Contractors can determine CUI and ITAR episode artwork

EPISODE · Jun 5, 2026 · 15 MIN

Contractors can determine CUI and ITAR

from NISPOM Central-Working with National Industrial Security Program

Send us Fan Mailhttps://www.thriveanalysis.com. For consultinghttps://www.nispomcentrial.com for books and traininghttps://www.skool.com/nispomcentral/about for Nispom central communityDue Diligence: Contractors’ Responsibility to Identify and Protect CUI and Sensitive InformationJeff Bennett of Thrive Analysis Group and NISPOM Central argues that the common claim “contractors are not authorized to determine CUI” is bad advice that leads people to ignore their responsibility to identify, mark, and protect sensitive information in their work products. He says contractors are authorized to apply derivative markings based on government instructions and must exercise “presumption of care” (duty of care) to prevent applied research, controlled technologies, export-controlled information (EAR/ITAR), proprietary data, PII, and CUI from entering the public domain, which can harm warfighters and technology. Citing examples of ITAR data nearly published and CUI text copied into deliverables, he emphasizes repeatable processes, reasonable standards aligned to NISPOM, DD Form 254, DFARS, CMMC, and NIST SP 800-171, plus marking by default and reviewing materials before release.00:00 Contractors Can Mark CUI01:05 Stopping the Big Mouth02:33 Bad Advice in Defense03:41 Due Diligence Basics05:55 When Research Turns Sensitive06:57 Real World CUI Slipups09:34 No CUI Police Myth10:41 Presumption of Care11:21 Derivative Marking Process12:12 Protect Warfighters and Wrap UpNISPOM CentralProviding security clearance books, training, and resources for cleared defense contractors.Clearance, NISPOM, and FSO ConsultingThrive Analysis Group Inc is your resource for security clearance, NISPOM, and FSO consulting.NISPOM StoreOur StoreNISPOM Central CommunityThe skill building community for FSOs who desire to progress in a measured way. Disclaimer: This post contains affiliate links. If you make a purchase, I may receive a commission at no extra cost to you.Support the showFSO Consulting:https://thriveanalysis.comNISPOM Compliancehttps://www.nispomcentral.comhttps://www.nispom.comThe Trusted Advisor for Technology Protection, FSO and NISPOM consulting. After dialing in my craft and many years of honing program protection experiences, I became a trusted advisor. I am currently supporting customers with technology protection and NISPOM compliance topics.INDUSTRIAL SECURITY TRUSTED ADVISORWhat Trusted Advisor Involves:I partner with executive leadership to design and operate security programs that meet and exceed NISPOM requirements. Results you can measure immediately:Prepared commercial organizations for defense contracting and NISPOM complianceDesigned ready to implement security programs before, during and after facility clearance awardRescued high risk security programs with quick turnaround; usually within 30 daysAchieved Commendable and Superior DCSA review ratingsDeveloped compliant FOCI mitigation programs

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Send us Fan Mail https://www.thriveanalysis.com. For consulting https://www.nispomcentrial.com for books and training https://www.skool.com/nispomcentral/about for Nispom central community Due Diligence: Contractors’ Responsibility to Identify and Protect CUI and Sensitive Information Jeff Bennett of Thrive Analysis Group and NISPOM Central argues that the common claim “contractors are not authorized to determine CUI” is bad advice that leads people to ignore their responsibility to identif...

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