CMMC Kill Chain - Project Plan CMMC Assessments

The concept of creating a “CMMC Kill Chain” was to create a proof of concept for an efficient way to plan out a roadmap to successfully pass a CMMC assessment. The end result is a viable approach for anyone to use in order to create a prioritized project plan for CMMC pre-assessment activities.

Why “CMMC Kill Chain” you ask? The concept of a kill chain is simply that it is easier to stop and prevent further damage if those malicious activities are discovered earlier, rather than later. When you look at CMMC's zero tolerance for deficiencies, if you have a single deficiency in a process or practice, you will fail your CMMC assessment. Given that reality with CMMC, the intention of using the CMMC Kill Chain is that if you apply a prioritized, phased approach towards CMMC-related pre-assessment activities, it is possible to avoid rework and cascading failures by addressing dependencies earlier in the process. The bottom line is this model breaks down CMMC into 24 major steps, which can then be translated into a project plan. 

This project was approached from the perspective of, “If I was hired at a company, what would my plan be to start from nothing to get a company to where it could pass an assessment?” All of the CMMC practices and processes are addressed within the CMMC Kill Chain, but it is clear that the prioritization and “bucketing” of practices into phases is a subjective endeavor and not everyone may agree with this approach. Just understand that every organization is different and you will invariably need to modify the approach to fit your specific needs.

Applying The Kill Chain Model To CMMC

You might be asking yourself how a kill chain model applies to CMMC. The root issue pertains to the situation facing many IT & cybersecurity professionals who are looking at CMMC compliance with dread: These front-line IT/cybersecurity practitioners currently do not know where to start, let alone what path they need to follow to pass a CMMC assessment. There is a plethora of "What is CMMC?" guidance on LinkedIn, webinars and on the Internet in general, but there is a lack of practical guidance of HOW you are actually supposed to "do CMMC" in realistic terms. The CMMC Kill Chain is designed to provide a roadmap that would be usable for (1) anyone starting out or (2) anyone wanting to double check their approach. This model will also be added to the CMMC Center of Awesomeness website if you are looking for it in the future. You can also download it by clicking on the image below to get a PDF version of the graphic and description. 

CMMC Kill Chain CMMC Kill Chain

CMMC Project Planning Tool

The premise of the CMMC Kill Chain is to build a viable project plan from the perspective of a prioritized listing of tasks in order to successfully prepare for and pass a CMMC assessment. Errors or misguided adventures with people, processes and technology earlier in CMMC practice/process implementation activities will have cascading effects, so the CMMC Kill Chain is meant to provide a model for prioritizing CMMC-related pre-assessment activities. The CMMC Kill Chain breaks down CMMC into 23 major steps, which can then be translated into a project plan. 

CMMC Kill Chain Phases

Here is information on the 23 phases of the CMMC Kill Chain (these correspond to the picture diagram):

    1. Define What CUI Is For Your Specific Business Case. This should be self-explanatory and is based on your contract(s).
    2. Establish The Scope of The CMMC Assessment Boundary. This has four subcomponent steps: (1) Create a Data Flow Diagram (DFD) that shows how CUI flows from the DoD all the way down to subcontractors; (2) Create a detailed asset inventory for all systems, applications and services for both in-scope and out-of-scope assets; (3) Create a detailed network diagram that includes where CUI is stored, transmitted and/or processed; and (4) Inventory Third-Party Service Providers (TSP) to determine TSP access to CUI and/or in-scope systems, applications and/or services.
    3. Document The Environment. This has two subcomponent steps: (1) Start populating the System Security Plan (SSP); and (2) Create a Plan of Action & Milestone (POA&M) to track and remediate deficiencies.
    4. Define The Network Architecture. This involves implementing a network architecture that ensures it is built on secure engineering principles and enclaves to protect sensitive information (e.g., FCI/CUI). POA&M deficiencies & document procedures.
    5. Plan, Identify Gaps & Prioritize Resources. This has six subcomponent steps: (1) Define applicable statutory, regulatory and contractual obligations (including DFARS, FAR, NIST 800-171 and CMMC); (2) Perform a gap assessment from applicable statutory, regulatory and contractual obligations; (3) Develop & implement policies and standards to address applicable statutory, regulatory and contractual obligations; (4) Identify the necessary People, Processes & Technology (PPT) that are necessary and appropriately sized; (5) Develop & implement a resource plan (e.g., business plan, budget, road map, etc.) to meet compliance obligations; and (6) Prioritize objectives from the resource plan for PPT requirements. POA&M any deficiencies from this phase.
    6. Develop Procedures. This has two subcomponent steps: (1) Develop & implement procedures to implement policies & standards; and (2) Define processes to securely handle CUI. POA&M any deficiencies from this phase.
    7. Risk Management. Develop & implement a Risk Management Program (RMP) to identify, assess and remediate risk. POA&M deficiencies & document procedures.
    8. Change Control. Develop & implement change control processes, including a Change Control Board (CCB). POA&M deficiencies & document procedures.
    9. Incident Response. Develop & implement incident response capabilities to detect, respond and recover from incidents. POA&M deficiencies & document procedures.
    10. Situational Awareness. Develop & implement situational awareness capabilities through log collection and analysis (e.g., SIEM). POA&M deficiencies & document procedures.
    11. System Hardening. Identify, build & implement secure baseline configurations (e.g., hardening standards) for all technology platforms. POA&M deficiencies & document procedures.
    12. Centralized Management. Build & implement Group Policy Objects (GPOs) for Microsoft Active Directory (AD). POA&M deficiencies & document procedures.
    13. Identity & Access Management. Develop & implement Identity & Access Management (IAM) to address "least privilege" and Role-Based Access Control (RBAC). POA&M deficiencies & document procedures.
    14. Maintenance. Develop & implement proactive maintenance practices. POA&M deficiencies & document procedures.
    15. Attack Surface Management / Vulnerability Management. Develop & implement Attack Surface Management (ASM) practices. POA&M deficiencies & document procedures.
    16. Asset Management. Develop & implement technology asset management practices. POA&M deficiencies & document procedures.
    17. Personnel Security. Work with Human Resources (HR) to ensure personnel security requirements are integrated into HR operations. POA&M deficiencies & document procedures.
    18. Network Security. Develop & implement network security practices. POA&M deficiencies & document procedures.
    19. Business Continuity. Develop & implement business continuity capabilities. POA&M deficiencies & document procedures.
    20. Cryptography. Develop & implement cryptographic key management and data encryption capabilities. POA&M deficiencies & document procedures.
    21. Physical Security. Develop & implement physical security practices. POA&M deficiencies & document procedures.
    22. Security Awareness Training. Build and maintain a security-minded workforce through training & awareness. POA&M deficiencies & document procedures.
    23. Internal Audit. Build and maintain an "internal audit" or Information Assurance (IA) capability to govern controls. POA&M deficiencies & document procedures.

Background On The Logic Used In This Model

Here is a quick explanation on some of the reasoning used for this model:

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