Episode 0: Ooey Cooey Is Back

Are you a defense contractor being told that everything is CUI—or that your contract contains CUI—without anything actually being marked? Or unsure whether you handle CUI at all, and therefore whether CMMC Level 1 or Level 2 applies to you?

That confusion is exactly why Ooey Cooey exists.

This re-introduction episode explains what this podcast is about, why it’s coming back now, and who it’s for. Ooey Cooey focuses on the full lifecycle of Controlled Unclassified Information (CUI)—from identification and designation to marking, safeguarding, sharing, retention, and destruction—and how those requirements actually show up in contracts and operations.

Since the last episode aired in 2021, a lot has changed: CMMC 2.0, new DFARS clauses, recurring cybersecurity attestations, compliance scoring, and third-party assessments have created a more complex and higher-risk environment for contractors. This episode explains what’s changed, why enforcement looks different today, and why clarity matters more than ever.

You’ll also hear how the podcast has evolved. Episodes will be short (15–20 minutes), focused on one concept at a time, and designed to answer four core questions:
 • What is the rule?
 • Who is responsible?
 • Where do contractors get it wrong?
 • What should you do instead?

This is not a technical podcast, not vendor-driven, not fear-based compliance—and not legal advice. It’s about clarity, context, and making informed, defensible decisions.

Earlier episodes from 2021 are still available and remain relevant for foundational CUI concepts based on the NARA CUI regulations. New episodes will build on that foundation and focus on how CUI requirements are being operationalized today.

If you’re confused about how, when, and where CUI safeguarding requirements impact your company, this show is for you. If you’re looking for a checklist without context, it probably isn’t.

Connect on LinkedIn: leslieweinsteinmba
Resources for government contractors: www.the-cyberadvisor.com

Until next time—and remember: don’t call it Cooey. That would be Ooey.

Transcript

Speaker 0:00

Are you a defense contractor trying to understand CMMC requirements? Being told that everything is CUI or that your contract will contain CUI but nothing is actually marked as CUI? Or maybe you don't even know if you handle CUI at all. So you don't know if you should be preparing for a CMMC level one or a level two. That confusion is exactly why CUI exists. Ooey Cooey is about the full life cycle of controlled unclassified information or CUI, not just one control, one framework, or one assessment. It's about how information is identified as CUI in the first place. Who is allowed to designate it? Do I generate CUI? And if I do, what does it look like for my company specifically? This isn't a technical podcast. I'm not walking through encryption settings or tool configurations. And it's not about policy theory. This is not an academic exercise. It is also not legal advice. This is about how CUI actually shows up in contracts and in solicitations, in flowdown clauses, and in day-to-day operations, especially when the guidance is incomplete or inconsistent. Because CUI is not just a cybersecurity issue. It's a legal issue, a contractual issue, and an operational one. The last time I recorded an episode of this podcast was June 2021, right around the time I graduated from Cornell with my MBA. Not long after that, the podcast went quiet, not because I lost interest in CUI, but because I ran out of bandwidth. I was working full-time consulting in the CMMC space, and then in August 2022, I started law school. While this podcast went dormant and my activity on LinkedIn slowed, I never stepped away from the substance. I continued to follow the regulatory changes, the contract language, the policy shifts, and the way that CUI obligations were evolving in practice. I'm picking this podcast back up now because I graduated from law school and finally have bandwidth to do more on the weekends than just brief cases and outline for law school. I am also picking up this podcast right now because I intend to remain practicing in this space this time as an attorney once I pass the bar exam. The substance of this podcast, cybersecurity compliance and CUI handling, remains the same, but my perspective is different. However, this podcast is not now and will never be legal advice. As a consultant, my role was focused on advising organizations on CUI workflows and the practical application of security controls, often working under attorney client privilege with third-party law firms so that I could have candid discussions with clients without creating additional legal exposure in the process. Soon, I'll be able to provide that additional layer of protection myself. Alongside recommendations for operational workflows and control implementations, I will also be able to explain the legal implications of different business choices, helping organizations weigh risk, understand trade-offs, and ultimately selecting the approach that best fits the company's operations and risk tolerance. Hiring an attorney who understands both the operational and legal impacts of cybersecurity compliance can mean the difference between making a smart business decision and walking into unintentional and unnecessary risk. Attorneys are bound by rules of professional conduct, subject to discipline, and they're held accountable to the courts and the bar. Providing inaccurate or careless advice carries real consequences for attorneys, up to and including the potential loss of a law license. This framework creates a level of rigor, independence, and assurance that you simply do not get from a random consultant pulled from an online marketplace. That obligation to be informed, precise, and careful is ultimately about protecting clients. And it also means that I will be able to bring new insights into helping companies understand and protect CUI. A lot has changed since 2021, and not just in name or in acronyms. Back then, most contractors were still trying to understand what CUI even meant in practice. Today, CUI has become the foundation for broader compliance regimes, especially with the rollout of the DOD's CMMC 2.0. We've seen the introduction and evolution of new DFARS clauses, increased reliance on certifications and representations, and a growing expectation that contractors understand their obligations before a contract is awarded, and not after performance begins. At the same time, guidance has not always kept pace. Class deviations and policy memos have created a patchwork of requirements that contractors are expected to navigate in real time. The result of all of this is a lot of uncertainty, especially for small and mid-sized businesses that don't have in-house legal or compliance teams. What's also changed is the enforcement posture. Cybersecurity representations are no longer abstract or aspirational. They're now directly tied to contract eligibility, payment, and legal risk. Contractors are being asked to make recurring affirmative attestations about their cybersecurity posture. Compliance is quantified through scoring tied to specific control implementation, all of which are being submitted to the government. At the same time, the Department of Defense has finalized the two necessary CMMC regulations, and CMMC clauses are now appearing in solicitations. In some cases, NIST 800-171 compliance is no longer self-asserted, and it must be validated through third-party assessments conducted by C3 PAOs as a condition of contract award. This combination of recurring formal attestations, generating compliance scores based on specific control implementation, and third-party verification creates an entirely new risk landscape that did not exist in 2021. Statements and representations of cybersecurity compliance carries real risk, with very little room for claiming ignorance. As compliance has become more complex and attestations more precise, the timing finally aligned to bring this podcast back to life. But let me be clear about what this podcast is and what it is not. Episodes will be shorter, I'm aiming for 15 to 20 minutes. Each episode will focus on a single concept. The goal is that you can listen to an episode, understand the issue, and walk away knowing how it applies to you. Every episode will be designed to answer the same core questions. What is the rule? Who is actually responsible? Where do contractors commonly get it wrong? And what should you be doing instead? This is not a podcast of four-hour deep dives or theoretical lectures. It is also not vendor-driven. There's no tool hype, no sales pitch, and no incentive to exaggerate risk for clients. And it's not fear-based compliance. This is not about telling you that you're already out of compliance and that everything is a crisis. This podcast is about clarity, how the rules actually work, how they show up in contracts and operations, and how to make informed, defensible decisions. This is not compliance theater. One other thing worth mentioning before I wrap it up here is that there are already episodes on my podcast channel that you can listen to today. Back in 2021, I recorded episodes on what CUI is, creating and designating CUI, marking and labeling and storing CUI, and even an interview with the ISOO. Those episodes are still available, and I have not gone back to update them. The core CUI framework is grounded in the NARA CUI regulations, and those foundational rules have not changed. So if you're looking for baseline concepts, what CUI is, how designation works, what marking requires, that material is still relevant and still available. I should also mention that I no longer own DODCUI.com, which is mentioned in those old episodes. What has changed is how those rules are being operationalized through contracts, attestations, and enforcement. That's where these new episodes come in. The goal now is to build on that foundation, add context, and focus on how CUI obligations are actually playing out today. You can listen to the older episodes as background or jump straight into the new ones. This podcast is meant to work either way. This podcast is for federal contractors trying to make sense of real cybersecurity and CUI obligations, not in theory, but in practice. It's for compliance and security leaders who are responsible for translating requirements into workable processes. It's also for in-house and outside counsel who need to understand how cybersecurity intersects with contracts, representations, and risk. It's also for program managers who inherit cyber obligations through a contract and are expected to execute without ever being given the full picture. If you've ever been confused about how, when, and where CUI safeguarding requirements impact your company, this show is for you. If you're looking for a checklist without context, this show probably is not for you. And finally, this podcast is not meant to be one way. I'm open to topic ideas, questions, and edge cases that you're seeing in practice. If there's something you want broken down clearly and practically, chances are you're not the only one asking. And that's exactly what this podcast is for. You can connect with me on LinkedIn at Leslie Weinstein MBA, and you can find additional resources for government contractors and book time with me on my consulting website www.the-cyberadvisor.com. Again, that's www.the-cyberadvisor.com. Thank you for listening to this reintroduction episode. If you think this podcast might be helpful, please feel free to share it with someone who's navigating these same questions. Until next time, and remember, don't call it cooey. That would be ooey.