http://danielkiehl.com/topics/cui--cmmc/Recent content in CUI & CMMC on Dan KiehlHugoen-usMon, 26 Oct 2026 00:00:00 +0000http://danielkiehl.com/articles/cui-authorized-holder-without-cmmc/Mon, 26 Oct 2026 00:00:00 +0000http://danielkiehl.com/articles/cui-authorized-holder-without-cmmc/<p>A prime contractor for a government agency sends you, a subcontractor, a drawing package marked CUI. The contract has no DFARS 252.204-7012, no CMMC level, and no CUI clause anyone can find. The question that follows is whether the company has any obligation to protect it, or whether CUI is really a DoW and CMMC problem.</p> <p>The confusion makes sense. For most of the defense industrial base, CUI compliance has meant CMMC for years, and 32 CFR Part 2002 says it applies to executive branch agencies.</p>