea of sharing the spotlight, but they eventually conceded. And their participation paved the way for all the others you see here. And though I'm no longer leading the DBIR production effort, I'm honored to be one of those logos I started adding so long ago. Also - it's not easy managing all those contributors and datasets. As you review and apply all the insights from this year's DBIR, raise a toast of appreciation to the DBIR team that is dedicated to what they do for the community. Many thanks David Hylender Suzanne Widup Philippe Langlois Alex Pinto #databreaches #cyberrisk

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Continuing the team's video series: compliance control mapping. This approach helps you identify and remediate identities that do not meet the compliance frameworks your organization adheres to. Here’s an example for PCI.

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Sandboxed recommendations that are prioritized by their risk-reduction potential are part of the foundation for strategic and programmatic cyber decisions, such as those made during risk committee meetings. The outcomes of those decisions can either be technically observed (i.e., implemented and validated via integration) or provided via user feedback (i.e., silencing because of control sustainability within a given business environment). The ultimate success story for this type of capability is enabling decision-analysis across business quarters, where three very simple questions can be answered: 1) What have we done? 2) What do we need to do? 3) How are we trending? #pelloniumriskintelligence

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Welcome back/to NIST 800-53 where we're going through every control for simplification and automation ❤️ Let's continue with: AC-02(05) Account Management | INACTIVITY LOGOUT Simply stated, this control requires: - Require that users log out from inactivity in a timeframe that makes sense for the organization How to simplify control implementation: - Map control to any VPN/ZTNA connectivity timeout periods - Leverage potential inheritance from an Identity Provider (IdP) and Identity Management teams (IdP mapping/inheritance will be pretty repetitive for the AC family as a whole) How to automate control implementation & assessment: - Leverage IdP/VPN/ZTNA timeout periods and token invalidation - Run checks/tests to ensure inactivity logouts are in place ⬇️ Tell me what I missed! ⬇️ #GRCEngineering #NIST #NIST80053 #Cybersecurity #ZeroTrust #GRC #AccessControl #Automation #AI #AccountManagement #OSCAL

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During yesterday's monthly The Cyber AB Town Hall, the release of 32 CFR, the #CMMC Program rule, was the big topic of conversation. The published rule will allow C3PAOs to begin performing CMMC L2 assessments as of December 16, 2024. However, the rule also identified a phased rollout that will only require self-assessments in 2025. This has led to a lot of organizations saying they can wait for CMMC until third party assessments are mandated. Eric Crusius joined the Town Hall to provide a lawyer's perspective on the final rule and the phased rollout. Eric pointed out the phased rollout may be more dangerous for organizations by allowing self-assessments. If an organization does not properly perform a self assessment, they become open to the False Claims Act. If they are reported for not conducting the assessment properly, the organization could face hefty penalties and loss of contracts. The final rule also sets a minimum threshold for a CMMC Score. Previously, contract officers determine what #SPRS scores were appropriate for their contract. The final rule requires organizations with CUI to implement a minimum of 80% of the CMMC requirements to pass the assessment and meet the remaining 20% within 180 days of the assessment. Do you need assistance addressing the CMMC requirements? If so, reach out to Optic Cyber Solutions ([email protected]) we're here to help!

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There are several items that are missed on any data security audit. One is the Cybersecurity Risk Management Plan and Assessment. Typically found in only 1% of audits. An Incident Response Plan. Found less than 1% of the time. But almost never found are Data Flow Diagrams. With over 50% of the organization's data on the cloud, without the data flows completed, no one, yes no one in the organization knows where all the PII, PHI, PFI, PCI and other critical data is located. It takes about a month to complete all the data flows for an organization since all the department heads need to share their knowledge. When complete, these secure documents will allow the organization's leaders to strategize how they will protect their data. Without the data flows, many segments of the organization's data are not properly managed or protected. The organization will not have a backup plan if access to these systems is lost. So ID.AM.03 of the NIST Core V2 is a critical data security control. Please download the CSF and do the work that needs to be done to protect your organization.

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