Safeguarding CUI: Why the National Security Strategy Turns Cyber Compliance Into Counterintelligence

For years, cybersecurity compliance in the Defense Industrial Base (DIB) has been framed as an IT problem. A checklist. A maturity model. Something to survive long enough to pass an audit.

The November 2025 National Security Strategy of the United States makes clear that era is over.

The document does not mention CMMC by name, but it doesn’t need to. Its language fundamentally reframes how the U.S. government views cyber risk across the defense supply chain. The shift is unmistakable: cybersecurity is no longer about protecting systems; it is about preventing adversaries from exploiting data, access, and trust.

For defense contractors, that has profound implications for safeguarding CUI.

From Cyber Hygiene to Counterintelligence

The Strategy repeatedly emphasizes threats that go well beyond routine cybercrime. It highlights:

• “Grand-scale intellectual property theft and industrial espionage”

• “Threats against our supply chains that risk U.S. access to critical resources”

• “Persistent threats to U.S. networks, including critical infrastructure”

  
  

This is not the language of IT best practices. It is the language of counterintelligence.

The document frames hostile cyber activity as a strategic weapon, used to undermine military readiness, hollow out industrial capacity, and extract sensitive information without firing a shot. In that context, mishandling Controlled Unclassified Information is no longer a technical failure. It is a national security exposure.

Why Safeguarding CUI Is Now a Strategic Obligation

The Strategy states plainly that the United States must “protect our intellectual property from foreign theft,” and that American economic and military power depend on preserving technological and industrial advantages.

For the DIB, CUI is where those advantages live.

Engineering drawings. Program data. Test results. Operational details. Contract performance information. All of it represents intelligence value to adversaries. And all of it increasingly sits outside traditional DoD networks, inside contractor environments.

That reality drives a clear expectation embedded throughout the Strategy: organizations must know their risk surface, not assume it.

Safeguarding CUI now means being able to answer, with confidence:

• Where does sensitive data actually reside?

• Who has access to it—human and system?

• How does it move across internal and external boundaries?

• What third parties inherit that access through workflows and integrations?

Anything less is no longer “immature security.” It is blindness.

The Death of Paper Compliance

One of the most consequential implications of the Strategy is what it signals about enforcement posture.

The document stresses competence, accountability, and merit, warning that complex systems “will cease to function” if those principles are undermined. Applied to cybersecurity, that is a direct rebuke of performative compliance.

In practical terms, this means:

• Policies without evidence will not hold up

• Diagrams without data validation will fail scrutiny

• Self-attestations that collapse under discovery will not be forgiven

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“Paper compliance” is no longer just ineffective. It is legally and reputationally radioactive.

This Strategy provides the policy foundation for aggressive use of existing enforcement mechanisms—False Claims Act actions, contract termination, suspension, and debarment—once cybersecurity representations become contractual claims.

CUI Mishandling as a Supply-Chain Threat

The Strategy repeatedly ties cybersecurity to supply-chain security, noting that adversaries target the “defense industrial base and defense-related production capacity” precisely because of its distributed nature 2025-National-Security-Strategy.

That means CUI exposure at a subcontractor is not viewed in isolation. It is viewed as:

• A vector into prime programs

• A means of mapping weapons systems and capabilities

• A way to degrade readiness without direct confrontation

  
  

Safeguarding CUI is therefore no longer about protecting your organization. It is about preserving collective defense integrity.

What This Means for DIB Leadership

The National Security Strategy draws a bright line: cybersecurity failures that expose sensitive data are strategic failures.

DIB leaders should take note:

• If you cannot locate and classify your CUI, you cannot credibly protect it

• If you cannot show who accesses it, you cannot claim control

• If you rely on documentation instead of verification, enforcement risk compounds

The Strategy does not threaten contractors—it redefines their role. Industry is no longer adjacent to national security. It is embedded within it.

And in that reality, safeguarding CUI is not a compliance exercise. It is a counterintelligence responsibility.

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