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The Big Blog
Defense Supply Chain Due Diligence: Vetting Subcontractors Under NIST 800-161
Supply chain security remains a critical challenge for organizations operating in the defense industrial base and other regulated sectors. Cyber threats, foreign influence, counterfeit components, and weak cybersecurity practices at any tier can compromise sensitive information and mission systems. Effective management of these risks requires both rigorous assessment of suppliers and the disciplined contractual transfer of requirements, commonly known as flow-down. NIST Speci
Jul 225 min read
How CMMC Flow-Down Will Reshape the Defense Supply Chain
For years, much of the discussion surrounding Cybersecurity Maturity Model Certification (CMMC) has focused on assessment preparation, documentation, and implementing the technical safeguards required by NIST SP 800-171. Those remain essential components of compliance, but another challenge is quickly emerging that could have an even greater impact on the Defense Industrial Base. As CMMC requirements begin appearing in contracts, organizations will not only need to demonstrat
Jul 76 min read
CMMC Flow-Down Requirements: Under DFARS 252.204-7021 (NOV 2025) and 32 CFR Part 170
Under CMMC, a prime contractor must flow the applicable safeguarding and certification requirements down to every subcontractor, at any tier, whose systems will process, store, or transmit Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). Suppliers that handle neither, and subcontracts solely for commercially available off-the-shelf (COTS) items, are outside the flow-down. Which requirements flow depends on the information type: FCI triggers the
Jun 2411 min read
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