Why Risk Reduction Matters for Compliance

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Federal cybersecurity has long since moved beyond compliance for its own sake. Still,  one of the most persistent and dangerous mistakes organizations continue to make is equating compliance with security.

This article repeats a common message that we’ve been hammering home for years: that risk reduction, not box-checking, must be the organizing principle of modern cybersecurity programs, particularly for organizations operating in regulated or government-adjacent environments.

 

Compliance Was Never Meant to Be the Finish Line

Frameworks such as NIST SP 800-171, NIST SP 800-53, FedRAMP, and CMMC were never designed to guarantee security. They were intended to establish minimum acceptable practices that, when implemented correctly, reduce the likelihood and impact of cyber incidents.

Over time, however, many organizations have inverted that intent. Controls are implemented to satisfy auditors, and documentation is compiled during audits rather than maintained as primary risk and security documents. 

As a result, security teams are rewarded for “passing” rather than for preventing incidents. This mindset creates a false sense of confidence. An organization may be compliant on paper while remaining dangerously exposed in practice.

A recent podcast on The Federal News Network captures this tension well. Compliance attorney Townsend Bourne notes that absolute risk reduction often occurs only after an incident, investigation, or enforcement action. 

 

Why Box-Checking Persists Despite Its Failures

So, if just checking boxes isn’t effective, why do we still see businesses pursue this approach?

  • Compliance frameworks are easier than risk management. Compliance is straightforward to document. Risk reduction, however, is contextual, continuous, and harder to measure.
  • Many companies still separate “compliance” from “security,” treating the former as a governance exercise and the latter as a technical function. This division encourages superficial alignment rather than integrated decision-making.
  • Smaller contractors often struggle with the cost of compliance initiatives. We recently addressed cost estimates for CMMC compliance, and adding more seems entirely out of the question. The problem is that while cutting corners can be tempting, it will lead to greater security risks over time. 

A compliance-only approach only shifts risk downstream, however, where it reemerges as incident response costs, contract termination, litigation, or reputational damage.

 

How Is Risk Management Unique from Compliance?

A blue key inserted into a loc on a shield symbol.

There’s a bit of a cliche about compliance being more tangible and risk management being more abstract. This isn’t the case, especially with many modern frameworks incorporating risk into assessments. The difference you’ll see will largely depend on how well you understand your IT and data resources. 

  1. Risk-focused organizations understand where their sensitive data lives, how it moves, and who can access it. This sounds obvious, yet Bourne highlights in the podcast that many contractors struggle to identify federal contract information in their environments. Controls applied without data awareness are inherently fragile.
  2. Risk-oriented teams prioritize controls based on threat relevance rather than audit relevance. They invest more heavily in identity security, access control, monitoring, and incident response because those areas consistently drive breach impact.
  3. Risk reduction emphasizes operational validation. Controls are tested in real scenarios, not just reviewed during annual assessments. This can mean reviewing logs, conducting pen tests, or running ongoing scans and tests in real-world configurations.
  4. Risk-focused organizations treat documentation as a living system. Policies, system security plans, and procedures reflect reality rather than aspirational diagrams created for assessors. This alignment becomes critical during investigations, when discrepancies between documentation and practice can undermine credibility.

 

How Does Risk-First Security Impact You, Outside of Compliance?

One of the most critical insights from the podcast discussion is that auditors distinguish between going through the motions and truly addressing risk. They take this into account during assessments. Regulators increasingly differentiate between organizations that focus on risk and those that make no move to do so. Compliance checklists don’t support most approaches here, and a lack of risk management can signal bad-faith attempts to avoid required risk assessments. 

On the other hand, a risk-reduction approach produces a defensible narrative. It shows that leadership understood tradeoffs, allocated resources deliberately, and continuously improved posture over time. Even when incidents happen, this narrative can significantly influence outcomes.

A common misconception, one that can cause some issues with compliance, is that advocating for risk reduction means dismissing compliance frameworks. This isn’t true:

  • Frameworks like CMMC and FedRAMP are valuable precisely because they encode decades of lessons about what matters in security. This includes risk management. However, if you’re focused on the letter of the law, rather than the spirit, you’ll miss out on insights buried in compliance and guidance documentation.
  • Accordingly, a mature security program uses compliance requirements as inputs into a broader risk model. Controls are mapped to threats, business processes, and mission impact. Gaps are evaluated based on likelihood and consequence, not just assessment scores.
  • Ultimately, passing an audit is about following best practices day-to-day. Security comes first, compliance follows, and outcomes improve because they are based on addressing real-world threats rather than relying on a spreadsheet. 

 

The Culture of Risk-First Security

For better or for worse, the move to risk-first security is primarily about your company’s culture. There are two approaches to addressing culture: first, promote and prioritize risk management across your IT and security teams. Second, work with experienced partners and service providers who understand the importance of risk management.

The podcast hints at this shift when discussing organizations that go beyond regulatory minimums, performing routine tasks such as tightening data-sharing rules, restricting overseas access, and scrutinizing supply-chain relationships even when not explicitly required. These behaviors reflect a mindset change, not just a policy update.

 

Lazarus Alliance: Risk Reduction as a Competitive Advantage

In 2025 and beyond, organizations that want to survive—and thrive—must stop treating cybersecurity as a checklist exercise and start treating it as what it has always been: a continuous effort to reduce real-world risk in an imperfect, adversarial environment.

Organizations that embrace automation and AI-driven defense will be better prepared. Those that rely on legacy, reactive models will struggle to keep up with threats moving at machine speed.

To learn more about how Lazarus Alliance can help, contact us

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