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Mitigating Risk in DFARS CUI/CMMC Compliance: What Primes Need to Know

  • Writer: Jill Lawson
    Jill Lawson
  • Jun 13
  • 1 min read

Updated: Jun 24

The DoD’s supply chain is under constant threat of CUI exfiltration—daily, hourly, and even momentarily. This document provides a detailed overview of the risks and mitigation strategies associated with Controlled Unclassified Information (CUI) in Department of Defense (DoD) supply chains.



Technical Risk

Self-assessments pose significant risks. Assessors may misinterpret the DoD Assessment Methodology, assign overly favorable scores, or exploit the lack of oversight. While oversight may be limited, accountability remains—especially if deliverables are compromised or data is exfiltrated.


Financial Risk

The Prime Contractor bears the risk associated with CUI compliance throughout the supply chain. Financial penalties and loss of contracts are potential consequences of non-compliance.


Reputational Risk

Non-compliance with the flow-down CUI regulations can damage the reputation of the Prime Contractor. This can lead to loss of trust and future business opportunities.


Mitigation Strategies

To mitigate these risks, Prime Contractors should consider the following strategies: - Implement shared CUI Enclaves to centralize and secure CUI. - Standardize the use of CMMC consultants and assessments to ensure consistent compliance. - Regularly review and update compliance protocols to adapt to evolving threats.


Conclusion

In conclusion, the DoD’s supply chain faces significant risks related to CUI compliance. By understanding these risks and implementing effective mitigation strategies, Prime Contractors can protect their financial interests and maintain their reputation. Learn how to streamline your compliance strategy and reduce costs—contact us for more information.


For more insights on mitigating supply chain costs and compliance risk, don’t hesitate to get in touch with Reach’s CMMC Director.



Jill Lawson

Retired DAWIA LVL 3 PM, RP, CCP, CCA

 
 
 

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