Executive Snapshot

How Alaska Native Corporations can manage CMMC 2.0 flow-down requirements to subsidiaries and vendors. Protect your 8(a) contracts.

  • Align telemetry, human process, and automation.
  • Instrument every control with real owners.
  • Transform insights into runbooks operators can execute.
CMMC 2.0 Flow-Down: A Practical Guide for Alaska Native Corporations

Legacy Gaps

  • Static controls that cannot flex with live incidents.
  • Orphaned processes without telemetry back to leadership.
  • Manual documents that fall out-of-date within weeks.

Ultra Moves

  • Instrumented responses tied to Borealis Ultra runbooks.
  • Shared situational picture across exec, ops, and engineering.
  • Continuous validation with readouts your board will trust.

As a parent corporation, you are responsible for ensuring your subsidiaries and vendors meet the new CMMC 2.0 standards. Here is how to manage the complexity.

The Flow-Down Challenge

Under DFARS 7012 and CMMC, prime contractors must flow down security requirements to any subcontractor handling CUI (Controlled Unclassified Information). For ANCs with diverse portfolios (construction, tech, logistics), this creates a massive governance challenge.

Strategies for Portfolio Management

  • Centralized vs. Decentralized: Should you push a single IT stack to all subs, or let them manage their own?
  • The "Enclave" Approach: Isolate CUI handling to a specific secure environment within the subsidiary to avoid dragging the whole company into Level 2.
  • Shared Services: Use the parent corp's security team to provide monitoring (MDR) and CISO services to smaller subs.

3 Steps to Start Today

  1. Inventory Contracts: Which subs actually have DFARS clauses today?
  2. Map CUI Flow: Where does the data go?
  3. Gap Assessment: Run a NIST 800-171 assessment on the critical subs first.

Need Help with Governance?

Our vCISO service specializes in ANC portfolio management.

Explore ANC Solutions

Borealis Field Case // Arctic Ops

A Northern operator faced compounding pressure across cloud, OT, and lean staffing. We rebuilt their response stack around Ultra modules, synced telemetry to a single console, and cut containment time by 64%.

Need an Ultra-grade response plan?

We’ll pressure-test your environment, script the containment moves, and stay on the net until signal improves.