Building a Defensible CMMC Program: What the False Claims Act Means

CMMC compliance is no longer just about passing an assessment. Defense contractors must be prepared to demonstrate that security controls are operating effectively throughout the year, not only during an audit. A strong compliance program requires continuous oversight, accurate documentation, regular reviews, and a clear understanding of how Controlled Unclassified Information (CUI) is handled across the organization. Gaps between documented policies and actual practices can create significant operational and financial risks as cybersecurity requirements continue to evolve. Organizations that treat compliance as an ongoing program rather than a one-time project are better positioned to reduce risk, maintain customer trust, and support long-term contract eligibility. By focusing on defensibility, accountability, and continuous improvement, contractors can strengthen their security posture while meeting federal requirements. Key takeaways: • Compliance is an ongoing responsibility, not a point-in-time achievement • Documentation and evidence are essential for demonstrating compliance • Accurate scoping and asset identification are critical for CMMC success • Regular reviews help identify and address gaps before they become larger issues • A mature security program supports both compliance and business resilience Timestamps 00:00 Introduction and Speaker Backgrounds 01:10 Why Companies Pursue CMMC Certification 02:30 The Problem with the "Checkbox Compliance" Mindset 04:00 CMMC as an Ongoing Program, Not a Project 05:50 Annual Affirmations and Continuous Compliance 07:20 Why Documentation Matters for Defensibility 08:50 Risks of Passing an Audit but Failing Compliance Later 10:15 Lessons from HIPAA and PCI Compliance Programs 12:15 Building a Defensible Security Program 13:30 What the False Claims Act Means for CMMC Contractors 15:20 FCA Penalties, Treble Damages, and Liability 16:40 How Whistleblowers Trigger FCA Investigations 18:15 Real-World False Claims Act Cases 20:00 Prime Contractor and Supply Chain Risk 22:15 Personal Accountability for Annual Affirmations 24:00 Why Small Contractors Face Greater Risk 25:45 Certification Is Only the Beginning 27:20 DOJ Enforcement Trends and Increased Scrutiny 29:00 Common CMMC Compliance Gaps #CMMC #Cybersecurity #Compliance #NIST800171 #DFARS #DefenseContractors #DoD #FederalContracting #InformationSecurity #RiskManagement #GovernanceRiskCompliance #CUI #CyberRisk #SecurityCompliance #CMMCLevel2 ___________________________________________ About RKON Since 1998, RKON has helped private equity and enterprise firms achieve seamless, secure, and scalable IT through a proven strategy-to-execution approach. Headquartered in Chicago, we deliver transformation in three stages: advisory, execution, and ongoing management—ensuring IT aligns with business goals at every step. ___________________________________________ Connect with RKON Find RKON on social media Facebook: https://bit.ly/2TxDNvC Twitter: https://bit.ly/3k3oCFQ Instagram: https://bit.ly/3e6qsnl LinkedIn: https://bit.ly/2HHtouA RKON 328 S. Jefferson St. Suite 450 Chicago, Illinois 60661 Call (312) 654-0300