cybersecurity · governance, risk & compliance

Audit evidence that comes out of your systems, not out of screenshots taken the week before fieldwork.

A lot of security audit findings come back to identity. MFA skips the internal apps. Access never got reviewed. Accounts outlived the people who owned them. We map your controls to the rules you answer to and fix the technical gaps, then set things up so your IdP, IGA and SIEM produce the evidence themselves.

platforms
cybersecurity / governance-risk-compliance 5 platforms
01 · CONTROL SOURCES 02 · EVIDENCE 03 · FRAMEWORKS Identity provider: MFA coverage by app Identityprovider MFA coverage byapp IGA platform: access review results IGA platform access reviewresults PAM platform: privileged session logs PAM platform privilegedsession logs SIEM: monitoring and alert history SIEM monitoring andalert history GRC tool: scheduled evidence exports GRC tool scheduled evidenceexports Unified control set: one control · many frameworks Unified control set one control · manyframeworks NYDFS Part 500: 500.12 MFA · 500.13 inventory NYDFS Part 500 500.12 MFA ·500.13inventory PCI DSS 4.0.1: 8.4.2 MFA into the CDE PCI DSS 4.0.1 8.4.2 MFA intothe CDE CMMC and NIST SP 800-171: self-assessment · SPRS CMMC and NISTSP 800-171 self-assessment· SPRS NERC CIP: CIP-004 · CIP-005 · CIP-015 NERC CIP CIP-004 ·CIP-005 ·CIP-015
SailPointOktaMicrosoft Entra IDCyberArk
in short·20-second read

Governance, risk and compliance (GRC) work ties security controls to the rules a business must follow and proves those controls operate.

Cohash maps controls to NYDFS Part 500, PCI DSS 4.0.1, HIPAA, NERC CIP and CMMC, closes technical gaps such as missing MFA or unreviewed access, and automates evidence from identity, PAM and logging systems. We engineer the controls and evidence, while legal interpretation stays with your counsel and assessors.

you probably need this if
  • Audit evidence is screenshots collected the week before fieldwork.
  • NYDFS now requires MFA on every system and your internal apps still skip it.
  • Each framework you answer to has its own spreadsheet and its own MFA project.
Ask an engineer facts checked 2026-10-20 · 9 sources
how it runs
  1. 01Scope
  2. 02Gap assessment
  3. 03Remediate
  4. 04Automate evidence
you keep
  • Applicability matrix by regulation and system
  • Unified control map across frameworks
  • Gap register with owners and target dates
+ 3 more documents
who does it
GRC analystIT controls and audit specialist (SOX, HIPAA)Identity governance engineer
platforms
the story · governance, risk & compliance

From the first call to a setup your own team can run.

Here's what usually prompts a call about your Governance, Risk & Compliance, what we do about it and in which order, and where you end up.

  1. chapter 01 · where it hurts

    Why teams reach out

    • Audit evidence is screenshots collected the week before fieldwork.
    • NYDFS now requires MFA on every system and your internal apps still skip it.
    • Each framework you answer to has its own spreadsheet and its own MFA project.
  2. chapter 02 · what we change

    How we solve it

    • NYDFS Part 500
    • PCI DSS 4.0.1
    • HIPAA Security Rule
    • NERC CIP
    • CMMC
    • Unified control mapping
  3. chapter 03 · how it runs

    Our approach

    • Scope
    • Gap assessment
    • Remediate
    • Automate evidence
  4. chapter 04 · where you end up

    What changes

    • The CISO files against a measured list of authentication paths.
    • Every route into the CDE now hits MFA at the boundary, and the DBA shortcut is gone.
    • IdP and SIEM evidence now backs the score.
    • Applicability matrix by regulation and system
what we do

Where we spend the hours

7 areas of work, each one done by an engineer who has run it in production.

  1. Since 1 November 2025, covered entities must use MFA for anyone accessing their information systems unless the CISO approves equivalent controls in writing, and must keep a written asset inventory under section 500.13(a). We close the MFA gaps and build the inventory from systems you already run.

  2. The future-dated requirements became mandatory on 31 March 2025, including requirement 8.4.2, MFA for all access into the cardholder data environment. Version 4.0.1 exempts accounts that use only phishing-resistant authentication. We trace every identity path into the CDE and fix the ones that fall short.

  3. HHS proposed a major Security Rule update in January 2025, including MFA, encryption and a technology asset inventory. As of October 2026 it isn't final and the current rule still applies. We work to the current rule and adopt the proposal's controls where that's cheap now.

  4. FERC approved CIP-015-1 in Order No. 907 on 26 June 2025, requiring internal network security monitoring for high-impact and some medium-impact BES Cyber Systems. We help utilities plan monitoring coverage alongside the access controls in CIP-004 and CIP-005.

  5. The DFARS rule took effect on 10 November 2025 and started Phase 1 self-assessments. On 13 July 2026 the Department of War suspended Phase 2 third-party certification. Self-assessments, SPRS affirmations and NIST SP 800-171 duties under DFARS 252.204-7012 still apply.

  6. One control set mapped across every framework you face, so a single MFA control answers NYDFS, PCI and CMMC wording instead of becoming three projects.

  7. Access review results, MFA coverage, privileged session logs and configuration baselines exported on a schedule to your GRC tool, so evidence stays current all year.

capability 01 / 07in production

NYDFS Part 500

Since 1 November 2025, covered entities must use MFA for anyone accessing their information systems unless the CISO approves equivalent controls in writing, and must keep a written asset inventory under section 500.13(a). We close the MFA gaps and build the inventory from systems you already run.

capability 02 / 07in production

PCI DSS 4.0.1

The future-dated requirements became mandatory on 31 March 2025, including requirement 8.4.2, MFA for all access into the cardholder data environment. Version 4.0.1 exempts accounts that use only phishing-resistant authentication. We trace every identity path into the CDE and fix the ones that fall short.

capability 03 / 07in production

HIPAA Security Rule

HHS proposed a major Security Rule update in January 2025, including MFA, encryption and a technology asset inventory. As of October 2026 it isn't final and the current rule still applies. We work to the current rule and adopt the proposal's controls where that's cheap now.

capability 04 / 07in production

NERC CIP

FERC approved CIP-015-1 in Order No. 907 on 26 June 2025, requiring internal network security monitoring for high-impact and some medium-impact BES Cyber Systems. We help utilities plan monitoring coverage alongside the access controls in CIP-004 and CIP-005.

capability 05 / 07in production

CMMC

The DFARS rule took effect on 10 November 2025 and started Phase 1 self-assessments. On 13 July 2026 the Department of War suspended Phase 2 third-party certification. Self-assessments, SPRS affirmations and NIST SP 800-171 duties under DFARS 252.204-7012 still apply.

capability 06 / 07in production

Unified control mapping

One control set mapped across every framework you face, so a single MFA control answers NYDFS, PCI and CMMC wording instead of becoming three projects.

capability 07 / 07in production

Evidence automation

Access review results, MFA coverage, privileged session logs and configuration baselines exported on a schedule to your GRC tool, so evidence stays current all year.

typical situations

Situations we walk into

We pieced these together from Governance, Risk & Compliance situations that come up a lot. They're patterns. You won't find a specific client in them.

case file 01

April NYDFS certification with internal apps still on passwords

composite · not a client story
  1. Beforethe situation

    Remote access and admin accounts at a covered entity require MFA. Internal web apps don't, and neither do local logins on Linux servers or a third-party claims portal. The CISO has to decide what the 15 April filing can honestly say.

  2. What we dothe work

    We inventory every authentication path from IdP, PAM and server logs and mark which ones meet Part 500's MFA rule. Internal apps get federated to the IdP. Server logins move behind PAM with MFA. Where the CISO approves an equivalent control, it is documented in writing.

  3. Afterwhere you end up

    The CISO files against a measured list of authentication paths. Any gap left has either a written CISO-approved control or a remediation date.

case file 02

PCI DSS 8.4.2 finding on a jump host without MFA

composite · not a client story
  1. Beforethe situation

    Admins get into the cardholder data environment through a Windows jump host. MFA is enforced at the VPN, not at the jump host, and DBAs also connect straight in from a management subnet. The QSA flagged requirement 8.4.2.

  2. What we dothe work

    We trace every identity path into the CDE from firewall rules and authentication logs. MFA goes at the CDE boundary, on the jump host through PAM or phishing-resistant authentication. The direct database route gets closed. Each path and its control is written down for the QSA.

  3. Afterwhere you end up

    Every route into the CDE now hits MFA at the boundary, and the DBA shortcut is gone. The QSA gets the list of paths with evidence for each one.

case file 03

SPRS score built from a self-assessment spreadsheet

composite · not a client story
  1. Beforethe situation

    A defense subcontractor posted its SPRS score off a self-assessment spreadsheet. Several NIST SP 800-171 controls were marked as met just because a policy existed. Two of them were MFA for network access and audit log review.

  2. What we dothe work

    We re-test the controls the score leans on most against system evidence, MFA and audit logging first. Identity and logging gaps get fixed before anything else. After that the system security plan and POA&M are updated so the affirmation matches what is actually running.

  3. Afterwhere you end up

    IdP and SIEM evidence now backs the score. The POA&M lists real gaps with dates, and the affirmation carries less False Claims Act exposure.

case studies

Governance, Risk & Compliance case studies

All case studies
implementation Security operations

CMMC Level 2 and SOC 2 readiness

Engineering the identity, access, logging and evidence controls behind CMMC Level 2 and SOC 2, so assessments rest on system evidence rather than narrative.

read the case study
AI rollout AI and agents

Microsoft 365 Copilot or Gemini Enterprise rollout with real adoption

Rolling out Microsoft 365 Copilot or Gemini Enterprise with oversharing fixed first, use cases tied to real tasks and adoption measured past login counts.

read the case study
migration Identity and access

IBM ISIM, Oracle OIM or homegrown provisioning to SailPoint or Saviynt

Getting off IBM ISIM, Oracle OIM or homegrown provisioning scripts and onto SailPoint or Saviynt, with provisioning, certifications and audit history intact.

read the case study
migration Identity and access

On-premises Active Directory to cloud-first Microsoft Entra ID

We shrink on-premises Active Directory one application at a time, moving groups, users and app authentication to Microsoft Entra ID as each app is ready.

read the case study
migration Identity and access

AD FS federation to Entra ID authentication

Converting federated domains from AD FS to Entra ID cloud authentication, moving relying parties app by app and retiring the AD FS farm.

read the case study
upgrade Identity and access

Auth0 Rules and Hooks to Actions before end of life

Rewriting Auth0 Rules and Hooks as Actions before their 18 November 2026 end of life, with token claims compared before and after each change.

read the case study
architecture

How audit evidence flows from your systems to each framework

The identity provider, IGA, PAM and SIEM export evidence to the GRC tool on a schedule. One unified control set maps that evidence to every framework you face, which is what your assessor reviews.

How audit evidence flows from your systems to each framework The identity provider, IGA, PAM and SIEM export evidence to the GRC tool on a schedule. One unified control set maps that evidence to every framework you face, which is what your assessor reviews. 01 · CONTROL SOURCES 02 · EVIDENCE 03 · FRAMEWORKS MFA report review results session logs monitoring control mapping evidence evidence evidence evidence Identity provider MFA coverage by app SP IGA platform access review results CA PAM platform privileged sessionlogs SIEM monitoring and alert history GRC tool scheduled evidence exports Unified control set one control · manyframeworks NYDFS Part 500 500.12 MFA · 500.13inventory PCI DSS 4.0.1 8.4.2 MFA into the CDE CMMC and NIST SP 800-171 self-assessment · SPRS NERC CIP CIP-004 · CIP-005 · CIP-015
Read the diagram as text
  1. Identity provider → GRC tool: MFA report
  2. IGA platform → GRC tool: review results
  3. PAM platform → GRC tool: session logs
  4. SIEM → GRC tool: monitoring
  5. Unified control set → GRC tool: control mapping
  6. GRC tool → NYDFS Part 500: evidence
  7. GRC tool → PCI DSS 4.0.1: evidence
  8. GRC tool → CMMC and NIST SP 800-171: evidence
  9. GRC tool → NERC CIP: evidence
how it runs

A typical engagement

We don't start a step until the last one has produced something you can check.

  1. step 01

    Scope

    Which regulations apply to which legal entities, systems and data.

  2. step 02

    Gap assessment

    Technical controls tested against each requirement, with identity and logging examined closely.

  3. step 03

    Remediate

    Gaps closed in priority order, starting with whatever a regulator or assessor tests next.

  4. step 04

    Automate evidence

    Scheduled evidence collection set up and walked through with internal audit.

you keep

What you're left with

We write these for your Governance, Risk & Compliance setup, and they're working documents. Your team should be able to keep things running from them long after we've gone.

  • document01

    Applicability matrix by regulation and system

    yours to keep
  • evidence02

    Unified control map across frameworks

    yours to keep
  • inventory03

    Gap register with owners and target dates

    yours to keep
  • design04

    Remediation designs for identity and logging gaps

    yours to keep
  • evidence05

    Automated evidence collection jobs

    yours to keep
  • evidence06

    Assessor-ready evidence index

    yours to keep
talent and delivery · governance, risk & compliance

Certified engineers, wherever you need them.

Some clients want a project team, some want a couple of engineers on theirs. Either works. Onsite, nearshore or offshore, with handovers across time zones that keep things moving.

Onsite

Engineers at your sites in the US

Nearshore

Overlapping hours with US teams

Offshore

Overnight progress on your backlog

All time zones

Coverage handed over across time zones

24-hour coverage · US Central time
OnsiteUS business hours
Nearshoreoverlapping US hours
Offshoreovernight progress
Combinedhandover, not hand-off
roles we staff
  • GRC analyst
  • IT controls and audit specialist (SOX, HIPAA)
  • Identity governance engineer
  • Security policy writer
  • Security risk analyst
01Can you certify us or sign off on our compliance?

That's your assessor's job, whether a PCI QSA, a CMMC C3PAO or an external auditor, and they need to be independent of whoever built the controls. Our part is the engineering and the evidence. We work alongside the assessor during fieldwork to answer technical questions.

02What does the NYDFS MFA expansion mean in practice?

MFA for every individual accessing any information system, not only remote access and privileged accounts. Internal web apps, local server logins and third-party access are the common gaps. Entities that qualify for the limited exemption in 500.19(a) have a narrower scope. Annual certifications covering these requirements were first due on 15 April 2026.

03Is CMMC still worth preparing for after the Phase 2 suspension?

Yes. Level 1 and Level 2 self-assessments and SPRS reporting remain in force, and NIST SP 800-171 obligations come from DFARS 252.204-7012 whether or not CMMC moves forward. The suspension paused third-party certification, not the security requirements, and inaccurate affirmations still carry False Claims Act exposure.

04Should we wait for the HIPAA Security Rule to be finalized?

No. The current rule already requires risk analysis and access controls, and OCR enforces it today. Controls the proposal stresses, such as MFA and an asset inventory, are sound practice either way. We'd hold off rewriting policies to the draft's exact wording until a final rule is published.

05Do you cover TriZetto Facets access for healthcare payers?

Yes. We connect Facets roles and user provisioning to your IGA platform and include Facets in access reviews, so the evidence for who can see member and claims data comes from the same process as every other system.

related

Often paired with

Projects on Governance, Risk & Compliance usually end up touching one of these, so they're worth a look.

next step

Tell us what you're running. We'll tell you what we'd do first.

A 30-minute working session with a senior engineer. No slides.

useful to bring
  • The platform and the version you're on
  • Where you need to get to, and by when
  • What's custom: rules, plugins, integrations
  • Any audit finding or deadline driving it