Introduction

For federal agencies, compliance frameworks such as the Cybersecurity Maturity Model Certification (CMMC), NIST SP 800-171, and FISMA outline requirements to safeguard federal systems and sensitive data. For US Federal CSIRTs, threat researchers, and threat hunters, these frameworks form the foundation for addressing complex security requirements. However, navigating these standards often reveals a tension between meeting compliance and managing active cyber threats.

This blog explores the essence of compliance, its operational impact, and strategies to align regulatory mandates with actionable cybersecurity practices. Subsequent blogs will explore each framework in depth.

The Compliance Imperative: Foundations of Cybersecurity Standards

Compliance frameworks are designed to establish baseline requirements for protecting sensitive information. For federal entities, key frameworks include:

• NIST SP 800-171 Rev 3:
  
  • Specifies the security requirements for protecting Controlled Unclassified Information (CUI) in non-federal systems, such as those controlled or managed by prime contractors and their subcontractors. Examples of CUI include personally identifiable information (PII), schematics and technical information with military or space applications, financial data and more.This framework now includes 17 families of security requirements, including  access control, incident response, and risk management (NIST SP 800-171 Rev 2).
• CMMC 2.0:
  
  • Introduces a tiered model to assess and certify the cybersecurity maturity of defense contractors and subcontractors. Compliance with CMMC’s Level 2 and Level 3 requirements includes adherence to the 110 security requirements specified in NIST SP 800-171 and Level 3 adds requirements for enhanced protections against Advanced Persistent Threats (APTs) (CMMC Overview).
• FISMA (Federal Information Security Modernization Act):
  
  • Mandates inventories of information systems and their risk levels, annual reviews and reporting on the effectiveness of federal information security programs, and establishes clear responsibilities for agencies to secure their systems (FISMA Overview).

While these frameworks are designed to standardize security measures and minimize vulnerabilities in critical infrastructure, their implementation often creates manually intensive tasks and operational challenges for security teams that are already overburdened.  Let’s take a closer look at what and where. 

Common Challenges in the Compliance Landscape

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Operational Resource Strain

For federal teams, meeting compliance often involves substantial documentation, process alignment, and continuous monitoring. Article 3.12 of NIST SP 800-171, for instance, requires organizations to maintain a robust security assessment process, while Article 3.14 mandates ongoing monitoring of system integrity to identify potential threats, unauthorized connections or users, and detection of unusual activities or conditions..

These requirements can overwhelm teams already managing active incident responses.

Visibility Beyond the Perimeter

Article 3.1.20 of NIST SP 800-171 highlights the need to control external connections and prevent unauthorized access to CUI. An example could be the use of personal devices such as cell phones in commercial or public facilities. Yet, compliance frameworks often overlook external assets or shadow IT environments, leaving critical blind spots in security postures.

Balancing Compliance and Proactive Security

While compliance frameworks provide a foundation, they often lack specificity in how to address evolving cyber threats. For instance, Article 3.6.1 of NIST SP 800-171 focuses on incident response capabilities but does not prescribe proactive measures such as external threat attribution or reconnaissance of threat actor activity.

The size and scope of these requirements still leave a lot of uncertainty, such as which agencies or departments have to comply and to what extent? What is the best way to achieve compliance? What should ongoing monitoring and reporting look like? Who is already successful at this? The truth is, most teams are struggling.

The Cost of Non-Compliance

Failing to meet compliance standards can severely impact Federal Governments ability to service citizens.  This isn’t just a result of significant penalties that are both financial and operational. For example, non-compliance with CMMC’s DFARS Clause 252.204-7012 can disqualify contractors from securing defense contracts, if you have to transfer large scale services from one provider to another the disruption is costly and painful..

Similarly, FISMA non-compliance may lead to loss of funding or public trust in federal systems, potentially impacting the ability to provide the level of service that Federal teams want their citizens to receive.

Beyond these direct consequences, organizations expose themselves to risks of data breaches, and there is also personal reputational damage for those at the helm when a breach or incident occurs. Who is going to take the blame?

What You Can Do Now: Integrate Visibility and Monitoring into Compliance Practices

To bridge the gap between compliance and operational cybersecurity, federal teams can adopting strategies that extend visibility and enhance monitoring capabilities.

These include:

Discovering External Assets

Understanding what assets reside outside the internal perimeter is critical. Compliance mandates like NIST SP 800-171’s Article 3.1.22 emphasize the importance of controlling public information but lack clarity on where this information could be exposed on external attackable surfaces. Automated tools and practices that map external-facing assets and supply chain infrastructure canprovide visibility into potential risks of where sensitive information could be exposed, and allows for processes for remedial action to follow.

Continuous Monitoring and Reporting

Article 3.3 of NIST SP 800-171 requires auditing and accountability measures. Extending these practices to include event logging, real-time monitoring of external threats and automating reporting mechanisms ensures alignment with compliance while addressing active risks and minimizing manual activity.

Threat Attribution and Response

Although compliance mandates incident handling (NIST SP 800-171 Article 3.6), integrating threat attribution enhances an organization’s ability to connect attacks to specific adversaries and their infrastructure. This not only satisfies compliance requirements but also strengthens proactive defenses.  

There are many Team Cymru Customer Case Studies that reference proactive blocking of threat actor infrastructure by using real-time intelligence to dynamically block malicious inbound communications, and prevent outbound connections to C2s for example.

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A Call to Action: Beyond Compliance

Compliance is a critical starting point, but it must be complemented by advanced visibility and proactive threat management. As federal teams navigate frameworks like NIST SP 800-171 and CMMC, integrating practices such as external asset discovery, continuous monitoring, and threat attribution becomes indispensable.

To explore the source regulations mentioned, visit:

• NIST SP 800-171
• CMMC Program Overview
• FISMA Overview

Understanding compliance is only the beginning. Future efforts must focus on turning compliance from a burden into a force multiplier for cybersecurity effectiveness.

Next Steps

If your program or service requires better insights to help proactively defend against nation-state threats, and improve risk management of public and critical infrastructure, reach out to Team Cymru’s own Government Team or email them at federalsales@cymru.com.

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