OSC — Am I in scope?

Advisory • Assurance • Audit — The Foundation of Readiness

When a customer marks a document “CUI” that does not meet the definition under 32 CFR Part 2002, that document is overmarked — and accepting it expands your CMMC scope into systems that should never have been pulled in. A CCA on the decontrol process, when to use it, and the worked example that saved a manufacturer six figures of unnecessary architecture.

Overmarked CUI: How to Request Decontrol Under 32 CFR 2002.20 (And Why It Shrinks Your CMMC Scope)

When a customer marks a document “CUI” that does not meet the definition under 32 CFR Part 2002, that document is overmarked — and accepting it expands your CMMC scope into systems that should never have been pulled in. A CCA on the decontrol process, when to use it, and the worked example that saved a manufacturer six figures of unnecessary architecture.
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CUI in Microsoft Teams, SharePoint, and OneDrive: Scoping Guide for GCC High

The Microsoft 365 GCC High tenant becomes a CUI Asset under the CMMC Scoping Guide Level 2 the moment any service in it processes, stores, or transmits CUI — and most C3PAOs default to assessing the full tenant under all 110 Level 2 requirements unless the OSC documents a narrower boundary. Per 32 CFR § 170.19(c)(2), the SSP must describe the M365 architecture at the service level (SharePoint, OneDrive, Teams, Exchange) with the Microsoft Purview sensitivity labels, Conditional Access policies, and DLP rules that enforce the CUI boundary. The contractor whose CUI is "somewhere in the tenant" walks into a much larger assessment than the one whose CUI sits in a dedicated CUI site collection.
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Heather Smith

Herrington Editor Post Blog

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