When organizations begin their journey toward Cybersecurity Maturity Model Certification (CMMC), one of the big questions that comes up is whether or not it makes sense to create a CMMC enclave. In the context of CMMC, an enclave is a secure, air-gapped, isolated environment within an organization’s network that handles and protects Controlled Unclassified Information (CUI) in compliance with CMMC requirements. But what exactly does that mean, and more importantly, does it make sense for your business?
What is a CMMC enclave?
An enclave is a separate network or system facility specifically set up to handle CUI. Even if an employee is indirectly exposed to CUI, such as when overhearing a conversation, the individual will directly fall under CMMC’s regulatory scope. Therefore, to prevent such scenarios, the enclave must be completely air-gapped from the rest of the organization’s IT infrastructure—meaning no direct connections, no shared resources, and no accidental cross-communication between the enclave and other systems.
Creating an enclave typically requires strict physical access controls, separate authentication systems, and entirely distinct security protocols to ensure no accidental or intentional leakage of CUI into non-protected environments. Additionally, employees working within the enclave may need specialized training and clear instructions on communication boundaries to avoid inadvertently sharing CUI outside the designated secure environment.
What is the benefit of a CMMC Enclave? Simplicity and cost savings.
If your company serves both government and non-government clients, you are only required to implement CMMC-level controls for areas handling CUI. By creating an enclave, you can limit the compliance burden to a specific part of the organization instead of applying it to the entire network. Here are the main benefits of doing so:
- Costs: Rather than purchasing numerous licenses or implementing expensive security measures across the entire network, you can focus on a smaller segment, potentially reducing the number of licenses or tools needed.
- Less maintenance: Managing compliance for a smaller portion of the network reduces complexity, requiring less training, fewer systems to monitor, and possibly lowering the risk of non-compliance.
Of course, nothing’s so easy in practice. One big downside of going the enclave route is that employees will need to know two different ways of doing things: different controls, policies, and tools for each environment. Less compartmentalization means fewer opportunities for mistakes, and your team only must learn one way of operating. Interesting enough, users in some online forums even discuss creating an entirely separate LLC instead of just creating an enclave!
Risk is never zero. What if there’s a breach?
Even with the most secure enclave, information security risk is never zero. You’re managing risk to a level that is acceptable to the organization, not erasing it. For instance, in the event of a security breach, you must report the incident within 72 hours through the DIBNet portal. This is mandated by the Cyber Incident Reporting requirements outlined in DFARS 7012, which you can review here: DFARS 7012 under section “(c) Cyber incident reporting requirement.” To report an incident, a DoD-Approved Medium Assurance Certificate is required, which could take up to several months to obtain. To that end, a CMMC implementor can assist the OSC (Organization Seeking Certification) in navigating through these requirements and making sure they are in place.
Moreover, an excellent way to keep your enclave secure is by creating a detailed System Security Plan (SSP) for CMMC. This document outlines how the enclave is protected and what controls are in place. Note, however, that this is not just a one-and-done document — it’s an ongoing process of testing, auditing, and updating as your systems evolve. An SSP becomes a vital part of your compliance journey and keeps auditors satisfied when it’s time to assess your CMMC maturity.
A Decision Best Made with CMMC Implementors
Like most things in cybersecurity, deciding whether to create a CMMC enclave depends on your specific situation. It’s all about CMMC scope. Once you understand how much of your business touches CUI, you can decide if separating that into an enclave is the right approach. Our team suggests working with expert CMMC consultants who can help guide the decision-making process. They’ll weigh the pros and cons, look at your organization’s scope and services, and help you determine the most efficient and cost-effective path forward.
Have you read?
How to Prepare for a CMMC Assessment with a C3PAO
10 Red Flags to Consider When Vetting a CMMC Consultant
CMMC Compliance: Be ready to achieve DoD cybersecurity certification
Hiring EXTEND Resources for CMMC Consulting Services
For many, the cost savings and ease of maintaining a smaller, isolated environment make sense. For others, especially those that only deal with CUI, applying controls across the entire network may be the better option. Whichever path you choose, the important thing is to look for a CMMC expert who can help you navigate these decisions and get you on the right track toward compliance.
With EXTEND Resources, NIST SP 800-171 compliance for CMMC L1 and L2 requirements becomes a streamlined, achievable journey. We offer comprehensive services, led by a CMMC Registered Practitioner, tailored to your unique needs.
Interested in exploring if a CMMC enclave makes sense for your organization? Contact us now.
