Practices found in CMMC Levels 1-3 called out an aggregated 130 Practices and 51 Processes that lead to Level 3 compliance. Level 4 specifically includes 26 additional technical practices derived from multiple sources such as NIST 800-171, CERT Resilience, CIS Controls v7.1, and more. See the Practices and Processes below:
Scott Edwards, President of Summit 7 and national security/compliance speaker, spoke on the importance of the Incident Response (IR) Domain and stated "Incident Response is something that I almost want to call the core of CMMC Level 4".
AC.4.023: Control Information Flows between security domains on connected systems
AC.4.025: Periodically review and update CUI program access permissions
AC.4.032: Restrict remote network access based on organizationally defined risk factors such as time of day, location of access, physical location, network connection state and measured properties of the current user and role.
AM.4.226: Employ a capability to discover and identify systems with specific component attributes (e.g., firmware level, OS type) within your inventory.
AU.4.053: Automate analysis of audit logs to identify and act on critical indicators (TTPs) and/or organizationally defined suspicious activity
AU.4.054: Review audit information for broad activity in addition to per machine activity.
AT.4.059: Provide awareness training focused on recognizing and responding to threats from social engineering, advanced persistent threat actors, breaches and suspicious behaviors; update the training at least annually or when there are significant changes to the threat.
AT.4.060: Include practical exercises in awareness training that are aligned with current threat scenarios and provide feedback to individuals involved in the training.
CM.4.073: Employ application whitelisting and an application vetting process for systems identified by the organization.
IR.4.100: Use knowledge of attacker tactics, techniques and procedures in incident response planning and execution
IR.4.101: Establish and maintain a security operations center capability that facilitates a 24/7 response capability
RM.4.149: Catalog and periodically update threat profiles and adversary TTPs.
RM.4.148: Develop and update as required, a plan for managing supply chain risks associated with the IT supply chain.
RM.4.150: Employ threat intelligence to inform the development of the system and security architectures, selection of security solutions, monitoring, threat hunting, and response and recovery activities.
RM.4.151: Perform scans for unauthorized ports available across perimeter network boundaries over the organization's Internet network boundaries and other organizationally defined boundaries.
CA.4.163: Create, maintain, and leverage a security strategy and roadmap for organizational cybersecurity improvement.
CA.4.164: Conduct penetration testing periodically, leveraging automated scanning tools and ad hoc using human experts
CA.4.227: Periodically perform red teaming against organizational assets in order to validate defensive capabilities
SA.4.171: Establish and maintain a cyber-threat hunting capability to search for indicators of compromise in organizational systems and detect, track and disrupt threats controls.
SA.4.173: Design network and system security capabilities to leverage, integrate, and share indicators of compromise.
SC.4.197: Employ physical and logical isolation techniques in the system and security architecture and / or where deemed appropriate by the organization.
SC.4.199: Utilize threat intelligence to proactively block DNS requests from reaching malicious domains.
SC.4.228: Isolate administration of organizationally defined high-value critical network components and servers.
SC.4.202: Employ mechanisms to analyze executable code and scripts (e.g., sandbox) traversing Internet network boundaries or other organizationally defined boundaries.
SC.4.229: Utilize a URL categorization service and implement techniques to enforce URL filtering of websites that are not approved by the organization.
SI.4.221: Use threat indicator information relevant to the information and systems being protected and effective mitigations obtained from external organizations to inform intrusion detection and threat hunting
Upon CMMC Level 3 compliance, or the implementation of the appropriate 130 Practices, you'll need to implement the additional 26 shown in the accordion section above.
A few ways to meet new practices and additional resourcing requirements (software, hardware, personnel, outsourcing) are:
For more information on recommendations for remedying these technical practices, watch this clip from the CMMC Level 4 webinar from the Summit 7 Team.
SIEM solutions to meet Incident Response requirements:
Summit 7 Preferred: Microsoft Azure Government Sentinel
Solutions for meeting Incident Response requirements specific to a SOC:
Summit 7 Preferred: Microsoft Azure Sentinel for alerting and Microsoft Cloud Access Security (MCAS) broker for the CASB
Risk Management port scanning solutions:
Summit 7 Preferred: Qualys Vulnerability Management System
Threat indicator and threat hunting subscriptions to meet System and Information Integrity requirements:
Summit 7 Preferred: Microsoft's Azure Sentinel supports input from MISP Project
Summit 7 has architected a solution set to help organizations achieve CMMC Level 4 compliance that is developed for Office 365 GCC High and Azure Government. To discuss with our team and develop your roadmap for Level 4, complete the form below.
Related Pages:
As the image below details, Level 4 requires organizations to practice "Proactive Cyber Hygiene", while having "reviewed" security processes and methods for "reducing risk of Advanced Persistent Threats (APT)s and increasing protection of CUI". For contractors in the DoD, Level 4 compliance may be more uncommon than Level 3, as it will be contractually required far less in RFPs and is seen as more of a transitional step to Level 5. It is also an increase in responsibility and likely cost. Levels are cumulative, meaning a Level 4 certified organization will need to meet the practices found in Levels 1, 2, 3, and 4. Access a more detailed explanation and overview of CMMC, as well as history and background here.
OUSD A&S and the CMMC-Accreditation Body solidified their partnership, November 25, 2020, in signing a No-Cost contract to support this very important mission for our cybersecurity, information security, and thus national security.
If you still have questions about CMMC Level 4, or anything around understanding the Cybersecurity Maturity Model Certification as a whole please do not hesitate to reach out to us.
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