38North Security: A CMMC Registered Provider Organization (RPO)

As a designated RPO, 38North’s US Department of Defense (DoD) security expertise has been validated by the CMMC-Accreditation Body (AB). We prepare organizations to advance along the maturity model and position themselves for success supporting US DoD.

38North is a Proven US DoD Security Provider

CMMC is in its infancy. No organization – including 38North – can claim to have much experience applying the CMMC.

However, 38North’s team of Senior Advisors have decades of experience helping the private sector interpret and implement DoD directives and security policy. From applying the RMF for DoD IT to field deployed systems, to designing secure cloud architectures for sensitive applications, we help complex organizations rapidly meet DoD security requirements. 

CMMC: A Complex, Pass-Fail Approach to Cybersecurity

The US DoD is starting an aggressive cybersecurity review of companies within the Defense Industrial Base (DiB). The 100,000+ companies that do business with DoD must earn a Cybersecurity Maturity Model Certification (CMMC) by being assessed against one of the five designated Maturity Levels.

The CMMC is unique among security standards in that companies are encouraged to continuously advance their security programs in order to achieve ever higher CMMC Maturity Levels. Sensitive, more advanced DoD programs will require higher maturity, making progress along the CMMC maturity model an important differentiator for defense contractors.

The CMMC requires that Maturity Level achievement be independently tested by Certified Assessors (CA) and validated by an accredited CMMC Third-Party Assessment Organization (C3PAO). Additionally, CMMC operates using a pass-fail model, where all practices and processes must pass at time of assessment to achieve CMMC certification. Any individual weakness is enough to halt a company’s CMMC progress.

CMMC Approach

38North can help you climb the CMMC maturity ladder. CMMC compliance is a moving target. While the individual controls are finalized, no one really knows how the CMMC-AB and DoD will interpret compliance. Much of this uncertainty, including proper use of external services, metadata security, scan coverage requirements and boundary guidance, has a major impact on system design and operation.

Backed by our experience supporting DoD, and our network of partnerships across the C3PAO community, we can help you navigate this uncertainty. We design enduring architectures and evidence-based approaches that will withstand DoD scrutiny.

Our CMMC approach begins by tracing flows of Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) within your organization. This helps us define a system boundary of in-scope assets, while excluding those that do not fall under the CMMC’s purview.

With the boundary scoped we then help you identify and resolve gaps. Our CMMC services include:

CMMC Workshops:

Our workshops combine introductory CMMC training with boundary development and hands-on consulting to get you started on your CMMC journey. We also help make sense of lingering CMMC confusion by drawing on DoD best practices to help you design systems and approaches that will withstand CMMC assessments.

CMMC Gap Analysis:

Gap analyses help defense contractors wrap their heads around what they’ll need to do to comply with the CMMC. Our CMMC gap analysis will determine your gaps against the various maturity levels. We also deliver a prioritized roadmap of actions required to close gaps and ensure a clean assessment.

CMMC Advisory Support:

38North’s senior DoD security advisors can help you design, deploy, document and maintain a scalable security approach that efficiently meets your desired CMMC maturity level. We can also help you plan for a more secure future by laying the groundwork for the achievement of ever higher maturity levels.

CMMC Pre-Assessment Support:

If you’re preparing for your first CMMC assessment but need some assistance, let our experienced CMMC consultants handle the hassle of dealing with a C3PAO. We are well-versed with the quirks of the formal assessments and can expeditiously resolve findings and streamline the authorization process. We also have relationships across the C3PAO community to help resolve misunderstandings and facilitate a smooth assessment.

CMMC Remediation Support:

This service is for those defense contractors that recently fell short on their CMMC assessment. We help plan, develop and implement remedial measures. This may come in the form of new technologies, policies, plans, procedures or training and awareness sessions. It may also mean tailoring current organizational processes to squeeze a little more out of existing investments.

Next Steps

Contact us to get started. The first step is a one hour introductory and readiness session, to understand your business landscape and gather technical details, while also making sure that we’re a mutual fit. We also offer unbilled follow up calls if you have any additional questions, or need consulting advice as you gear up for CMMC.

Following our initial meetings, formal proposals and pricing are submitted within approximately one week. We can kick-off with a dedicated senior-level team within two to three weeks of contract signature.

Jeremiah Thompson

Director of Cloud Security Architecture

Jeremiah Thompson is 38North’s Director of Cloud Security Architecture. He leads 38North’s technical teams as they tackle engineering challenges and design secure, compliant cloud security architectures.

For over 18 years Jeremiah has helped clients in the commercial, defense and federal civilian sectors engineer secure solutions to modern cyber challenges. Prior to 38North, he served as a Director at Coalfire, one of the nation’s preeminent Third-Party Assessment Organizations (3PAOs). At Coalfire he led FedRAMP and DoD FedRAMP+ assessments supporting Fortune 500 organizations. He was also a Lead Information Security Compliance Auditor supporting the National Cancer Institute, and an Information Security Compliance Auditor at IBM.

Jeremiah currently holds CISSP, CISM, CAP, C|EH, Security+, Network+, CCSK and MCP certifications.

Andy Davidson

Senior Director of Cloud Security

Andy Davidson is Senior Director of Cloud Security at 38North. He leads 38North Senior Advisors as they prepare IaaS, PaaS and SaaS providers for the rigors of FedRAMP authorization. One of the nation’s most experienced FedRAMP practitioners, Andy has been supporting FedRAMP assessment and consulting efforts since the initial FedRAMP pilot project. He specializes in helping hyperscale Cloud Service Providers (CSPs) navigate FedRAMP requirements and successfully achieve Provisional Authorities to Operate (P-ATO).

Prior to 38North, Andy was Senior Director of FedRAMP and Assessment Services at Coalfire, one of the leading Third-Party Assessment Organizations (3PAOs). At Coalfire, he was responsible for growing the 3PAO practice and managing assessor teams in the execution of high profile assessments for Fortune 500 CSPs. He also helped start Veris Group’s 3PAO practice. Prior to Veris, Andy was an IT security consultant at Booz Allen Hamilton, supporting security assessments and engineering efforts across the federal government.

Linda Morales

Senior Director of Global Compliance

Linda Morales is the Senior Director of Global Compliance at 38North Security. She leads assessments for customers in the healthcare, federal and commercial spaces. She specializes in helping organizations prepare for and complete FISMA, FedRAMP and HIPAA assessments. She is adept at leading teams to deliver efficient, accurate security reviews that withstand scrutiny from federal regulators. Linda is also a recognized expert in Healthcare security, helping Health-IT providers secure and defend Protected Health Information (PHI).

Prior to 38North, Linda served as a Director at Endeavor Systems, where she played a key role growing the federal security services practice. She also served as Security Manager for the Federal Aviation Administration’s (FAA) enterprise-wide assessment program, with responsibility for 150+ systems across FAA.

Linda earned a BS in Computer Science and a Masters in Engineering Management, with a focus in Information Security, both from The George Washington University. She is also a Certified Information Systems Security Professional (CISSP), Project Management Professional (PMP), and a Registered Practitioner with the Cybersecurity Maturity Model Certification Advisory Board (CMMC-AB).

Spence Witten

Senior Advisor and Director of Business Development

Spence Witten is a 38North Senior Advisor and Director of Business Development. He serves as a trusted security advisor to 38North’s clients in the cloud services, healthcare, financial, defense and critical infrastructure communities.

Prior to 38North, Spence was Vice President of Global Sales at Lunarline. Spence led sales and marketing across ten cybersecurity business units, culminating in Lunarline’s acquisition by Motorola Solutions. Prior to becoming VP of Global Sales, Spence ran Lunarline’s US Federal Security Services practice, overseeing Lunarline’s defense, intelligence and federal civilian portfolio. He was also an early employee of Endeavor Systems. He played a key role in Endeavor’s rapid expansion in the federal, civilian, defense, and research and development markets, through to Endeavor’s successful acquisition.

An Adjunct Professor at Cleveland-Marshall College of Law, Spence serves on the Board of Directors for the Center for Cybersecurity and Privacy Protection at Cleveland State University. He is also a member of CyberOhio, the official cybersecurity advisory board for the Governor of Ohio.

Virginia Suazo

Senior Director of Cloud Security Advisory

Virginia Suazo is 38North’s Senior Director of Cloud Security Advisory. She is responsible for leading 38North’s cloud security and compliance efforts, with a speciality in helping global CSPs juggle multiple overlapping regulatory frameworks.

Before joining 38North, Virginia worked at a tech startup supporting the first and only Red Hat OpenStack Platform that is FedRAMP-authorized. She played a vital role in successfully obtaining FedRAMP Moderate and High authorizations for IaaS, PaaS, and SaaS systems, while supporting other certifications including DoD IL4/5, PCI DSS, HIPAA and HITECH. Her 15 years of cybersecurity experience also includes several tours supporting US federal agencies, including State Department, Department of Justice, Health and Human Services, Food and Drug Administration, General Services Administration and Department of Transportation.

Matt Earley


Matt Earley is 38North’s founder and President. He started 38North – the premier cloud security advisory company, in the US and internationally – to solve complex security challenges while developing trusted relationships with an elite client base.

For over 20 years Matt Earley has designed and implemented security solutions for the US and Australian federal governments, critical infrastructure, utilities, and for global finance and healthcare organizations. He focuses on lean security architecture design and prioritizing security efforts based on the critical needs of his clients.

Prior to founding 38North, Matt was the director of federal services at Endeavor Systems, where he was responsible for Endeavor’s largest business unit, serving the Federal Aviation Administration, Department of Homeland Security and some of the world’s largest security operations centers. He was also a Senior Manager in the Australian Department of Defense, where he represented Australasia on the Common Criteria Management Board.

Matt has a Bachelor of Engineering in computer engineering from the University of Canberra in Australia, and a Master’s in engineering management from George Washington University. He also is a Certified Information Systems Security Professional (CISSP) and Project Management Professional (PMP).