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Taking CMMC Seriously:
What is the Cost of
Compliance?
September, 19, 2023
Welcome!
Bill Wootton
Chief Revenue Officer
C3 Integrated Solutions
bwootton@C3isit.com
© 2023 C3 Integrated Solutions. All Rights Reserved.
3
Today’s Topics
▸Overview: Major Components of the Cost of CMMC
▸Building a Strategy
▸Deployment
▸Management and Monitoring
▸Compliance
▸Data Enclaves: Options and Impact
▸Three Types of Companies
Building a Strategy
© 2023 C3 Integrated Solutions. All Rights Reserved.
5
Building Your CMMC Strategy
Understanding
your business
Setting the
system
boundary
Determining the
organizational
impact
Determining
the expertise
you need
© 2023 C3 Integrated Solutions. All Rights Reserved.
6
Understanding Your Business
External Factors Internal Factors
▸ Your Customers…
▸ Which agencies do you work with?
▸ Your Partners…
▸ Who are your primes and subs?
▸ What are THEIR requirements to continue
working with them?
▸ Your Contracts…
▸ What clauses are already in your contracts?
▸ Your Future…
▸ Where will your business be in 2-3 years?
▸ Your Data…
▸ Do you have CUI?
▸ Do you have export-controlled data?
▸ Can you segment it from the rest of the
organization?
▸ Your People…
▸ Who directly interacts with CUI
▸ Who indirectly interacts with CUI?
▸ Your Systems…
▸ Which systems store, process, or transit
data?
The better you know your business, the less you will need a consultant to answer these questions.
© 2023 C3 Integrated Solutions. All Rights Reserved.
7
Company Examples: All 100-Person Firms
Research Firm
• Almost all commercial work
• Single DoD contract
• Team segmented from rest
of the firm
Manufacturing Firm
• Approximately 90% DoD
work
• Highly customized parts for
aircraft
• Large amounts of export-
controlled data
Professional Services
• Many distributed contracts
• Team members rotate
between DoD and civilian work
regularly
• Centralized admin supports all
contracts
Current systems are not compliant. No preexisting certifications (e.g. ISO
9001)
© 2023 C3 Integrated Solutions. All Rights Reserved.
8
Employee Access to CUI (100-person
Company)
????????
90 People 10 people
90 People
10 people
Commercial
Within CUI Boundary
Company 1 – Research
Firm
Company 3 – Professional Services Firm
Company 2 – Manufacturing Firm
© 2023 C3 Integrated Solutions. All Rights Reserved.
9
Determining System Boundaries: Enclave or
All-In?
ENCLAVE
Separate environment isolated
from the corporate environment
ALL-IN
Full configuration of corporate
environment to meet CMMC
requirements
Pros
▸ Reduced investment and scope
▸ Smaller attack surface
▸ More controlled system
boundary
▸ Limited (if any) data migration
Cons
▸ Swivel-seat user impact
▸ Illusion of cost savings
▸ Dual administration
▸ Unintended spillage
Pros
▸ Single, consolidated
environment
▸ Eliminates all technical debt
(fresh start)
Cons
▸ Data migration
▸ User impact
▸ Higher deployment costs
▸ Everyone is “locked down”
▸ Non-approved applications
© 2023 C3 Integrated Solutions. All Rights Reserved.
10
Enclave or All-In?
????????
90 People 10 people
90 People
10 people
Commercial
Within CUI Boundary
Company 1 – Research
Firm
Company 3 – Professional
Services
Company 2 - Manufacturing
Enclave
????
All-in
© 2023 C3 Integrated Solutions. All Rights Reserved.
11
Cost Drivers in Building a Strategy
Drivers Costs
▸ Knowledge of business
▸ Knowledge of data
▸ Current situation
▸ Technical debt
▸ Documentation
▸ Previous investment
▸ Internal resources
▸ Expertise/knowledge
▸ Availability
▸ Direct costs
▸ Outside consultant
▸ Internal effort
▸ Indirect costs
▸ Organization impact beyond IT
⁃ Business process changes
⁃ Segmenting and isolating data in an
enclave
▸ Impact of Strategy
⁃ Determines cost of the rest of the
process
▸ Confidence
▸ Risk of pursuing the wrong approach
Strategy costs are
not directly related to
the size of the
company. In most
cases, the scope of
effort drives the cost
profile.
Deployment
© 2023 C3 Integrated Solutions. All Rights Reserved.
13
Setting the System Boundary
System Boundary System Selection
• Communications
• E-mail
• Unified communications
• Collaboration
• Documents
• Other data
• CRM
• Financial
• Operational technology
• Access
• Virtual desktop
• Physical devices
• Mobile devices
• Cloud v. on-premises
• FedRAMP
• Export control
• US data residency
• US persons
Minimizing the
system boundary
reduces the services
that need to be fully
compliant
© 2023 C3 Integrated Solutions. All Rights Reserved.
14
Technology Costs
▸System selection
criteria
▸Accreditations
▸Attestations
▸Export control
▸GovCloud is
typically at least
30% higher
Commercial GCC GCC High
Data Centers Worldwide US Only US only
Accreditation FedRAMP
Moderate*
FedRAMP
Moderate
FedRAMP High
DFARS 7012 No Yes Yes
ITAR/EAR No No Yes
CUI/CDI No Maybe Yes
Customer
Support
Worldwide/Commercial
Personnel
Directory/Nt
k Azure Commercial Azure Gov
M365 G5
($/yr) $684 $684 $1120
Source: Understanding Compliance Between Microsoft 365 Commercial, GCC, GCC-High and DoD Offerings - Microsoft Community Hub
Microsoft 365 Example
Critical to choose the right systems that are accredited and can attest to requirements
© 2023 C3 Integrated Solutions. All Rights Reserved.
15
Deployment Costs
▸Provisioning
▸Establish the tenant
▸Configure
▸Should align to NIST SP 800-171
▸Data migration
▸Proportional to the size of the company
▸Microsoft 365 examples
⁃ Mailboxes
⁃ Teams and SharePoint
• Complexity – Workflows, etc.
Management and
Monitoring
© 2023 C3 Integrated Solutions. All Rights Reserved.
17
Management
Standard Services Compliant Services
▸ System administration
▸ Operational monitoring
▸ Patch management
▸ Support Desk
▸ Moves, adds, changes
▸ Documentation
▸ SLA
▸ SRM
▸ Standardized
procedures
▸ Configuration updates
▸ System reviews
▸ Support for GRC tool
▸ Assessment support
▸ U.S. based
If your corporate IT or
current MSP provider
cannot support
requirements (i.e. US
person only support),
an MSP specializing in
the DIB should be
considered.
© 2023 C3 Integrated Solutions. All Rights Reserved.
18
Monitoring – What to look for
▸ Automation
▸ Export control
▸ 24x7
▸ Documentation
▸SLA
▸SRM
▸IR Plan
▸ Assessment support
▸ Incident response
▸ Certifications
▸SOC-2
▸ Vulnerability scanning
Costs vary widely
depending on the
level of services and
the sophistication of
the solution.
Compliance
© 2023 C3 Integrated Solutions. All Rights Reserved.
20
Cost of Managing Compliance
Initial Costs Ongoing Costs
▸ Pre-assessment review
▸ Documentation
development
▸ System Security Plan (SSP)
▸ Policies
▸ Procedures
▸ Incident response plan
▸ Initial assessment
▸ Gap analysis
▸ POAM development
▸ Initial table-top
▸ Documentation
▸ Management and upkeep
▸ Integration with services?
▸ Assessment support
▸ Annual validations
▸ Table-top
▸ GRC tool
▸ Licensing
▸ Information upkeep
▸ Ad hoc consulting
Compliance costs have a
minimum threshold where
certain activities (i.e.
assessment) are required
regardless of company
size.
Back to Our Examples…
Numbers provided are for illustration purposes only.
© 2023 C3 Integrated Solutions. All Rights Reserved.
22
Cost Profile
Considerations
▸ Commercial v. GCCH M365
▸ IT support costs
▸ Monitoring costs
▸ Users swivel seat
▸ Double count users across both
environments
Not considered
▸ Additional applications
▸ Intangibles
▸User frustration
▸Overhead and administration of multiple
environments
Corporate Government
Microsoft
365
Commercial M365 G5
$57/month
GCC High M365
G5
$1120/year
IT Support
Internal
$150 month
equivalent
Outsourced
$200/month
Monitoring
Commercial Grade
$26/endpoint
Compliant
$35/endpoint
Strategy, deployment and cost of compliance
assumed comparable across examples unless noted.
© 2023 C3 Integrated Solutions. All Rights Reserved.
23
Pre-CMMC Annual IT Budget
▸M365 Commercial
▸G5 license
▸100 users
▸IT Support
▸$150/user cost of operation
▸May be internal or external
▸Monitoring
▸“Commercial grade”
▸$26/endpoint
▸Assume 100 endpoints
▸Annual budget: $279,600
$68,400
$180,00
0
$31,200
$-
$50,000
$100,000
$150,000
$200,000
$250,000
$300,000
Corporate
M365 IT Support Monitoring
© 2023 C3 Integrated Solutions. All Rights Reserved.
24
Company 1: Research Firm
▸GCC High enclave
▸10 users, M365 G5
▸Azure Virtual Desktop
▸User access
▸No additional applications
▸$2000/month usage
▸IT Support
▸$200/user, External vendor
▸Monitoring
▸$35/endpoint (virtual)
▸Total Budget: $343,700
$279,60
0
$64,100
$-
$50,000
$100,000
$150,000
$200,000
$250,000
$300,000
$350,000
$400,000
Annual Budget
Corporate Enclave
© 2023 C3 Integrated Solutions. All Rights Reserved.
25
Company 2: Manufacturing Firm
▸All-In
▸Microsoft 365 GCC High
▸100 users
▸Azure Virtual Desktop
▸Not required
▸Endpoints converted
▸IT Support
▸$200/user
▸External vendor
▸Monitoring
▸$35/endpoint (virtual)
▸Migration costs not considered
▸Total Budget: $401,000
$119,00
0
$240,00
0
$42,000
$-
$50,000
$100,000
$150,000
$200,000
$250,000
$300,000
$350,000
$400,000
$450,000
All-In
M365 IT Support Monitoring
© 2023 C3 Integrated Solutions. All Rights Reserved.
26
Company 3: Professional Services
▸ All-in or Enclave?
▸ Likely the most expensive from a
strategy development perspective
▸ Escalating commitment as users
are added
▸ Increased risk of unintended
spillage
▸ Increased user frustration and
confusion
▸ Break even to go all-in just under
30 users
* Does not consider other applications
nor strain of managing multiple
environments for both IT and users
$-
$100,000
$200,000
$300,000
$400,000
$500,000
$600,000
$700,000
$800,000
0 10 20 30 40 50 60 70 80 90 100
Commerical GCCH Enclave All-In
© 2023 C3 Integrated Solutions. All Rights Reserved.
27
About C3 Integrated Solutions
Technology
Experience
11 years Microsoft partner
6+ years experience in GCC
High
Multiple Gold competencies
Co-Sell Authorized
Client Experience
450+ Microsoft 365 clients
200+ GCC High clients
Deep NIST, DFARS, ITAR
experience
Industry Leader
First to offer GCC High
backup and hosted voice
CMMC Registered
Practitioner Organization
Two successful C3PAO
clients
Wrap-up and Questions
Get Started
Build the barriers that
protect your business,
not disrupt it.
Our mission is to protect sensitive data and prevent breaches by providing world-class
cybersecurity and compliance services to businesses of all sizes.
visit
c3isit.com

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SPONSORED CONTENT: Taking CMMC Seriously - What Is The Cost Of Compliance?

  • 1. Taking CMMC Seriously: What is the Cost of Compliance? September, 19, 2023
  • 2. Welcome! Bill Wootton Chief Revenue Officer C3 Integrated Solutions bwootton@C3isit.com
  • 3. © 2023 C3 Integrated Solutions. All Rights Reserved. 3 Today’s Topics ▸Overview: Major Components of the Cost of CMMC ▸Building a Strategy ▸Deployment ▸Management and Monitoring ▸Compliance ▸Data Enclaves: Options and Impact ▸Three Types of Companies
  • 5. © 2023 C3 Integrated Solutions. All Rights Reserved. 5 Building Your CMMC Strategy Understanding your business Setting the system boundary Determining the organizational impact Determining the expertise you need
  • 6. © 2023 C3 Integrated Solutions. All Rights Reserved. 6 Understanding Your Business External Factors Internal Factors ▸ Your Customers… ▸ Which agencies do you work with? ▸ Your Partners… ▸ Who are your primes and subs? ▸ What are THEIR requirements to continue working with them? ▸ Your Contracts… ▸ What clauses are already in your contracts? ▸ Your Future… ▸ Where will your business be in 2-3 years? ▸ Your Data… ▸ Do you have CUI? ▸ Do you have export-controlled data? ▸ Can you segment it from the rest of the organization? ▸ Your People… ▸ Who directly interacts with CUI ▸ Who indirectly interacts with CUI? ▸ Your Systems… ▸ Which systems store, process, or transit data? The better you know your business, the less you will need a consultant to answer these questions.
  • 7. © 2023 C3 Integrated Solutions. All Rights Reserved. 7 Company Examples: All 100-Person Firms Research Firm • Almost all commercial work • Single DoD contract • Team segmented from rest of the firm Manufacturing Firm • Approximately 90% DoD work • Highly customized parts for aircraft • Large amounts of export- controlled data Professional Services • Many distributed contracts • Team members rotate between DoD and civilian work regularly • Centralized admin supports all contracts Current systems are not compliant. No preexisting certifications (e.g. ISO 9001)
  • 8. © 2023 C3 Integrated Solutions. All Rights Reserved. 8 Employee Access to CUI (100-person Company) ???????? 90 People 10 people 90 People 10 people Commercial Within CUI Boundary Company 1 – Research Firm Company 3 – Professional Services Firm Company 2 – Manufacturing Firm
  • 9. © 2023 C3 Integrated Solutions. All Rights Reserved. 9 Determining System Boundaries: Enclave or All-In? ENCLAVE Separate environment isolated from the corporate environment ALL-IN Full configuration of corporate environment to meet CMMC requirements Pros ▸ Reduced investment and scope ▸ Smaller attack surface ▸ More controlled system boundary ▸ Limited (if any) data migration Cons ▸ Swivel-seat user impact ▸ Illusion of cost savings ▸ Dual administration ▸ Unintended spillage Pros ▸ Single, consolidated environment ▸ Eliminates all technical debt (fresh start) Cons ▸ Data migration ▸ User impact ▸ Higher deployment costs ▸ Everyone is “locked down” ▸ Non-approved applications
  • 10. © 2023 C3 Integrated Solutions. All Rights Reserved. 10 Enclave or All-In? ???????? 90 People 10 people 90 People 10 people Commercial Within CUI Boundary Company 1 – Research Firm Company 3 – Professional Services Company 2 - Manufacturing Enclave ???? All-in
  • 11. © 2023 C3 Integrated Solutions. All Rights Reserved. 11 Cost Drivers in Building a Strategy Drivers Costs ▸ Knowledge of business ▸ Knowledge of data ▸ Current situation ▸ Technical debt ▸ Documentation ▸ Previous investment ▸ Internal resources ▸ Expertise/knowledge ▸ Availability ▸ Direct costs ▸ Outside consultant ▸ Internal effort ▸ Indirect costs ▸ Organization impact beyond IT ⁃ Business process changes ⁃ Segmenting and isolating data in an enclave ▸ Impact of Strategy ⁃ Determines cost of the rest of the process ▸ Confidence ▸ Risk of pursuing the wrong approach Strategy costs are not directly related to the size of the company. In most cases, the scope of effort drives the cost profile.
  • 13. © 2023 C3 Integrated Solutions. All Rights Reserved. 13 Setting the System Boundary System Boundary System Selection • Communications • E-mail • Unified communications • Collaboration • Documents • Other data • CRM • Financial • Operational technology • Access • Virtual desktop • Physical devices • Mobile devices • Cloud v. on-premises • FedRAMP • Export control • US data residency • US persons Minimizing the system boundary reduces the services that need to be fully compliant
  • 14. © 2023 C3 Integrated Solutions. All Rights Reserved. 14 Technology Costs ▸System selection criteria ▸Accreditations ▸Attestations ▸Export control ▸GovCloud is typically at least 30% higher Commercial GCC GCC High Data Centers Worldwide US Only US only Accreditation FedRAMP Moderate* FedRAMP Moderate FedRAMP High DFARS 7012 No Yes Yes ITAR/EAR No No Yes CUI/CDI No Maybe Yes Customer Support Worldwide/Commercial Personnel Directory/Nt k Azure Commercial Azure Gov M365 G5 ($/yr) $684 $684 $1120 Source: Understanding Compliance Between Microsoft 365 Commercial, GCC, GCC-High and DoD Offerings - Microsoft Community Hub Microsoft 365 Example Critical to choose the right systems that are accredited and can attest to requirements
  • 15. © 2023 C3 Integrated Solutions. All Rights Reserved. 15 Deployment Costs ▸Provisioning ▸Establish the tenant ▸Configure ▸Should align to NIST SP 800-171 ▸Data migration ▸Proportional to the size of the company ▸Microsoft 365 examples ⁃ Mailboxes ⁃ Teams and SharePoint • Complexity – Workflows, etc.
  • 17. © 2023 C3 Integrated Solutions. All Rights Reserved. 17 Management Standard Services Compliant Services ▸ System administration ▸ Operational monitoring ▸ Patch management ▸ Support Desk ▸ Moves, adds, changes ▸ Documentation ▸ SLA ▸ SRM ▸ Standardized procedures ▸ Configuration updates ▸ System reviews ▸ Support for GRC tool ▸ Assessment support ▸ U.S. based If your corporate IT or current MSP provider cannot support requirements (i.e. US person only support), an MSP specializing in the DIB should be considered.
  • 18. © 2023 C3 Integrated Solutions. All Rights Reserved. 18 Monitoring – What to look for ▸ Automation ▸ Export control ▸ 24x7 ▸ Documentation ▸SLA ▸SRM ▸IR Plan ▸ Assessment support ▸ Incident response ▸ Certifications ▸SOC-2 ▸ Vulnerability scanning Costs vary widely depending on the level of services and the sophistication of the solution.
  • 20. © 2023 C3 Integrated Solutions. All Rights Reserved. 20 Cost of Managing Compliance Initial Costs Ongoing Costs ▸ Pre-assessment review ▸ Documentation development ▸ System Security Plan (SSP) ▸ Policies ▸ Procedures ▸ Incident response plan ▸ Initial assessment ▸ Gap analysis ▸ POAM development ▸ Initial table-top ▸ Documentation ▸ Management and upkeep ▸ Integration with services? ▸ Assessment support ▸ Annual validations ▸ Table-top ▸ GRC tool ▸ Licensing ▸ Information upkeep ▸ Ad hoc consulting Compliance costs have a minimum threshold where certain activities (i.e. assessment) are required regardless of company size.
  • 21. Back to Our Examples… Numbers provided are for illustration purposes only.
  • 22. © 2023 C3 Integrated Solutions. All Rights Reserved. 22 Cost Profile Considerations ▸ Commercial v. GCCH M365 ▸ IT support costs ▸ Monitoring costs ▸ Users swivel seat ▸ Double count users across both environments Not considered ▸ Additional applications ▸ Intangibles ▸User frustration ▸Overhead and administration of multiple environments Corporate Government Microsoft 365 Commercial M365 G5 $57/month GCC High M365 G5 $1120/year IT Support Internal $150 month equivalent Outsourced $200/month Monitoring Commercial Grade $26/endpoint Compliant $35/endpoint Strategy, deployment and cost of compliance assumed comparable across examples unless noted.
  • 23. © 2023 C3 Integrated Solutions. All Rights Reserved. 23 Pre-CMMC Annual IT Budget ▸M365 Commercial ▸G5 license ▸100 users ▸IT Support ▸$150/user cost of operation ▸May be internal or external ▸Monitoring ▸“Commercial grade” ▸$26/endpoint ▸Assume 100 endpoints ▸Annual budget: $279,600 $68,400 $180,00 0 $31,200 $- $50,000 $100,000 $150,000 $200,000 $250,000 $300,000 Corporate M365 IT Support Monitoring
  • 24. © 2023 C3 Integrated Solutions. All Rights Reserved. 24 Company 1: Research Firm ▸GCC High enclave ▸10 users, M365 G5 ▸Azure Virtual Desktop ▸User access ▸No additional applications ▸$2000/month usage ▸IT Support ▸$200/user, External vendor ▸Monitoring ▸$35/endpoint (virtual) ▸Total Budget: $343,700 $279,60 0 $64,100 $- $50,000 $100,000 $150,000 $200,000 $250,000 $300,000 $350,000 $400,000 Annual Budget Corporate Enclave
  • 25. © 2023 C3 Integrated Solutions. All Rights Reserved. 25 Company 2: Manufacturing Firm ▸All-In ▸Microsoft 365 GCC High ▸100 users ▸Azure Virtual Desktop ▸Not required ▸Endpoints converted ▸IT Support ▸$200/user ▸External vendor ▸Monitoring ▸$35/endpoint (virtual) ▸Migration costs not considered ▸Total Budget: $401,000 $119,00 0 $240,00 0 $42,000 $- $50,000 $100,000 $150,000 $200,000 $250,000 $300,000 $350,000 $400,000 $450,000 All-In M365 IT Support Monitoring
  • 26. © 2023 C3 Integrated Solutions. All Rights Reserved. 26 Company 3: Professional Services ▸ All-in or Enclave? ▸ Likely the most expensive from a strategy development perspective ▸ Escalating commitment as users are added ▸ Increased risk of unintended spillage ▸ Increased user frustration and confusion ▸ Break even to go all-in just under 30 users * Does not consider other applications nor strain of managing multiple environments for both IT and users $- $100,000 $200,000 $300,000 $400,000 $500,000 $600,000 $700,000 $800,000 0 10 20 30 40 50 60 70 80 90 100 Commerical GCCH Enclave All-In
  • 27. © 2023 C3 Integrated Solutions. All Rights Reserved. 27 About C3 Integrated Solutions Technology Experience 11 years Microsoft partner 6+ years experience in GCC High Multiple Gold competencies Co-Sell Authorized Client Experience 450+ Microsoft 365 clients 200+ GCC High clients Deep NIST, DFARS, ITAR experience Industry Leader First to offer GCC High backup and hosted voice CMMC Registered Practitioner Organization Two successful C3PAO clients
  • 29. Get Started Build the barriers that protect your business, not disrupt it. Our mission is to protect sensitive data and prevent breaches by providing world-class cybersecurity and compliance services to businesses of all sizes. visit c3isit.com