CMMC 2.0 Scoping Guidance Limits the Scope of Cybersecurity Assessments
Client Alert | 1 min read | 12.23.21
The Department of Defense (DoD) recently released the initial guidance documents for Version 2.0 of its Cybersecurity Maturity Model Certification (CMMC) program, including its much-anticipated Scoping Guidance. While the guidance documents generally adhere to the current requirements for the protection of Federal Contract Information (FCI) and Controlled Unclassified Information (CUI), the Scoping Guidance includes notable developments. Chief among them is the introduction of two asset categories — “Specialized Assets” and “Contractor Risk Managed Assets” — that could potentially limit the scope of a contractor’s CMMC assessment, as well as the number and types of assets to be assessed against the applicable CMMC practices.
- Specialized Assets include government property; internet of things (IoT) and industrial internet of things (IIoT) devices; operational technology; systems configured based entirely on government requirements and used to support a contract; and test equipment.
- Contractor Risk Managed Assets include computing resources that are capable of handling CUI but are prevented from doing so by the contractor’s security policies, procedures, and practices.
Contractors expecting to be subject to CMMC should carefully review the Scoping Guidance, as well as the other guidance documents, to determine whether and how they may wish to limit the scope of CMMC’s applicability.
Contacts

Partner and Crowell Global Advisors Senior Director
- Washington, D.C.
- D | +1.202.624.2698
- Washington, D.C. (CGA)
- D | +1 202.624.2500
Insights
Client Alert | 4 min read | 04.09.26
DOJ Establishes National Fraud Enforcement Division
On April 7, 2026, Acting Attorney General Todd Blanche issued a memorandum establishing the National Fraud Enforcement Division (NFED) within the U.S. Department of Justice (DOJ). This new division will be dedicated to the centralized, coordinated investigation and prosecution of fraud against taxpayer dollars and taxpayer-funded programs. AAG Blanche acknowledged that, while DOJ has a “storied history of combatting fraud,” DOJ has “never adopted a comprehensive and coordinated approach to investigating and prosecuting fraud against taxpayer dollars and tax-payer funded programs.” The NFED was created to close that gap with its core mission being to “zealously investigate and prosecute those who steal or fraudulently misuse taxpayer dollars.”
Client Alert | 2 min read | 04.09.26
OMB Issues New Policy on Federal IT Transparency and Acquisition Oversight
Client Alert | 3 min read | 04.09.26
Preserve It or Lose It: A Missing Jury Instruction Costs Columbia University $94M in Damages
Client Alert | 5 min read | 04.09.26
U.S. State Privacy Enforcement: Key Priorities and Practical Guidance From State Regulators

