While most of the focus of CMMC is on primary contractors, subcontractors (especially small and mid-sized firms) play an equally critical role in ensuring information security across the supply chain. As such, they are increasingly in the spotlight, both in terms of compliance requirements and as focal points for supply chain risk.

However, their smaller size and limited resources often make them more vulnerable to cyber threats. Attackers have long targeted the weakest links in the supply chain, and subcontractors usually serve as such entry points. The DoD’s implementation of CMMC aims to address this by enforcing standardized cybersecurity practices at every tier of the supply chain.

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FedRAMP, initially established in 2011 to standardize the security authorization of cloud services for federal use, has often been criticized for its complexity and cost. To address these challenges, the FedRAMP Program Management Office launched FedRAMP 20x—a modernization initiative designed to radically transform how cloud service providers achieve and maintain FedRAMP authorization.

FedRAMP 20x represents a strategic pivot toward efficiency, trust, and technological alignment for IT leaders and CSPs navigating the federal cybersecurity landscape.

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Protecting CUI is critical to national security. As adversaries increasingly target the Defense Industrial Base, the Department of Defense has strengthened its approach to cybersecurity compliance through the CMMC. While CMMC does not explicitly create or enforce data governance frameworks, it plays a pivotal role in operationalizing the technical and procedural controls necessary to secure CUI throughout its lifecycle.

This article explores how CMMC intersects with data governance and CUI lifecycle management.

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