60% of C3PAO Assessments Fail on First Attempt

Don't Fail Your CMMC Assessment on Insider Risk

Most failures aren't from encryption or firewalls—they're from insider threat controls. We make sure you pass.

Most defense contractors think they're ready for CMMC. They've implemented encryption, configured firewalls, deployed endpoint protection. Then they fail their C3PAO assessment on Personnel Security (PS), Access Control (AC.L2-3.1.5), and Awareness Training (AT.L2-3.2.3) requirements.

A failed assessment costs you $15k-30k in wasted fees, 6-12 months to remediate, and if you miss your deadline, you lose the contracts that fund your business.

We've spent 20+ years building insider threat programs for Fortune 100 companies. We know exactly what C3PAO assessors look for—and what fails assessments.

Schedule Free Gap Assessment

Why Companies Fail CMMC Insider Risk Requirements

These three gaps cause the majority of C3PAO assessment failures

Gap #1: Personnel Security

  • No pre-employment screening process
  • No ongoing monitoring of personnel behavior
  • No formal termination/transfer procedures
  • No subcontractor vetting framework

Gap #2: Subcontractor Transparency

  • Unknown personnel accessing systems
  • Offshore developers with no visibility
  • Cloud admins from foreign-owned companies
  • No framework for foreign national disclosure

Gap #3: Behavioral Monitoring

  • Generic awareness training (not insider-threat focused)
  • No behavioral analytics or anomaly detection
  • No designated insider threat program manager
  • No incident reporting procedures

These gaps fail C3PAO assessments. We fix them.

Schedule Assessment

What an Insider Threat Program Actually Looks Like

The four components that pass C3PAO scrutiny

Personnel Vetting

  • Background checks before CUI access
  • Foreign national disclosure requirements
  • Periodic re-screening procedures
  • Documented screening policies

Access Governance

  • Least privilege enforcement (AC.L2-3.1.5)
  • Quarterly access reviews
  • Automated provisioning/deprovisioning
  • Role-based access control (RBAC)

Behavioral Analytics

  • User behavior monitoring (UBA/UEBA)
  • Data exfiltration detection
  • Anomalous access pattern alerts
  • Integration with SIEM/EDR tools

Awareness Training

  • Insider threat indicators (AT.L2-3.2.3)
  • Reporting procedures and whistleblower protections
  • Social engineering awareness
  • Quarterly training updates

Your Path to CMMC Certification

✓

Gap Assessment: 2-3 weeks

✓

Implementation: 6-10 weeks

✓

C3PAO Ready: 8-12 weeks total

CMMC Insider Risk Compliance Packages

Comprehensive services to get you C3PAO-ready

Gap Assessment

Starting at $18,000

One-time assessment

Perfect For:

  • Organizations unsure if they need CMMC
  • Companies preparing for Level 2 certification
  • Contractors who failed their first C3PAO attempt

What's Included:

  • 2-3 day comprehensive assessment
  • Personnel security baseline review
  • Access control audit (AC.L2-3.1.5)
  • Awareness training gap analysis
  • Subcontractor risk evaluation
  • Prioritized remediation roadmap with cost estimates

Timeline: 2-3 weeks

Deliverable: Gap analysis report + 90-day implementation plan

Schedule Gap Assessment

Program Implementation

Starting at $48,000

Full implementation

Perfect For:

  • Companies with CMMC deadline in 4-6 months
  • Organizations that identified gaps but need implementation help
  • Contractors preparing for C3PAO assessment

Everything in Gap Assessment, PLUS:

  • Full insider threat program design
  • Personnel vetting procedures + templates
  • Subcontractor personnel disclosure framework
  • Access governance implementation (least privilege, MFA)
  • Behavioral monitoring roadmap
  • Awareness training program (includes phishing simulation)
  • Policy suite (insider threat, acceptable use, BYOD)
  • CMMC self-assessment preparation

Timeline: 8-10 weeks

Deliverable: Fully operational insider risk program + CMMC Level 2 readiness

Get Started

C3PAO Assessment Support

Starting at $75,000

+ $12k/month retainer

Perfect For:

  • Companies targeting CMMC Level 3
  • Organizations with complex supply chains
  • Contractors with 150+ employees

Everything in Program Implementation, PLUS:

  • Full insider threat operations center setup
  • Advanced behavioral analytics deployment
  • Supply chain personnel transparency program
  • Offshore development risk assessment
  • Designated insider threat program manager training
  • C3PAO assessment preparation & support
  • Quarterly program audits
  • Annual penetration testing (insider threat scenarios)
  • Monthly monitoring, attestation support, control testing

Timeline: 12-16 weeks + ongoing

Deliverable: C3PAO-ready insider risk program with continuous compliance support

Schedule Consultation

Note: Prices shown are example starting costs. Final pricing requires individual scoping based on your organization's size, complexity, and specific requirements. Contact us for a customized quote.

Why Defense Contractors Choose SPM Advisors

20+ Years Insider Threat Expertise

Kenneth Vignali spent 8 years in Army protective operations at federal levels, then built insider threat programs for Fortune 100 companies at Dell SecureWorks and GuidePoint Security. We've seen what works—and what fails C3PAO assessments.

Insider Risk Consortium Member

We're active members of the Insider Risk Consortium, the leading community advancing insider threat detection and prevention. You get access to cutting-edge best practices and threat intelligence.

InfraGard Partnership

Our partnership with InfraGard (FBI collaboration) means we have real-time insight into nation-state insider threat tactics, including China's National Intelligence Law implications for your supply chain.

Published Legal Analysis

We just published the industry's most comprehensive legal analysis on CMMC insider risk requirements, filling gaps that even major defense contractors missed. Read the Paper

Recent Success: $48k Implementation Saved $250k+ in Contracts

Client Profile: 75-employee IT services contractor (NAICS 541519), preparing for first C3PAO assessment

The Problem

  • Offshore developers in their supply chain (no personnel visibility)
  • Cloud admins with excessive privileges
  • No behavioral monitoring
  • Generic awareness training (not CMMC-compliant)

The Solution

  • 8-week insider threat program implementation
  • Personnel vetting framework
  • Access governance overhaul
  • Behavioral analytics deployment
  • CMMC-specific training
  • ✓ Passed C3PAO assessment on first attempt
  • ✓ Avoided $15k-30k failed assessment costs
  • ✓ Met CMMC deadline—retained $250k+ in annual contracts
  • ✓ Now positioned for Level 3 certification

"We thought we had CMMC handled until Kenneth's gap assessment showed us the insider risk blind spots. His team got us compliant in 8 weeks. We passed our C3PAO on the first try."

CMMC Insider Risk FAQs

If you're in the Defense Industrial Base supply chain (even as a sub-sub-contractor) and handle Controlled Unclassified Information (CUI), yes. Many companies don't realize they're subject to CMMC until a prime contractor sends them certification requirements. Our gap assessment includes a CMMC applicability review—we'll tell you definitively if you need it and what level.
Most cybersecurity programs focus on technical controls (encryption, firewalls, EDR). CMMC insider risk requirements are different—they focus on Personnel Security (PS), Access Control governance, and behavioral monitoring. Even sophisticated programs usually miss these. Our gap assessment identifies exactly what you're missing.
For Level 1 and some Level 2 contracts, yes. But self-assessments have a 60%+ failure rate when validated because companies don't know what assessors actually look for. We've built insider threat programs for Fortune 100 companies—we know exactly what passes and what fails. Our implementation ensures you pass the first time.
You waste $15k-30k in assessment fees, spend 6-12 months remediating, then reschedule (another 4-8 week wait). If you miss your CMMC deadline, you lose the contracts. Failed assessments are expensive and avoidable—our programs are designed specifically to pass C3PAO scrutiny.
Yes. Subcontractor transparency is one of the three critical gaps we fix. We help you identify who's accessing your systems, where they're located, what foreign legal obligations they face (China NIL is a big issue), and implement disclosure/vetting frameworks that satisfy C3PAO requirements.
Gap assessment: 2-3 weeks. Full implementation: 6-10 weeks. C3PAO assessment after you're ready: 4-8 weeks. Total: 12-20 weeks from start to certification. If your deadline is 6 months away, you need to start immediately.
This is exactly what we address. Offshore developers and cloud admins create insider risk vectors that fail CMMC assessments. We evaluate your supply chain, assess foreign legal compulsion risks (especially China's National Intelligence Law), and implement transparency/mitigation controls that satisfy C3PAO requirements without disrupting your operations.
Yes. While we're based in Lynchburg, VA, we serve defense contractors nationwide, with regional coverage extending to Utah, Idaho, and Wyoming. Most of our work is remote, with on-site options for complex implementations.

Don't Fail Your CMMC Assessment on Insider Risk

You've invested in encryption, firewalls, and endpoint protection. Don't let insider threat controls—the #1 CMMC failure point—cost you your contracts.

Free 20-Minute Gap Assessment

  • We'll review your situation and tell you:
  • • If you're actually vulnerable
  • • What controls you're missing
  • • Rough timeline and cost to fix

No pressure, no sales pitch. Just honest assessment from someone who's built these programs for 20+ years.

Schedule Free Assessment

Download Our CMMC Insider Risk Paper

  • Our comprehensive legal analysis on CMMC insider risk requirements:
  • • Gaps even major defense contractors miss
  • • China's National Intelligence Law implications
  • • Supply chain personnel transparency requirements
Download Paper

Kenneth Vignali, Founder

SPM Advisors

kenneth@spmadvisors.net | (434) 602-5418

Insider Risk Consortium Member | InfraGard Partner | 20+ Years Cybersecurity Experience