Need Help Building a CMMC Enclave? Here’s What You Need to Know
If you're handling Controlled Unclassified Information (CUI) and pursuing CMMC compliance, defining the right system boundary is a critical first step. One of the most effective—and commonly misunderstood—strategies is the enclave approach.
If you’re handling Controlled Unclassified Information (CUI) and pursuing CMMC compliance, defining the right system boundary is a critical first step. One of the most effective—and commonly misunderstood—strategies is the enclave approach. Whether you’re aiming to limit your compliance scope or just need help with building a CMMC enclave that fits your unique environment, understanding your options is key. In this post, we’ll break down what a CMMC enclave is, why it matters, and how to decide if it’s the right path for your organization.
What Is a Compliance Scope?
Once you understand the people, systems, and processes that interact with CUI, you can now determine your compliance scope. In essence, this means mapping and documenting all locations and pathways of CUI data in your environment in order to define exactly what must be included in your compliance efforts in order to ensure that you can meet regulatory requirements. The compliance scope defines the boundaries of the systems that store, process, and/or transit CUI data. It also sets the stage for all the future steps and is a key parameter in your overall CMMC assessment scope.
Once you understand where CUI data exists and where it flows, your next decision is whether to choose an enclave or all-in approach for your compliance boundary. Each approach has pros and cons, so it’s important to consider which one makes the most sense for your organization.
Enclave Approach to CMMC
The enclave approach specifically isolates systems that handle CUI into a separate environment. This approach is particularly beneficial for organizations seeking a more controlled scope rather than bringing everything within the system boundary.
Pros of taking an enclave approach:
- Smaller initial investment compared to an enterprise-wide solution.
- Reduced scope simplifies compliance efforts by minimizing the number of systems that need protection.
- A smaller attack surface may reduce cybersecurity risks.
- Minimal data migration decreases operational disruption during implementation.
Cons of taking an enclave approach:
- Swivel-seat users (that is, employees who work across both compliant and non-compliant systems) may face inefficiencies from having to switch back and forth between environments.
- Having dual administration requirements often creates additional operational complexity.
- You may experience higher costs than anticipated if you underestimate ongoing maintenance costs.
- Data spillage potential increases because users may inadvertently transfer sensitive data between compliant and non-compliant environments.
All-In Approach
The all-in approach involves applying CMMC requirements across the entire organization, creating a unified environment where everything is contained within the system boundary.
Pros to all-in:
- A single, unified environment eliminates the need for both dual administration and swivel-seat users.
- There’s the potential to eliminate technical debt because moving to a single environment will probably involve replacing legacy systems.
Cons to all-in:
- Data migration to a new environment can create challenges that disrupt operations and increase deployment costs.
- Every user in the organization must comply with stringent security requirements, which may impact productivity, especially at the beginning.
- Users may request non-approved applications, resulting in additional administrative controls and denial of such requests.
Is CMMC Enclave Right for You? Choosing the Right Approach
When making the decision between the enclave or all-in approach, consider the percentage of DoD work your organization does. Organizations that provide commercial products and services with only a small percentage of revenue coming from the DoD tend to benefit from the enclave approach. Conversely, companies that focus on the DoD or have DoD contracts deeply intertwined with their commercial business may find an all-in approach is the best fit.
At C3 Integrated Solutions, we have seen cases where a client’s final objective is an all-in approach, but they choose to start with an enclave. This allows the organization to move quickly to an initial compliance posture, and then migrate additional users and systems over time.
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