Protect controlled information
Whether cybersecurity posture and documentation actually substantiate what has been attested — and where the gap between claimed and implemented control creates exposure.
The verification mechanism for defense-contractor cybersecurity is under active revision. The underlying obligation is not. Organizations handling controlled unclassified information still carry documentation requirements under NIST SP 800-171, and a self-attested security score that overstates actual implementation is a false statement with consequences — including False Claims Act liability — regardless of how or when it is later verified.
The durable requirement is accuracy: a System Security Plan that matches the environment, controls that are actually implemented and evidenced, and an attestation an organization can stand behind if it is ever examined. The value Sanctir provides is making that attestation true and defensible, not making a number look passable.
Engagements include self-assessment against NIST SP 800-171, SSP and POA&M development, CUI boundary definition, evidence organization, and independent review of whether an existing attestation is supportable. Related expert analysis supports counsel in cyber-fraud and standards-of-care matters.
A dated assessment of the current state of CMMC verification and attestation exposure is published in the research library: The Deadline Went Away. The Obligations Did Not. (SB-2026-01, 20 July 2026).
On the distinction between an export-control obligation and a cybersecurity one — and how the two attach independently: The Export Rule Controls Your Data. It Never Tells You How to Protect It. — where a cybersecurity obligation actually comes from when an export-control regulation controls your information but prescribes no control set. 10 CFR Part 810, the CUI framework, and why applicability is a contract question, not a question about the data. Read SB-2026-02 →
Discuss an engagement
An initial scoping conversation is provided at no charge. Describe the situation in general terms first; use an encrypted channel for anything specific.