CMMC
DoD certification for cybersecurity maturity in defense supply chain
AEO
Global certification for low-risk supply chain security
Quick Verdict
CMMC mandates cybersecurity certification for DoD contractors protecting FCI/CUI, while AEO is voluntary customs status for low-risk traders securing supply chains. DoD firms adopt CMMC for contract eligibility; global traders pursue AEO for faster clearance and fewer inspections.
CMMC
Cybersecurity Maturity Model Certification (CMMC) 2.0
Key Features
- Three tiered certification levels for FCI, CUI, APTs
- C3PAO and DIBCAC third-party assessments for verification
- Direct mapping to 110 NIST SP 800-171 controls
- SPRS affirmations and eMASS reporting requirements
- Flow-down mandates across DIB supply chains
AEO
Authorized Economic Operator (AEO) Program
Key Features
- Risk-based supply chain security across 13 criteria
- Demonstrated customs compliance and infringement absence
- Robust records management and audit trails
- Financial solvency and viability assessments
- Mutual Recognition Agreements for cross-border benefits
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
CMMC Details
What It Is
Cybersecurity Maturity Model Certification (CMMC) 2.0 is a DoD certification framework verifying cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) in the Defense Industrial Base (DIB). It uses a tiered, risk-based model with three levels: Level 1 for basic FCI safeguards, Level 2 for CUI via NIST SP 800-171, and Level 3 for APT defenses adding NIST SP 800-172.
Key Components
- 14 domains (e.g., Access Control, Incident Response) with 17 practices (Level 1), 110 (Level 2), plus 24 enhanced (Level 3).
- Built on FAR 52.204-21, NIST SP 800-171 Rev 2, and NIST SP 800-172.
- Certification via self-assessments (Level 1/2), C3PAO (Level 2), or DIBCAC (Level 3), with POA&Ms limited to 180 days and SPRS/eMASS reporting.
Why Organizations Use It
Mandated for DoD contractors/subcontractors handling FCI/CUI, ensuring contract eligibility. Reduces breach risks, enhances supply chain trust, and provides competitive bidding advantages. Builds operational resilience and aligns with broader NIST frameworks.
Implementation Overview
Phased approach: scoping, gap analysis, remediation, assessment preparation, certification, sustainment. Applies to all DIB sizes, from SMEs to primes. Requires SSPs, evidence collection, annual affirmations; timelines 12-18 months for Level 2.
AEO Details
What It Is
Authorized Economic Operator (AEO) is a voluntary certification program established under the World Customs Organization (WCO) SAFE Framework of Standards. It designates compliant, low-risk businesses involved in international goods movement as trusted partners. The primary purpose is to secure supply chains while facilitating trade via risk-based customs controls and partnerships. Key approach includes self-assessment via harmonized SAQ (Criteria A-M), rigorous validation, and ongoing monitoring.
Key Components
- Four pillars: customs compliance, records/internal controls, financial solvency, supply chain security.
- 13 SAQ criteria groups covering training, data security, cargo/premises/personnel security, partners, crisis management, continuous improvement.
- Built on SAFE Framework; compliance model features initial validation, periodic re-validation, mutual recognition.
Why Organizations Use It
- Facilitation benefits: reduced inspections, priority clearance, cost savings (e.g., avoided exams).
- MRAs enable cross-border advantages.
- Enhances risk management, reputation, tender competitiveness; voluntary but strategic for trade efficiency.
Implementation Overview
- Phased: gap analysis, SOPs design, training, digital evidence/IT integration, mock audits.
- Cross-functional project for supply chain actors; 6-12 months typical; requires site audits, continuous governance.
Key Differences
| Aspect | CMMC | AEO |
|---|---|---|
| Scope | Cybersecurity for FCI/CUI in DoD contracts | Supply chain security and customs compliance |
| Industry | Defense Industrial Base (DIB), US-focused | International trade, logistics, global supply chains |
| Nature | Mandatory certification for DoD contractors | Voluntary trusted trader status |
| Testing | Self-assess/C3PAO/DIBCAC every 3 years | Customs validation, periodic re-validation |
| Penalties | Contract ineligibility, debarment | Status suspension/revocation, lost benefits |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CMMC and AEO
CMMC FAQ
AEO FAQ
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