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Operational Plan of Action in CMMC Compliance

July 8, 2026July 8, 2026 by techprognosis

Operational Plan of Action: The Missing Link Between CMMC Compliance and Real Remediation

Many DIB contractors understand the System Security Plan (SSP) and assessment Plan Of Action & Milestones (POA&M), but the Operational Plan of Action is where CMMC readiness becomes real remediation. This article explains what it is, why it matters, and how to use it as an ongoing cybersecurity management process.

In CMMC readiness conversations, the System Security Plan often gets most of the attention. The POA&M also receives plenty of discussion, especially because of the rules around conditional status and post-assessment remediation. But one requirement deserves more attention across the Defense Industrial Base: the Operational Plan of Action.

At first glance, it may sound like another compliance artifact. In practice, it asks a much more operational question: when your organization discovers a cybersecurity deficiency or vulnerability, how do you make sure it actually gets fixed?

That question matters because CMMC readiness should not stop at documentation. It should create a repeatable way to identify weaknesses, assign responsibility, drive remediation, validate completion, and sustain improvement over time.

Security Information and Event Management (SIEM) and Regulated Industries

June 17, 2026 by Daniel Ihonvbere

Understanding SIEM in 2026: Limitations—and How to Build a Compliant, Outcome‑Driven Detection Program

Executive summary. Security Information and Event Management (SIEM) remains central to modern detection and response, but the playing field has evolved: cloud‑first estates, identity‑centric attacks, and new or strengthened rules (CMMC, HIPAA Security Rule enforcement practices, FTC Safeguards updates, ISO/IEC 27001:2022, and NIST CSF 2.0) raise the bar for logging, monitoring, and evidence. SIEM alone isn’t enough; you’ll need smart log source prioritization, detection engineering mapped to frameworks like MITRE ATT&CK, and automation you can trust (SOAR), all tuned to produce defensible evidence for audits and assessments.

What is Security Information and Event Management (SIEM) today (and what it isn’t)

A SIEM centrally collects and analyzes logs and events across systems, networks, applications, identities, and cloud services to help analysts detect, investigate, and report incidents. It’s often paired with Security Orchestration, Automation, and Response or SOAR to orchestrate and automate response actions.

SOAR (security orchestration, automation, and response) provides playbooks and automation for triage and remediation; it does not replace analytic rigor or governance.

Governments and industry recently published pragmatic guidance for implementing SIEM/SOAR, highlighting benefits (visibility, faster response) and pitfalls (data normalization, coverage, resource intensity).

Where SIEM fits in frameworks: NIST CSF 2.0 explicitly expects continuous monitoring and event logging outcomes (e.g., PR.PS‑04 requires that log records are generated and made available for continuous monitoring)—functions typically enabled by SIEM + SOAR.

Chief Risk Officer Role in Banking: Evolution in the Age of AI

May 20, 2026 by Daniel Ihonvbere

AI risk management is becoming a defining priority for banks and other financial institutions. As artificial intelligence moves from experimentation to operational use across financial services, the Chief Risk Officer is being asked to do more than monitor exposures and enforce controls. The role now sits at the center of AI governance, model risk management, regulatory discipline, and customer trust.

Over the next several years, AI in banking will reshape how institutions identify emerging threats, assess customer and portfolio risk, detect anomalies, and respond to changing market conditions. For Chief Risk Officers, the shift is not simply technological. It is strategic. The role is evolving from oversight alone to active partnership in enterprise transformation, responsible AI adoption, and predictive risk management.

Revolutionary FAR Overhaul (RFO) for CMMC

April 23, 2026April 19, 2026 by Daniel Ihonvbere

The CMMC Revolutionary FAR Overhaul (RFO): Why the DoD’s Quiet Regulatory Reset Changed Cybersecurity Enforcement Forever

Executive Summary (For Decision‑Makers)

In late 2025 and early 2026, the Department of Defense executed a sweeping regulatory cleanup now commonly referred to as the Revolutionary FAR Overhaul (RFO). While much of the attention has focused on the deletion of specific clauses—most notably DFARS 252.204‑7019—the real story is far larger.

RFO fundamentally changed how cybersecurity compliance is enforced, not just how it is described. Temporary, trust‑based mechanisms were removed. Verified, system‑enforced eligibility replaced them. As a result:

DFARS 7019 disappeared
SPRS was repositioned
CMMC became non‑negotiable
Contract eligibility—not intent—became the enforcement mechanism

This article explains what RFO actually is, why it occurred, and how it permanently reshaped cybersecurity enforcement across the Defense Industrial Base (DIB).

CMMC Level 2 Readiness: The Need for Strong IT Audits

April 12, 2026 by Daniel Ihonvbere

CMMC Level 2 Readiness: Why Strong IT Audits Are the Difference Between Compliance and Contract Loss

For defense contractors, CMMC Level 2 is no longer a theoretical requirement—it’s a gatekeeper. As the Department of Defense moves away from self‑attestation toward evidence‑based assessments, organizations handling Controlled Unclassified Information (CUI) must now prove their cybersecurity maturity.

At the core of that proof is one often‑misunderstood capability: the IT audit function.

In our work helping organizations prepare for and pass CMMC Level 2 assessments, we consistently see the same pattern. Companies that treat audits as a last‑minute compliance exercise struggle. Companies that integrate internal and external audit disciplines into their CMMC strategy succeed—and stay compliant long after certification.

This article explains how IT audits directly support CMMC Level 2 readiness, why both internal and external auditors matter, and how audit‑driven programs build real cybersecurity resilience.

Cyber Resilience for CMMC Contractors: Why It Matters and How to Build It

April 3, 2026 by Daniel Ihonvbere

Cyber Resilience for CMMC Contractors: Why It Matters and How to Build It

Cyber resilience is the capability to anticipate, withstand, recover from, and adapt to adverse cyber conditions—so that your mission‑essential manufacturing operations continue even when an attack succeeds. Resilience complements CMMC’s confidentiality‑focused controls (based on NIST SP 800‑171r3) by emphasizing continuity, restoration, and adaptation across IT and OT.

Audience: Defense Industrial Base (DIB) manufacturers and suppliers that handle FCI/CUI and are preparing for (or maintaining) CMMC compliance.

Why Cyber Resilience Now (Especially in the DIB)

The DIB remains a prime target for espionage and ransomware, and the Department of Defense (DoD) created CMMC to raise the floor on contractor protections for FCI/CUI.
NIST’s Cybersecurity Framework (CSF) 2.0 underscores governance and recoverability as integral to enterprise risk management—useful language for your board, program managers, and auditors.
Ransomware and OT/ICS impacts propagate from IT to plant networks; resilient manufacturers isolate critical processes, segment IT/OT, and test offline backups to maintain production.

Bottom line: CMMC helps protect sensitive data; resilience keeps your line running and deliveries on time.