Virtru and CMMC Level 3: Understanding the Requirement & Where We Fit

If you're exploring CMMC Level 3 certification, you're handling some of the DoW's most sensitive CUI and preparing for contracts that require the highest level of cybersecurity maturity. You've probably also been evaluating which security solutions can help you get there.

We've had several defense contractors reach out recently asking how Virtru supports CMMC Level 3 compliance. It's a fair question, and one that deserves a clear answer about what Level 3 actually requires and where data protection fits in.

What Is CMMC Level 3?

CMMC Level 3 represents the most advanced tier of the program, designed specifically for organizations that must defend against advanced persistent threats (APTs) like nation-state adversaries with significant resources, time, and sophisticated attack capabilities.

Level 3 includes approximately 134-136 total practices: all 110 Level 2 requirements from NIST SP 800-171 R2, plus 24-26 additional enhanced security requirements from NIST SP 800-172.

These additional Level 3 requirements focus on five key themes:

1. Advanced Threat Detection & Response

Going beyond basic monitoring to implement behavioral analytics, anomaly detection, insider threat detection programs, advanced threat hunting, and enhanced incident correlation.

2. Layered Defense (Defense-in-Depth)

Building multiple security layers specifically designed to slow down sophisticated adversaries, including deception technologies like honeypots and decoys, obfuscation techniques, and redundant security mechanisms.

3. Protecting Against APTs (Advanced Persistent Threats)

Implementing controls specifically designed for nation-state level threats, including long-term threat monitoring, advanced malware protection, and adversarial simulation and red teaming.

4. Enhanced Visibility & Monitoring

Deploying continuous monitoring and diagnostics, advanced audit capabilities, system and user behavior analytics (UEBA), and threat intelligence integration.

5. Supply Chain & Insider Risk

Strengthening supply chain risk management, enhanced personnel security, trusted software/hardware verification, and contractor and vendor security programs.

The Level 3 Prerequisite: Level 2 Certification

You cannot pursue Level 3 without first achieving Level 2 (C3PAO) certification for the same CMMC assessment scope.

Level 3 builds on top of Level 2; it doesn't replace it. Organizations must:

• Achieve and maintain Level 2 certification
• Continue annual Level 2 affirmations even while holding Level 3 status
• Demonstrate full compliance with all 110 Level 2 practices before DIBCAC will assess the additional Level 3 requirements

This means Level 2 controls, including data protection, remain foundational even as you implement advanced capabilities.

Recommended Reading: Supporting CMMC Level 2 Certifications with Data-Centric Security

Virtru as Part of Your Security Stack

Level 3 compliance requires a comprehensive security program with multiple technology layers working together, and no single vendor addresses all 134-136 practices. Virtru specifically focuses on data protection controls and integrates with your broader security architecture complying with level 2, including your threat detection platforms, SIEM, endpoint protection, and network security tools.

We're designed to be one strong layer in your defense-in-depth strategy, not a standalone solution.

Recommended Reading: Virtru Shared Responsibility Matrix for CMMC

1. Meeting the Level 2 Data Protection Prerequisite

Virtru helps organizations address 27 of the 110 Level 2 control areas—specifically those related to protecting CUI as it's shared via email and file transfer:

FedRAMP Authorized & FIPS 140-2 Validated Platform

• Virtru is FedRAMP Authorized at the Moderate level (not just "FedRAMP Equivalent")
• FIPS 140-2 Validated encryption provides trusted, vetted data security
• Meets DFARS 252.204-7012 requirements for cloud services storing or transmitting CUI

Data-Centric Encryption & Access Control

• End-to-end encryption for CUI in email and file sharing
• Split-knowledge architecture providing logical separation of keys and content
• Granular, attribute-based access controls (ABAC) for every file and email
• Works seamlessly with Gmail, Outlook, Google Workspace (all SKUs), Microsoft Commercial Cloud, Microsoft Government Cloud, and GCC High

The Trusted Data Format (TDF)

Virtru's encryption is powered by TDF, which creates a secure container around CUI that enables:

• Immediate access revocation, even after sharing
• Expiration dates and forward disable
• Document watermarking
• Detailed audit logs showing who accessed CUI, when, where, and for how long

Without solid Level 2 data protection controls, you can't move forward to Level 3. Virtru addresses that specific foundational piece.

2. How Virtru Products Support Your CMMC Journey

Virtru for Email

Client-side email encryption plugins for Gmail and Outlook protect CUI in transit and at rest. No new usernames, passwords, or software required for recipients—and no complicated mail routing or gateways to configure. Deploy in minutes, not months.

Virtru Secure Share

Secure file exchange for files up to 15 GB. Share CUI with primes, subcontractors, agencies, and mission partners across Microsoft and Google environments. Recipients access files through a secure viewer or controlled download, keeping CUI in a FedRAMP Authorized environment at all times.

Virtru Private Keystore

For organizations requiring heightened key control, host your private encryption keys separately in the location of your choice: on-premises, HSM, or public/private cloud. This ensures any request to access data (including government subpoenas) comes to your organization, not your cloud provider.

3. Supporting Level 3's Defense-in-Depth Philosophy

Level 3's second theme, layered defense, assumes that adversaries may breach perimeter controls. Data-centric encryption provides an additional layer of protection:

Enhanced Visibility & Monitoring: Virtru generates detailed audit logs showing exactly who accessed which CUI, when, and how. Export event logs for analysis or integrate with your SIEM and security analytics platforms, feeding the enhanced monitoring capabilities Level 3 requires.

Layered Defense: Even if an adversary compromises email systems, endpoints, or networks, CUI encrypted with Virtru remains protected. The encryption follows the data, and keys remain under your control—with the option to revoke access instantly.

Supply Chain & Insider Risk: Virtru enables granular control over which contractors, subcontractors, and partners can access specific CUI. Change permissions or revoke access organization-wide if a supply chain risk emerges or an insider threat is detected.

Protecting Against APTs: Persistent adversaries often maintain long-term access to compromised environments. Data-centric encryption limits what attackers can exfiltrate, even if they've achieved persistence in your network.

Recommended Reading: There's No Silver Bullet for CMMC: How to Spot Empty Promises by Software Vendors

The Bottom Line

If you're pursuing CMMC Level 3, you need a comprehensive security architecture with multiple specialized solutions working together. Virtru is one component of that architecture, specifically addressing:

1. The Level 2 prerequisite: Data protection controls for CUI in email and file sharing
2. Defense-in-depth: An additional encryption layer that protects CUI even when other controls fail
3. Enhanced visibility: Detailed audit data that feeds your monitoring and analytics platforms

We work alongside your other security technologies to help build the layered defense that Level 3 demands.

Evaluating solutions for your Level 3 journey? Let's discuss whether Virtru's data protection capabilities fit your security architecture. Book a demo today.

Note: CMMC Level 3 certification requires approximately 134-136 practices spanning multiple security domains. Virtru addresses specific data protection controls within the Level 2 prerequisite and contributes to Level 3's defense-in-depth approach. Work with qualified CMMC consultants, C3PAOs, and DIBCAC assessors to develop a comprehensive Level 3 compliance strategy.