If you are aware of German Christmas folklore (and really, who isn’t?), you know that Belsnickel is a legendary companion of St. Nick who carries a switch with which to punish naughty children and a pocketful of sweets to reward good ones. This holiday season, many are feeling the sting of a switch of another kind, this one involving the December 20, 2016, issuing by the National Institute of Standards and Technology (NIST) of a preholiday revision of Special Publication 800-171 (SP 800-171), Protecting Controlled Unclassified Information (CUI) in Nonfederal Information Systems and Organizations. If SP 800-171 sounds familiar, it is because the publication is the source of the cybersecurity controls that defense contractors must follow and flow down to subcontractors pursuant to DFARS Subpart 204.73 and its operative clauses (e.g., DFARS 252.204-7008 and DFARS 252.204-7012). Essentially accompanying St. Nick (perhaps Santa Clause may be more appropriate) this season, the NIST’s revised publication may resemble Belsnickel’s switch (pun intended) to contractors who already have existing SP 800-171 controls in place (as the controls have been required, in various forms, since November 2013) or who have started down the road toward SP 800-171 adherence in advance of the DFARS-directed December 2017 deadline. With that in mind, let’s take a quick look at the implications that switch (pun still intended) brings to the security requirements for protecting the confidentiality of CUI in nonfederal systems and organizations:

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Etymology, particularly the Greek or Latin roots of words, aids our understanding in much the same way as root cause analysis does. The Greek word for disclosure is αποκάλυψη, transliterated to apokálypsi, or “apocalypse.” Nomen est omen. This came to mind while reading the pronouncements proffered by various agencies this year – each of which influences voluntary disclosures of export control violations.

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