Jim Motes

Today’s San Antonio Chapter of CFMA lunch reminded me why cross-functional learning is one of the most underrated risk management tools we have. Here are the three insights that hit hardest for me: 1. Tax changes create security gaps. Rushed tech purchases to capture bonus depreciation or R&D credits often skip security vetting and that’s where exposure creeps in. 2. Construction firms face rising cyber risk. According to the Dodge Construction Network, 59% of construction firms experienced a cybersecurity threat over a two year period. The industry’s complexity makes it a prime target. 3. Finance + IT disconnect = avoidable risk. In most of the firms I talk to, finance leaders can’t list all of the cloud tools their project teams rely on. This is a blind spot attackers love. Takeaway: Your tax strategy, growth plan, and cybersecurity posture aren’t separate. They’re interconnected systems that can either reinforce or undermine each other. Huge thanks to Kathryn Hall, Bradley Frantz, Nita McBride, and the speaker for today's session Shelley Woitena for an outstanding CFMA meeting. Also wanted to thank Denice Allison for the introduction to the San Antonio crew. What’s an unexpected place you’ve learned something critical about your business?

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CMMC Compliance Deadline: Are You Ready for October 1st?   The DoD’s latest update to 48 CFR Part 204.75 makes it official: CMMC certification is mandatory for contractors starting October 1, 2025. If your organization handles Federal Contract Information (FCI) or Controlled Unclassified Information (CUI), you must be certified to bid, renew, or extend DoD contracts. 🎯 Don’t risk disqualification. As a CMMC Registered Practitioner Organization (RPO), Concertium helps defense contractors like you: * Assess and close compliance gaps * Build cybersecurity policies and procedures * Train your team and prepare for certification ⏳ Time is running out. Let’s get you ready before Phase 1 begins. 📅 Book your free consultation today: concertium.com/cmmc-rpo

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“PCI SSC has seen comments…” 👀 -Assessor Newsletter, June 2025 A few weeks ago, I raised a flag about FAQ 1597 and the related infographic, where the language suggested that acceptance of lower-risk vulnerabilities wasn’t on the table. That post gained great traction and sparked important conversations in the community. Well, the PCI Security Standards Council has now responded. In their June 2025 Assessor Newsletter, they stated: ✅ Clarification (main bullet points summarized): - “Addressed” ≠ “Resolved.” - Examples of "addressed" where not an exhaustive list. - Low-risk vulnerabilities can be accepted—if justified by a Targeted Risk Analysis (TRA). - Addressing a vulnerability may mean fixing it, compensating for it, disabling it, or accepting the risk. - The TRA must be reviewed annually to ensure it still reflects the environment and risk tolerance. This clarification is welcome—but also tacit acknowledgment that feedback from assessors and the broader community (yes, some of those comments they saw were from you all) helped make it happen. 📌 Next step for the Council: Update FAQ 1597 and the DSS itself at some point to reflect this broader interpretation. The ambiguity in the official text still risks confusion and audit inconsistencies. As of this posting date, the only place this clarification exists is within the assessor newsletter. 🤨 One nitpick I will call out though— the Council called out that their original definition of “addressed” wasn’t all inclusive. However, words matter. For a reminder, this was the definition: Addressed - the entity determines whether to resolve the vulnerability or to mitigate the risk by addressing the vulnerability in another way (e.g., with a compensating control or by disabling a vulnerable service) So to be clear, their definition says resolve OR mitigate. How were we to infer that acceptance is acceptable!?! 🤷‍♂️ If you’re a QSA or manage PCI in your organization, this is a significant development. It gives you back the flexibility to treat low-risk issues rationally, as long as your TRA process is strong. Thank you to Viviana W. for letting me know about the publication within the newsletter! #PCIDSS #CyberSecurity #QSA #VulnerabilityManagement #GRC #PCICompliance #InfoSec #AssessorLife

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Audits and forensics aren’t witch-hunts to “name the hacker.” They’re how you stop the next breach. A good audit/forensic review will: Expose misconfigurations and control gaps Surface broken processes (people • tech • vendors) Produce a clear timeline to improve response Provide evidence for insurance claims and regulators Demonstrate senior management intent and due diligence One breach costs more—in money, trust, and time—than doing the work properly up front. At Tylers, we turn incidents into hardening plans: fixes, owners, deadlines. Not blame—better security. #CyberSecurity #DigitalTrust #Forensics #Audit #IncidentResponse #Tylers

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