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Compliance Engineering

Architecture and evidence built against NIST SP 800-171, CMMC 2.0 and FIPS 140-3 from the start, so the audit is a reporting exercise rather than a rebuild.

Home Services Compliance engineering

  • NIST SP 800-171
  • CMMC 2.0
  • FIPS 140-3
  • Evidence trail

In plain terms

Regulators and customers require you to prove your security, not just have it. We design systems so the proof is produced automatically as they run — meaning an audit becomes a report you print rather than a scramble to reconstruct what happened months ago.

Compliance retrofitted at the end of a security program is expensive and usually incomplete. Designing the control mapping and the evidence trail into the architecture costs far less than proving it after the fact.

A note on scope. CerbaCore engineers systems to meet these frameworks and produces the evidence your assessor will ask for. We are not an accrediting body and we do not issue certifications. Formal authorization is granted by the relevant authority or a certified third-party assessor, and we work alongside them.

Frameworks we build against

NIST SP 800-171

Protection of controlled unclassified information in non-federal systems. We map each control family to the actual mechanism that satisfies it, and flag the ones your architecture currently cannot satisfy rather than writing a plan of action that quietly never closes.

CMMC 2.0

Required through the defense industrial base supply chain. We scope the enclave, design the boundary so the assessable footprint stays as small as it honestly can, and build the evidence collection to match the level you are seeking.

FIPS 140-3

Cryptographic module validation. This one is frequently misunderstood: the validation attaches to the module, not to your product. We inventory every cryptographic operation in the design, identify which need validated modules, and document the boundary.

Evidence as a build output

The expensive part of an audit is rarely the control — it is proving the control was operating throughout the period. We instrument for that during design: automated configuration evidence, tamper-evident logging with defined retention, and a control-to-artifact map an assessor can follow without a workshop.

What this looks like in practice

  • Control mapping against your real architecture, not a generic template
  • Gap analysis with remediation sequenced by assessment risk and cost
  • Boundary and enclave design that limits assessable scope
  • Evidence automation wired into the systems that generate it
  • Support through assessment, including responding to assessor findings

Control, mechanism, artifact

Control to evidence mappingEach control maps to one named mechanism which emits one artifact, collected on a schedule into a timestamped evidence store.one control, one named mechanism, one automatically collected artifactControle.g. 3.1.1 limitsystem accessMechanismthe config thatsatisfies itArtifactlog, config export,reportEvidence storetimestampedimplemented byemitscollectedWHAT AUDITORS ACTUALLY ASK“Show me this control was operating on 14 March.” If the artifact is generated on a schedule and stored immutably,that is a query. If it is produced on request, it is a scramble — and a control with no evidence of continuous operationis treated as a control that was not operating.
Evidence is designed in during the build. Retrofitting it is where compliance budgets go.

Every control maps to exactly one named mechanism and one automatically collected artifact. Where a control maps to "process" rather than a mechanism, we flag it — process controls without a generated artifact are where audits fail, because nobody can prove the process ran in March.

A real mapping, three rows

ControlMechanismArtifactCadence
800-171 3.1.1 — limit system access to authorized usersIdP group membership bound to role Nightly group export, hashed and storedDaily
800-171 3.4.1 — maintain baseline configurationsConfig-as-code repo with signed commits Commit log + drift-detection reportContinuous
800-171 3.14.1 — identify and correct flawsVulnerability pipeline with SLA clock Remediation report with open/closed ageingWeekly

Framework overlap — map once, derive many

Organizations subject to several frameworks routinely run parallel compliance programs against the same underlying controls. That is a duplication of cost, not a duplication of assurance.

MechanismNIST 800-171CMMC 2.0 L2ISO 27001SOC 2
Role-based access with quarterly review3.1.1, 3.1.2AC.L2-3.1.1A.5.15CC6.1
Centralized, tamper-evident logging3.3.1, 3.3.2AU.L2-3.3.1A.8.15CC7.2
Encryption of CUI at rest3.13.16SC.L2-3.13.16A.8.24CC6.7
Vulnerability remediation with SLA3.14.1SI.L2-3.14.1A.8.8CC7.1

One mechanism, one artifact, four framework views generated from the same evidence.

Frameworks outside the United States

An estate spanning AMER, EMEA and APAC is rarely subject to one regime. We map once to the underlying mechanism and derive each jurisdiction's view from the same evidence, rather than running parallel programs that prove the same control three times.

MarketRegimeApplies toWhat it changes in the build
EMEAGDPRAnyone processing EU/UK personal data Telemetry is personal data. Retention, lawful basis and transfer mechanism must be designed in, not added later.
EMEANIS2Essential and important entities in the EU Incident reporting inside 24 hours for early warning; management is personally accountable.
EMEADORAEU financial entities and their ICT providers Third-party register, exit plans and mandated resilience testing.
EMEA (UK)Cyber Essentials / PlusUK public-sector supply chain A defined technical baseline, externally verified for Plus.
APAC (ANZ)Essential EightAustralian government and suppliers Maturity-level targets per control, assessed rather than self-declared.
APAC (ANZ)IRAP / ISMAustralian government systems Assessment by an endorsed IRAP assessor; data must generally stay onshore.
APACMAS TRM, Singapore CCoPSingapore financial and CII operators Prescriptive OT and resilience requirements for critical infrastructure.
LATAMLGPD (Brazil)Processing Brazilian personal data GDPR-shaped obligations with local reporting specifics.
GlobalISO/IEC 27001Anyone The common spine. Most other regimes can be derived from a well-run ISMS.
Global (OT)IEC 62443Industrial operators and vendors Zone and conduit architecture — see SCADA and ICS security.

Data residency decides your telemetry architecture

This is the single most common cross-border mistake we are called in to unpick. Endpoint telemetry contains usernames, hostnames, file paths and process command lines — personal data under GDPR and LGPD, and frequently subject to onshore requirements under IRAP and several APAC regimes.

A platform that ships all telemetry to a single US region is a transfer problem that surfaces during an audit, long after the architecture is fixed. Decide residency before the deployment design: regional collection with local retention, and only aggregated or pseudonymised data crossing a boundary. Retrofitting this means redeploying the estate.

FIPS 140-3, precisely

The most common misunderstanding we correct

FIPS 140-3 validates a cryptographic module — a specific version of a specific library or hardware element, on a specific platform, listed on the NIST CMVP register. It does not validate your product, your system or your company.

Consequences people are surprised by: using a validated module incorrectly does not give you a validated posture; upgrading the library invalidates the specific validation you relied on; and "FIPS compliant" is a marketing phrase with no standing, as against "FIPS validated" with a certificate number you can look up.

What we actually do: inventory every cryptographic operation in the design, identify which fall inside the boundary requiring validated modules, select modules with current certificates, document the boundary, and configure the module in its approved mode — which is frequently not the default.

Worked example — 260-person defense supplier, 11 months to contract renewal

  1. Month 1 — CUI discoveryCUI found in 14 locations, including a shared drive open to all staff and two engineers' personal email. Every system holding it was in scope for assessment.
  2. Month 2 — scoping decisionA dedicated enclave for CUI work: 40 users, 12 servers, one VDI pool. In-scope systems fell from roughly 400 to 53.
  3. Months 3–4 — migrationCUI relocated into the enclave, source locations sanitized, and data-loss controls placed on the boundary to stop it leaking back out — the step most programs omit, after which scope quietly regrows.
  4. Months 5–8 — remediationAll 110 controls assessed honestly; 31 gaps. Remediated in order of assessment risk. Four required capital spend and were scheduled with the CFO rather than discovered at the last minute.
  5. Month 9 — evidence automationArtifact collection wired in, backfilled where legitimate, with a clear record of which controls had evidence from which date.
  6. Months 10–11 — assessmentSSP and POA&M prepared, artifacts mapped control by control, and we attended to answer findings.

The scoping decision in month 2 is what made the other nine months affordable. See CMMC compliance services.

Scope your endpoint and network architecture

Bring us the estate you actually have — mixed OS fleets, ageing routers, unmanaged IoT — and we will tell you what can be unified under one agent and what needs custom work.

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