Five Practical Steps to Boost CMMC Level 2 Compliance in a Cloud-Hosting Environment

For organizations pursuing Cybersecurity Maturity Model Certification (CMMC) Level 2, achieving compliance within a cloud-hosting environment can feel daunting. However, by focusing on high-impact actions, businesses can make significant progress toward certification in just 30 days. Below are five practical steps that organizations can implement, along with tools and strategies to streamline the process.

1. Implement Multi-Factor Authentication (MFA) Across All Cloud Accounts

One of the most effective ways to enhance security and align with CMMC Level 2 requirements is to enforce multi-factor authentication (MFA) for all users accessing the cloud environment. CMMC Level 2 mandates strong access controls to protect Controlled Unclassified Information (CUI), and MFA significantly reduces the risk of unauthorized access.

How to Implement:

• Enable MFA on Cloud Platforms: Major cloud providers like AWS, Azure, and Google Cloud offer built-in MFA options. Administrators should navigate to the identity and access management (IAM) settings to mandate MFA for all users.
• Use Authenticator Apps: Encourage the use of authenticator apps like Microsoft Authenticator or Google Authenticator for secure, token-based authentication, avoiding less secure SMS-based MFA.
• Tool Recommendation: For organizations with diverse cloud services, a tool like Okta or Duo Security can centralize MFA management across multiple platforms, simplifying deployment and monitoring.

Impact: Enabling MFA immediately strengthens access controls, addressing CMMC practices such as AC.L2-3.1.5 (Employ MFA for network access to privileged and non-privileged accounts).

2. Conduct a Comprehensive Asset Inventory

Organizations cannot protect what they don’t know they have. CMMC Level 2 requires a detailed inventory of assets that store, process, or transmit CUI. A complete asset inventory provides visibility into the cloud environment, ensuring all systems are accounted for and secured.

How to Implement:

• Leverage Cloud-Native Tools: Use tools like AWS Config, Azure Asset Management, or Google Cloud Asset Inventory to automatically discover and catalog cloud resources such as virtual machines, databases, and storage buckets.
• Tag Assets: Implement a tagging strategy to label assets that handle CUI, making it easier to track and apply security controls.
• Tool Recommendation: For a more robust solution, tools like ServiceNow IT Asset Management or Axonius can integrate with cloud platforms to provide real-time asset visibility and compliance reporting.

Impact: A thorough asset inventory supports CMMC practices like CM.L2-3.4.1 (Establish and maintain an inventory of organizational systems), laying the foundation for other security measures.

3. Deploy Endpoint Detection and Response (EDR) Solutions

CMMC Level 2 emphasizes continuous monitoring and rapid response to security incidents. Deploying an Endpoint Detection and Response (EDR) solution across cloud-hosted endpoints, such as virtual machines and containers, enhances an organization’s ability to detect and mitigate threats in real time.

How to Implement:

• Select an EDR Solution: Choose a cloud-compatible EDR tool like CrowdStrike Falcon, Microsoft Defender for Endpoint, or SentinelOne. These tools provide real-time monitoring, threat detection, and automated response capabilities.
• Integrate with Cloud Workloads: Ensure the EDR solution is configured to monitor all cloud-based endpoints, including servers and employee devices accessing the cloud environment.
• Tool Recommendation: For organizations with hybrid environments, Carbon Black Cloud offers seamless integration with major cloud providers and robust threat-hunting capabilities.

Impact: EDR deployment aligns with CMMC practices like SI.L2-3.14.2 (Monitor system security alerts and advisories and take action), improving incident response and audit readiness.

4. Configure Security Information and Event Management (SIEM) for Log Aggregation

CMMC Level 2 requires organizations to collect, store, and analyze security logs to identify and respond to potential incidents. A Security Information and Event Management (SIEM) system is critical for centralizing logs from cloud services and enabling proactive threat detection.

How to Implement:

• Choose a Cloud-Native SIEM: Tools like Splunk Cloud, Azure Sentinel, or AWS Security Hub can aggregate logs from cloud services, providing a unified view of security events.
• Define Log Retention Policies: Configure the SIEM to retain logs for at least 12 months, as required by CMMC, and ensure logs capture user activity, system events, and security alerts.
• Tool Recommendation: For small to mid-sized organizations, Elastic Security offers a cost-effective SIEM solution with powerful search and analytics capabilities, ideal for cloud environments.

Impact: A properly configured SIEM supports CMMC practices like AU.L2-3.3.1 (Create and retain system audit logs and records), enabling organizations to demonstrate compliance during assessments.

5. Establish a Vulnerability Management Program

Regularly identifying and remediating vulnerabilities in the cloud environment is a cornerstone of CMMC Level 2. A structured vulnerability management program ensures that weaknesses are addressed before they can be exploited.

How to Implement:

• Use Cloud-Native Scanning Tools: Leverage built-in tools like AWS Inspector, Azure Security Center, or Google Cloud Security Command Center to scan for vulnerabilities in cloud resources.
• Schedule Regular Scans: Configure weekly or bi-weekly scans to identify misconfigurations, outdated software, or exposed ports, and prioritize remediation based on severity.
• Tool Recommendation: For comprehensive vulnerability management, tools like Qualys or Tenable.io offer cloud-specific scanning capabilities, integrating with cloud platforms to provide actionable insights.

Impact: A robust vulnerability management program addresses CMMC practices like RA.L2-3.11.2 (Scan for vulnerabilities in organizational systems and applications), reducing the attack surface and enhancing compliance.

Getting Started in the Next 30 Days

To maximize impact within 30 days, organizations should prioritize these steps based on their current security posture:

• Week 1: Enable MFA across all cloud accounts and begin asset inventory collection.
• Week 2: Deploy an EDR solution and configure initial SIEM log aggregation.
• Week 3: Set up a vulnerability management program and conduct the first round of scans.
• Week 4: Review progress, refine configurations, and document processes to prepare for a CMMC assessment.

By leveraging cloud-native tools and third-party solutions like Okta, CrowdStrike, Splunk, or Tenable, organizations can implement these controls efficiently. Each step addresses critical CMMC Level 2 practices, bringing businesses closer to certification while strengthening their overall cybersecurity posture.

For those navigating the CMMC journey, starting with these high-impact actions provides a clear path forward. By taking decisive steps in the next 30 days, organizations can build a solid foundation for compliance and demonstrate their commitment to protecting sensitive data in the cloud.