Threat & Research Team Blog

Can ITAR Be CUI? Why ITAR Could Be in Scope for your CMMC Assessment
Ross Seay Ross Seay

Can ITAR Be CUI? Why ITAR Could Be in Scope for your CMMC Assessment

Any defense contractors mistakenly believe ITAR-controlled data sits outside the boundaries of CMMC Level 2 — but that assumption could cost you your certification.

In reality, the National Archives and Records Administration (NARA) confirms that certain ITAR-regulated information qualifies as Controlled Unclassified Information (CUI Specified). That means if your organization handles ITAR data, it’s likely in scope for your CMMC assessment — and must meet strict safeguarding and dissemination requirements.

In this article, we explain how ITAR and CUI overlap, what the CUI Registry actually says, and why treating ITAR as CUI is both the safest and most compliant path forward for defense contractors.

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Scoping CUI for CMMC Level 2 Certification
Ross Seay Ross Seay

Scoping CUI for CMMC Level 2 Certification

Defining the scope of your Controlled Unclassified Information (CUI) environment is the first and most critical step in preparing for a CMMC Level 2 assessment. Proper scoping ensures you know exactly which assets, people, and systems fall within your compliance boundary—and it can make the difference between a smooth certification process and costly setbacks. In this blog, we break down the scoping requirements, explain how to categorize assets, and share a practical checklist to help your organization build a clear, audit-ready System Security Plan (SSP).

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CMMC Compliance Series: The CMMC Shared Responsibility Matrix
CMMC, Cyber Security Compliance Ross Seay CMMC, Cyber Security Compliance Ross Seay

CMMC Compliance Series: The CMMC Shared Responsibility Matrix

The CMMC Shared Responsibility Matrix helps businesses define which cybersecurity tasks they own and which are handled by service providers like AWS or Microsoft Azure. By clarifying roles in encryption, access control, and incident response, organizations can simplify compliance, strengthen security, and prepare for upcoming CMMC requirements

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