Skip to content
In December 2024, China’s acknowledged cyberattacks on U.S. infrastructure underscored the escalating threat to the Defense Industrial Base (DIB), amplifying the urgency of the Cybersecurity Maturity Model Certification (CMMC) 2.0. For Department of Defense (DoD) and Intelligence Community (IC) contractors handling Controlled Unclassified Information (CUI), CMMC Level 2’s third-party assessments, starting in Q1 2025, are critical to countering advanced, state-sponsored threats. This blog post examines the nature of these cyberattacks, highlights the role of CMMC 2.0 in strengthening cybersecurity, and provides practical strategies to enhance IT systems, achieve compliance, and protect against Chinese cyber threats.
The Growing Threat of Chinese Cyberattacks
China’s cyberattacks, as reported in December 2024, target critical infrastructure and sensitive data, including CUI held by DoD contractors. These attacks employ sophisticated techniques, such as:
- Advanced Persistent Threats (APTs): Long-term, stealthy intrusions to steal CUI, such as technical designs or operational plans.
- Supply Chain Exploits: Targeting subcontractors or vendors to infiltrate prime contractor networks.
- Phishing and Social Engineering: Tailored attacks to gain unauthorized access to systems handling CUI.
- Zero-Day Exploits: Leveraging unpatched vulnerabilities to bypass defenses and exfiltrate data.
CMMC 2.0’s Level 2 requirements, aligned with 110 NIST SP 800-171 controls, provide a framework to counter these threats through robust cybersecurity measures, verified by Certified Third-Party Assessment Organizations (C3PAOs). With the CMMC final rule effective December 16, 2024, contractors must act swiftly to protect CUI and maintain contract eligibility.
Why CMMC 2.0 Is Essential for Defense
Failing to address Chinese cyberattacks or achieve CMMC 2.0 compliance risks:
- Compromised CUI, undermining national security and mission-critical operations.
- Loss of contracts, as CMMC certification is mandatory at award starting in 2025.
- Supply chain vulnerabilities, as non-compliant contractors weaken the DIB.
- Audit failures, as C3PAOs and DoD auditors scrutinize defenses against advanced threats.
CMMC Level 2’s third-party assessments ensure contractors implement controls to detect, prevent, and respond to state-sponsored cyberattacks, safeguarding the DIB and supporting national defense.
Strategies to Defend Against Cyberattacks with CMMC 2.0
Contractors can enhance cybersecurity, achieve CMMC Level 2 compliance, and counter Chinese cyberattacks with the following strategies, focusing on robust IT systems and NIST SP 800-171 alignment:
1. Assess Threat Detection Needs
Start by evaluating your organization’s ability to detect and respond to advanced cyber threats:
- Map CUI Systems: Identify systems, networks, and applications handling CUI to prioritize monitoring and protection efforts.
- Analyze Threat Vectors: Study recent Chinese cyberattacks (e.g., APTs, phishing) to identify risks like unauthorized access or supply chain exploits.
- Align with NIST Controls: Focus on controls like AU-2 (Audit Events), IR-4 (Incident Handling), and SI-4 (System Monitoring) to guide threat detection planning.
This assessment ensures defenses target the sophisticated tactics used in state-sponsored attacks.
2. Build Secure IT Systems
Robust IT systems are critical to counter cyberattacks and meet CMMC requirements:
- Implement Zero-Trust Architecture: Require continuous verification for users and devices, using MFA and role-based access to meet AC-2 (Account Management) and IA-2 (Identification and Authentication).
- Encrypt Data: Use FIPS 140-2 compliant encryption for CUI at rest and in transit, aligning with MP-1 (Media Protection) to prevent data theft.
- Harden Systems: Apply secure configurations, disable unnecessary services, and use firewalls to comply with CM-6 (Configuration Settings) and reduce attack surfaces.
- Deploy Endpoint Protection: Use antivirus and intrusion detection to detect malware or exploits, supporting SI-3 (Malicious Code Protection).
These measures directly address Chinese cyber tactics like APTs and zero-day exploits.
3. Leverage Microsoft 365 GCC High for Security
Microsoft 365 GCC High, a DoD-compliant cloud platform, enhances defenses against cyberattacks:
- Enable Threat Detection: Use GCC High’s audit logs and security dashboards to monitor for suspicious activity, such as failed logins or unauthorized access, aligning with AU-6 (Audit Review).
- Configure DLP Policies: Prevent CUI leaks with data loss prevention (DLP), meeting SC-7 (Boundary Protection) and MP-1 (Media Protection).
- Secure Collaboration: Restrict Teams and OneDrive sharing to authorized users, protecting CUI during workflows and complying with AC-3 (Access Enforcement).
- Automate Alerts: Set up real-time notifications for policy violations or anomalies to enable rapid response, supporting IR-4 (Incident Handling).
GCC High simplifies compliance with multiple NIST controls while countering cyber threats.
4. Refine Incident Response Plans
Effective incident response is critical for CMMC 2.0 and the 72-hour reporting mandate in the August 2024 DFARS rule:
- Define Workflows: Establish procedures for detecting, analyzing, containing, and reporting incidents within 72 hours, using the DoD’s DIBCS portal, per IR-6 (Incident Reporting).
- Test Plans: Conduct tabletop exercises to simulate Chinese cyberattacks, such as phishing or APTs, ensuring rapid response and compliance with IR-2 (Incident Response).
- Automate Detection: Use SIEM tools or GCC High alerts to identify incidents quickly, minimizing response time and meeting IR-4 (Incident Handling).
- Document Responses: Maintain records of incidents and actions taken as evidence for C3PAO assessments, supporting AU-3 (Content of Audit Records).
A refined incident response plan ensures timely reporting and resilience against attacks.
5. Document Compliance with SSPs and POA&Ms
Comprehensive documentation demonstrates CMMC 2.0 compliance and cybersecurity readiness:
- System Security Plan (SSP): Detail how NIST controls are implemented, including threat detection tools, encryption, and incident response workflows, per RA-2 (Security Categorization).
- Plan of Action and Milestones (POA&M): List any control gaps, such as incomplete monitoring or weak endpoint protection, with remediation steps and deadlines.
- Organize Evidence: Collect logs, configuration screenshots, and incident response records for C3PAO review, ensuring accessibility and accuracy.
- Update Regularly: Revise documentation to reflect system changes or new threats, maintaining audit readiness.
Clear documentation proves defenses are robust and compliant.
6. Implement Managed IT for Continuous Protection
Managed IT practices sustain cybersecurity and compliance, countering ongoing threats:
- Monitor Continuously: Use SIEM or GCC High tools to track threats in real time, supporting SI-4 (System Monitoring) and AU-6 (Audit Review).
- Patch Promptly: Apply updates to close vulnerabilities exploited by Chinese cyberattacks, aligning with SI-2 (Flaw Remediation).
- Secure Backups: Store encrypted CUI backups in compliant environments, meeting MP-4 (Media Storage) for recovery from attacks.
- Train Staff: Educate employees on recognizing phishing or social engineering, complying with AT-2 (Security Awareness) to reduce human-centric risks.
These practices ensure systems remain secure and audit-ready.
7. Prepare for CMMC Level 2 Assessments
Third-party assessments, starting in Q1 2025, verify defenses against cyberattacks:
- Conduct Mock Audits: Test systems and documentation against NIST SP 800-171 controls, focusing on threat detection, incident response, and encryption.
- Compile Evidence: Organize SSPs, POA&Ms, logs, and records to demonstrate compliance with controls like IR-6, AU-2, and SC-7.
- Train Teams: Prepare IT and compliance staff to explain cybersecurity measures and incident response processes to C3PAOs.
- Remediate Gaps: Fix issues identified in mock audits, such as incomplete logs or weak configurations, to ensure certification success.
Proactive preparation ensures contractors pass assessments and maintain contract eligibility.
Looking Ahead: Cyber Threats and CMMC 2.0 in 2025
As Chinese cyberattacks intensify, contractors should anticipate:
- Stricter DoD Oversight: Assessments and audits will focus on defenses against state-sponsored threats, emphasizing rapid incident response.
- Supply Chain Scrutiny: Prime contractors will require subcontractor compliance to protect interconnected systems from Chinese exploits.
- Evolving Attack Techniques: AI-driven phishing and advanced APTs will demand robust, adaptive cybersecurity measures.
Early preparation for CMMC 2.0 positions contractors to counter these challenges effectively.
Conclusion
China’s December 2024 cyberattacks on U.S. infrastructure highlight the critical need for DoD/IC contractors to strengthen cybersecurity through CMMC 2.0. By assessing threat detection needs, building secure systems, leveraging Microsoft 365 GCC High, refining incident response, and preparing for assessments, contractors can achieve Level 2 compliance and defend against state-sponsored threats. These strategies not only ensure certification but also protect CUI, bolster national security, and maintain competitiveness in a high-threat DIB landscape.
