SUPPLY CHAIN AND M&A
Test CUI representations against the actual environment
Vendor questionnaires, supplier attestations, and diligence checklists rely on what an organization says about its own data. Teramis examines the environment itself so you can test those representations against findings from the systems, repositories, and files that were authorized for review.
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An attestation describes the environment. Discovery examines it.
WHAT YOU INHERIT
CUI Risk Transfers With the Transaction
When you acquire an organization, integrate a supplier, or separate a business unit, the data environment comes with it. So does whatever Controlled Unclassified Information is sitting in that environment.
An inaccurate picture affects valuation, integration planning, separation planning, and CMMC scope:
- You inherit a CUI footprint that was not measured against the actual environment
- Integration plans are built on an inventory that does not reflect what is present
- A supplier attestation about CMMC scope does not match the systems and repositories in use
- Data separation after a divestiture leaves CUI in the wrong entity
- Compliance obligations surface after close instead of before the transition plan is set
These are different versions of the same issue. A representation was accepted before it was tested.
COMMON SCENARIOS
Four situations where CUI representations should be tested
- Acquisition diligence: Examine the target's CUI footprint before valuation and integration planning are finalized.
- Supplier and vendor review: Test whether a supplier's stated CMMC scope and CUI handling match the environment.
- Integration planning: Establish the combined CUI footprint before environments are merged and a shared boundary is defined. Explore Migration Support
- Divestiture and data separation: Confirm which CUI belongs to which entity, and whether separation was completed in the systems that were reviewed.
FROM CLAIM TO FINDING
Questions discovery can answer
- Does CUI exist in the environment, and where is it located?
- Does the footprint match what was represented during diligence or review?
- Is CUI present in systems the representation did not mention?
- How much of the examined environment appears to fall inside CMMC scope?
- What would need to move or change before integration?
- What CUI-related obligations come with this transaction or supplier relationship?
- After separation, is any CUI still present where it should not be?
A PRACTICAL CONSTRAINT WORTH PLANNING FOR
Discovery requires access and permission
Teramis examines only environments and data sources it is expressly authorized to examine. In a transaction or supplier review, that authorization needs to be part of the process from the start.
This work usually happens during diligence when access has been granted under agreement, immediately after close as part of integration, or during a supplier review conducted with the supplier's cooperation. When the access question is planned early, the findings can support the rest of the work.
EVIDENCE FOR THE DEAL FILE
Findings both sides can examine
- CUI inventory information for the examined environment
- File and repository detail
- Findings outside the represented scope
- Validation and sampling output
- A documented baseline for post-close monitoring
- Evidence to support integration and separation planning
What Teramis does not do
- Value a transaction or assess deal terms
- Provide legal opinions on representations, warranties, or indemnities
- Determine whether a party breached an agreement
- Certify a supplier's compliance status
- Replace legal, financial, or technical due diligence
- Access any environment without express authorization
TEST THE REPRESENTATION
Find out what the environment actually contains
Talk with Teramis about the transaction or supplier review, the access available to you, and the timeline you are working within.
Request a Demo | Talk to a CUI Discovery Expert