Mar 20, 2025 | Kate Rode
Cybersecurity threats and awareness are at an all-time high. IT compliance audits play a critical role in ensuring that organizations meet regulatory requirements and protect sensitive information; this is the baseline from which cybersecurity programs should be built. Businesses working with the Department of Defense (DoD) and other government entities must adhere to frameworks like NIST 800-171 and CMMC certification to maintain cybersecurity compliance and continue operations. Still, all organizations can benefit greatly from adhering to these principles.
Overview of NIST 800-171 and CMMC Compliance Requirements
The National Institute of Standards and Technology (NIST) 800-171 publication outlines security requirements for federal agencies to protect the confidentiality of Controlled Unclassified Information (CUI) in nonfederal systems. It applies to components that process, store, or transmit CUI or systems that protect such components. Similarly, the Cybersecurity Maturity Model Certification (CMMC) builds on these requirements, ensuring that defense contractors meet varying levels of compliance readiness.
Organizations must follow a structured audit checklist to ensure they meet IT governance standards and regulatory requirements. Key areas include risk assessment, security controls, and employee awareness training.
Pre-Audit Preparation: Gathering Required Documentation and Policies
The initial steps to success during a compliance audit will be ensuring all of the pre-audit preparation is completed. Organizations must ensure they have documented security measures, policies, and procedures in place to meet the framework’s requirements. Here are some recommendations to help properly prepare for an audit:
Review and Update Security Policies and Procedures
These are some of the primary areas to focus on when preparing for the NIST 800-171 Compliance audit.
- Access control – Ensuring only authorized users can access Controlled Unclassified Information (CUI).
- Incident response – Defining how the organization will detect, respond to, and recover from security incidents.
- Data protection – Implementing encryption, secure storage, and transmission protocols for CUI.
- User authentication – Requiring strong passwords and multi-factor authentication (MFA) for system access.
Ensure Clear Documentation of Access Controls and Network Security Measures
To comply with NIST 800-171, businesses must establish strict access controls and document how they protect CUI. This includes:
- Maintaining identity and access management (IAM) records to track who has access to sensitive data.
- Maintaining role-based access control (RBAC) to enforce the principle of least privilege.
- Deployment of firewalls, intrusion detection systems (IDS), and endpoint security solutions.
Maintain Records of Previous Risk Assessments and Internal Audits
A strong compliance program includes continuous assessment and improvement. Organizations should:
- Maintain detailed records of risk assessments that evaluate vulnerabilities and threats to CUI.
- Execute internal audits to help identify any gaps in compliance and remediate them before an official audit.
- Document remediation actions taken to strengthen security controls and ensure ongoing compliance.
Ensuring Data Encryption and Secure Storage Meet NIST 800-171 Standards
Protecting Controlled Unclassified Information (CUI) is a fundamental requirement of NIST 800-171, and encryption plays a critical role in securing sensitive data. Organizations must implement encryption mechanisms and secure storage solutions that align with regulatory requirements to prevent unauthorized access, breaches, and data loss.
Encrypt Sensitive Data at Rest and in Transit
Using proper encryption techniques ensures that even if data is compromised, it is indecipherable without the encryption key. Organizations must:
- Encrypt data at rest using AES-256 encryption or other FIPS 140-2 validated* cryptographic modules to protect CUI stored on servers, databases, and removable media.
- Encrypt data in transit using TLS 1.2 or higher, this ensures that network communications over the internet are secure.
- Ensure end-to-end encryption for sensitive information transmitted between users, devices, and cloud services.
- Keep encryption protocols up to date to ensure protection against new and emerging threats.
*Important note:
“FIPS-compliant” is often assumed to be the same as “FIPS-validated,” but that is not the case. To be certified as “FIPS-validated” a product’s hardware AND associated software/firmware has undergone rigorous testing by a NIST-approved testing vendor. Once validated, the hardware and associated software/firmware will appear on the NIST Cryptographic Module Validation Program (CMVP). FIPS-compliant is typically used by manufacturers to inform users they consider their product to be compliant to FIPS 140-2 standards. For help with finding FIPS 140-2 approved software and hardware, contact Layer8 for a consultation.
Employee Training and Security Awareness for CMMC Readiness
Conduct Regular Security Awareness Training
Organizations should develop a comprehensive and ongoing security awareness training program that includes:
- Mandatory training sessions for all employees handling sensitive data, including onboarding and annual refreshers.
- Interactive training modules that simulate real-world cyber threats, such as phishing, social engineering, and insider threats.
- Role-specific training for employees based on their access to CUI and level of responsibility in securing systems.
- Policy and procedure training to ensure employees understand company security policies and procedures. Employees need to understand how the compliance objectives affect their use of the organization’s systems..
Provide Guidelines for Securely Handling and Sharing Sensitive Information
Improper handling of Controlled Unclassified Information (CUI) can lead to compliance violations. To mitigate risks, organizations must:
- Enforce guidelines on data categorization and verify that employees understand how to label, store, and transmit sensitive data securely.
- Utilize secure file sharing protocols and procedures, like the use of encrypted email services, secure collaboration tools, and access controls.
- Enforce the principle of least privilege to ensure employees only have access to the data necessary for their job functions.
- Establish data retention and disposal policies that require employees to securely delete or archive information according to compliance standards.
Conducting Internal Risk Assessments and Mock Audits
Test Security Policies and Incident Response Effectiveness
A critical aspect of compliance audits is demonstrating that an organization’s security policies and incident response plans are effective. Internal risk assessments and mock audits should include:
- Simulating cybersecurity incidents, such as a ransomware attack or unauthorized access attempt, to test the organization’s ability to detect, respond, and recover from threats.
- Ensuring that the incident response team (IRT) follows established procedures, including reporting incidents, containing threats, and mitigating damages.
- Testing data encryption and secure storage measures to confirm that CUI remains protected in the event of a cyberattack or data breach.
- Assessing backup and disaster recovery strategies to verify that critical data can be restored without compromise.
- Reviewing security awareness training effectiveness by testing employees’ responses to phishing simulations and social engineering attacks.
Ensure Corrective Actions Are in Place to Address Vulnerabilities
Once compliance gaps and security weaknesses are identified, organizations must take continuous corrective actions to strengthen their security posture. A vulnerability management program is essential for compliance. Key concepts include:
- Prioritizing remediation efforts based on the severity of identified risks, addressing high-risk vulnerabilities first.
- Updating security policies and procedures to reflect new controls or compliance requirements.
- Implementing technical security enhancements, such as stronger encryption protocols, improved firewall configurations, or additional access controls.
- Conducting follow-up risk assessments to ensure that corrective actions have been effectively implemented.
How Layer 8 Consulting Can Help with NIST 800-171 and CMMC Compliance
At Layer8 Consulting, we specialize in helping businesses navigate NIST 800-171 requirements and CMMC certification. Our team provides:
- Comprehensive IT compliance audits.
- Customized security policies and risk assessment strategies.
- Employee training programs for cybersecurity compliance.
- Ongoing monitoring and compliance maintenance.
Ensuring compliance with NIST 800-171 and CMMC requires a proactive approach. Partnering with experienced IT professionals can streamline the process, mitigate risks, and ensure long-term security.
Ready to start your compliance and readiness journey? Contact Layer8 Consulting today!
