CMMC / DFARS 252.204-7012
Cybersecurity certification
CMMC Level 2 readiness against NIST SP 800-171 Rev 2. Gap matrices, System Security Plans, POA&M packages, evidence collection, and C3PAO assessment preparation.
CMMC · Export Controls · Sanctions Compliance
What you need to pass your CMMC assessment and keep your contracts.
Fixed-scope CMMC Level 2 readiness assessments, ITAR/EAR classification, and OFAC sanctions program design. Delivered against a documented analytical methodology published openly under WP-2026.
For defense contractors, biotech and dual-use technology firms, outside counsel, and investment funds facing cybersecurity, export-control, or sanctions compliance requirements.
Tri-pillar regulatory coverage
Published methodology (WP-2026)
Fixed-fee and retainer engagements
Nationwide remote availability
Practice Areas
A tri-pillar defense compliance practice
Three regulatory regimes intersect in nearly every defense and dual-use engagement: contract-gating cybersecurity requirements, export controls on technical data, and counterparty risk under the sanctions regime. Engagements are scoped against the regime driving the deadline.
ITAR / EAR / 22 CFR 120
Export control classification
USML commodity jurisdiction and ECCN determinations. Deemed-export risk assessments. Technology Control Plans. Voluntary Self-Disclosure preparation.
OFAC / IEEPA / CAATSA
Sanctions program design
OFAC compliance frameworks aligned with the 2019 Framework. Counterparty risk mapping. Screening architecture, testing, and escalation protocols.
CMMC Level 2 is now contract-gating
Contractors without demonstrable readiness face elevated risk of bid exclusion in the 2026–2027 acquisition cycle. Phase 1 enforcement is active. C3PAO assessments become mandatory for applicable contracts in November 2026.
- SPRS score below 88 — no conditional certification path
- No System Security Plan — assessment cannot proceed
- Missing MFA or centralized logging — high-probability failure condition
See published analysis: CMMC Level 2 Readiness Risk in the U.S. Defense Industrial Base →
Services
What Sanctir delivers
Structured readiness, remediation, and advisory engagements. Typical CMMC readiness engagement: 4–6 weeks. Export-control and sanctions engagements scoped against regulatory complexity rather than time.
Flagship · Entry Engagement
CMMC Level 2 Readiness Assessment
Full assessment against NIST SP 800-171 Rev 2. Gap matrix, SSP outline, POA&M, priority remediation roadmap. Integrated with ITAR handling controls where applicable.
Fixed fee · 4–6 weeks · Deliverables defined at scoping
Triggered · Follow-On
ITAR/EAR Classification & Compliance
ECCN and USML commodity jurisdiction determinations. Deemed export risk assessments. Technology Control Plans. Voluntary Self-Disclosure preparation.
Fixed fee · 2–4 weeks
Triggered · Follow-On
Sanctions Compliance Program Design
OFAC compliance frameworks aligned with the 2019 Framework for Compliance Commitments. Counterparty risk mapping. Screening program architecture and testing.
Fixed fee · 4–10 weeks
Advanced
CFIUS Cybersecurity Risk Assessment
Pre-filing cybersecurity risk assessments for transactions subject to CFIUS review. Network architecture analysis, data flow mapping, mitigation agreement compliance.
Hourly advisory · 2–6 weeks
Retainer
Virtual CISO
Part-time security leadership. Risk assessment, policy development, incident response planning, board-level reporting, and regulatory engagement. 15–25 hours/month.
Monthly retainer · Ongoing
Advanced
Technical Advisory for Counsel
Technical analysis supporting litigation teams on cybersecurity standards of care, export control matters, sanctions compliance disputes, and digital forensics.
Hourly advisory · Per engagement
Representative Engagements
What this looks like in practice
Anonymized engagement patterns illustrating typical scope, deliverables, and outcomes. No client-identifying information is disclosed.
CMMC + ITAR Integration
Defense subcontractor preparing for Level 2 certification while handling export-controlled technical data
Small electronics manufacturer (under 200 employees) with active DoD subcontracts required CMMC Level 2 readiness while also handling ITAR-controlled design files shared by the prime contractor. Assessment identified 34 control gaps, three ITAR handling deficiencies, and an undocumented CUI data flow to a cloud environment outside the assessed boundary.
Deliverables: Gap matrix · SSP · POA&M · CUI boundary diagram · ITAR handling control recommendations · remediation priority roadmap.
Biotech Export Control Review
Biotech firm with foreign national research staff requiring deemed export analysis
Mid-market biotech company (300+ employees) with R&D staff holding citizenship in countries subject to EAR restrictions. Required deemed-export analysis for controlled technology access, segmentation of controlled processes, and a Technology Control Plan satisfying BIS requirements.
Deliverables: Deemed-export risk assessment · ECCN classification memos for three product lines · Technology Control Plan · staff briefing materials.
CFIUS Diligence Support
Transaction counsel requiring cybersecurity risk analysis for foreign acquisition review
Outside counsel retained for a CFIUS filing required technical cybersecurity risk analysis for a cross-border acquisition involving a company with access to controlled unclassified information. Network architecture review, data flow assessment, and a concise risk memo suitable for inclusion in the filing.
Deliverables: Cybersecurity risk assessment · data flow diagram · mitigation recommendation memo · architecture narrative for counsel.
Sanctions Compliance Architecture
Technology firm with international counterparty exposure requiring OFAC screening program
Software company expanding into markets with sanctions-adjacent counterparty risk required a compliance framework aligned with OFAC guidance, including screening architecture, escalation protocols, and a control matrix covering nine counterparty risk categories.
Deliverables: OFAC compliance framework · screening program architecture · escalation decision tree · control matrix · staff training materials.
Recent Analysis
Published risk assessment and methodology
Every engagement applies the analytical methodology documented in the WP-2026 research series: dual-axis probability and confidence labeling, explicit statement of limits and unknowns, structured evidence tiers, and prohibition on advocacy language.
CMMC Level 2 Readiness Risk in the U.S. Defense Industrial Base
Evidence, drivers, and a 90-day remediation path — March 2026
A non-trivial proportion of SMB defense contractors may not achieve CMMC Level 2 readiness without structured external remediation. One industry survey reported the average SPRS score among respondents at -12 against a required threshold of 88.
Documentation deficiency, control implementation gaps, and audit preparation failure are assessed as the primary structural drivers of non-readiness. These patterns appear consistent across the DIB.
Contractors entering late 2026 without an initiated gap assessment face elevated risk of contract ineligibility during the 2026–2027 acquisition cycle.
Sanctions and statecraft methodology series
Corpus: 62 documents across 10 analytical domains. 374-node global enforcement targeting register. Licensed under CC BY 4.0.
Core Framework
Methodology
Strategic Architecture
Assessment Risk
What fails CMMC assessments
Based on publicly available C3PAO guidance and practitioner reporting, the following conditions are assessed as likely to produce assessment failure or conditional denial.
- No current, tailored System Security Plan (SSP) — assessment cannot proceed without one
- No multi-factor authentication for remote or privileged access — critical 5-point control deficiency
- No centralized audit logging or evidence of log review — Audit and Accountability controls cannot be demonstrated
- Evidence not collected, organized, or retrievable — implemented controls treated as not implemented for scoring
- CUI boundary not defined or documented — assessment scope cannot be established
- SPRS score below 88 with no viable POA&M path — no route to conditional certification
Presence of any single condition above is consistent with elevated risk of assessment failure. Presence of multiple conditions simultaneously is consistent with high probability of assessment failure.
Entry Point
Initial readiness diagnostic
Structured 10–15 minute diagnostic
Estimate your current readiness posture and identify primary failure risks before committing to a full engagement. Designed for organizations preparing for near-term CMMC assessment.
- Estimated SPRS range
- Key control gaps
- Assessment readiness risk level
- Recommended next steps
Engagement Model
01
Gap Assessment
02
Control Remediation
03
Documentation & Evidence
04
Assessment Readiness
Typical engagements: 4–6 weeks. Structured around gap assessment, remediation prioritization, and evidence readiness. Designed for organizations preparing for near-term C3PAO assessment.
About
About Sanctir
Sanctir is an independent defense compliance practice operating at the intersection of cybersecurity certification, export controls, and sanctions enforcement. The practice serves defense contractors, dual-use technology firms, biotech companies, outside counsel, and investment funds facing contract-gating compliance requirements and enforcement risk.
Engagements are delivered under a documented analytical methodology: dual-axis probability and confidence labeling, structured evidence tiers, explicit statement of limits and unknowns, and prohibition on advocacy language. The methodology is published as the WP-2026 research series under CC BY 4.0, providing prospective clients full visibility into how analysis is constructed before engagement begins.
Scope of services is deliberately narrow. Sanctir does not provide managed security services, penetration testing, or staff augmentation. The practice delivers documented assessments, classification determinations, compliance program design, and advisory memoranda — work product that survives audit and supports counsel.
Contact
Assess your CMMC readiness
✓ Fixed-fee scoping
✓ Two-business-day response
✓ Secure communication available
✓ No sensitive materials via web form
Use the form below to request a structured readiness diagnostic or scoped engagement discussion. Initial scoping call at no charge. Response within two business days.
Important. Do not submit classified, export-controlled, privileged, or otherwise restricted information through this form. Limit submissions to high-level scoping information. Form submissions are retained only as long as necessary to respond to the inquiry. Submission of this form does not create a consulting engagement, confidentiality obligation, or attorney-client relationship absent a signed engagement agreement.