The Pentagon suspended CMMC Phase 2 requirements on July 13, pausing the mandatory third-party assessment requirement that had been set to take effect Nov. 10. For some defense contractors, the announcement was a reason to wait. For Gemini Industries, a technology solutions provider specializing in mission-critical support for U.S. government agencies and national security customers, it reaffirmed a decision the company had already made: invest in cybersecurity and use independent certification to validate that investment.

Gemini Industries strengthened its cybersecurity program and achieved CMMC Level 2 certification with a perfect score of 110 with the support of CyberSheath. While the Phase 2 pause delays the implementation of mandatory third-party assessments, it does not change the underlying cybersecurity obligations established under DFARS and NIST SP 800-171. Defense contractors remain responsible for protecting Controlled Unclassified Information (CUI), maintaining accurate Supplier Performance Risk System (SPRS) scores, and substantiating their cybersecurity posture. Contractors that have represented a perfect SPRS score without the ability to support those representations continue to face potential liability under the False Claims Act.

“Compliance deadlines will continue to shift, but the underlying requirement to protect CUI has been in place for nearly a decade,” said Emil Sayegh, CEO of CyberSheath. “Gemini’s leadership understood that cybersecurity should never be driven by regulatory calendars. Certification simply validates the investments the company has already made to protect its customers’ information and strengthen its security posture. That decision has positioned Gemini well regardless of how the Department’s review ultimately concludes.”

Gemini Industries handles CUI across a complex operating environment that includes three corporate offices and additional sites nationwide, ITAR-controlled programs, and ISO compliance requirements. Since 2022, CyberSheath has served as Gemini’s managed cybersecurity partner. Rather than preparing for a single assessment event, the two organizations focused on building a mature cybersecurity program that protects sensitive information every day. The third-party assessment by ControlCase validated that ongoing investment without disrupting Gemini’s day-to-day operations.

“In our next 40 years, Gemini teams will face challenges that we have not seen before. As threats change, we may have to change. But who we are and No-Fail, No-Excuses Execution will not change,” said Victoria R. Bondoc, Board Chair of Gemini Industries. “The mission does not pause when regulations do, and organizations must focus on what matters most…contributing to the Mission Success of our American Warfighters and getting them home safely.”

Gemini’s decision also demonstrates that small and medium-sized businesses can successfully implement robust cybersecurity programs when they have the right strategy and the right partner. Rather than delaying progress because of regulatory uncertainty, the company chose to strengthen its cyber resilience and independently validate its security posture.

Learn more about how CyberSheath helps defense contractors build, operate, and continuously improve secure environments.

About CyberSheath

Established in 2012, CyberSheath is one of the most experienced and trusted IT security services partners for the U.S. defense industrial base. The company helps defense contractors assess, implement, operate, and continuously improve secure environments that meet DOD cybersecurity requirements, including NIST SP 800-171, DFARS, and CMMC. Learn more at www.cybersheath.com.

About Gemini Industries

Gemini Industries Inc. specializes in innovative solutions to complex National Security challenges. Headquartered in Burlington, MA with operations across the United States, for over 40 years, Gemini has committed its resources to support National Security projects, U.S. Conventional and Special Forces, Improvised Threat Defeat, Counter Terrorism Initiatives and International Programs. Gemini’s project teams have provided advisory and assistance, intelligence analysis and fusion, advanced technology integration and traditional and rapid acquisition services to complex high-priority national security challenges by deploying the mission focused features of military leadership thereby enabling our customers to achieve their goals.

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