CUI CRM Compliance Decision Tree: Is Your CRM CMMC-Ready?

Not sure if your CRM meets CMMC requirements for handling CUI? Walk through this decision tree. Each question leads to either the next verification step or identifies a specific gap requiring remediation.

This resource accompanies our CUI-Safe CRM guide and CMMC CRM compliance checklist.

Question 1: Does Your CRM Touch CUI?

Does your CRM store, process, or transmit any of the following?

• Emails with government contacts discussing contracts or technical work
• Opportunity records with contract values, NAICS codes, or technical requirements
• Contact records with government personnel clearance information
• Attached documents (SOWs, RFPs, technical specifications)

YES: Your CRM is in scope for CMMC. Proceed to Question 2.

NO: Verify this by auditing email sync settings and data entry practices. Most GovCon CRMs contain CUI even when teams believe they don't.

Question 2: Is the CRM FedRAMP Authorized?

Check the FedRAMP Marketplace for your CRM vendor and verify the authorization covers your specific deployment.

FedRAMP High or Moderate: Good foundation, but FedRAMP alone isn't CMMC compliance. Proceed to Question 3.

Not FedRAMP: GAP IDENTIFIED. Your CRM must either be FedRAMP authorized or you must document equivalent controls in your SSP. This is a significant remediation effort.

Question 3: Is Email Sync Classified?

When emails are synced to your CRM, is there a process (automated or manual) to classify content for CUI?

YES with classification: Proceed to Question 4.

NO classification: GAP IDENTIFIED. Email sync without classification is the #1 CUI exposure vector. See our email ingestion analysis for remediation.

Question 4: Are Access Controls Role-Based?

Can you restrict CRM access by role, ensuring users only see records they need for their job function?

YES with RBAC: Verify it's configured (not just available). Proceed to Question 5.

NO or not configured: GAP IDENTIFIED. CMMC requires least-privilege access. Configure RBAC or switch to a CRM that supports it.

Question 5: Are Audit Trails Complete?

Can you demonstrate who accessed what CUI, when, and what they did with it?

YES with user-level detail: Proceed to Question 6.

NO or partial logging: GAP IDENTIFIED. You need comprehensive audit logging that tracks CUI access at the record and field level. Many CRMs require add-on modules for this.

Question 6: Is Data Encrypted at Rest and in Transit?

Is all CUI in your CRM encrypted with FIPS 140-2 validated modules, both at rest and during transmission?

YES for both: Proceed to Question 7.

NO or unsure: GAP IDENTIFIED. Verify your CRM vendor's encryption implementation. FIPS 140-2 validation is required, not just 'AES-256.'

Question 7: Are AI Features Isolated?

If your CRM has AI features (summarization, scoring, auto-complete), does it process CUI through isolated, single-tenant infrastructure?