The CMMC Accreditation Body has ignored a deadline to simply acknowledge a major complaint filed with it alleging multiple ethics violations by former and current Board members.

The complaint was filed consistent with requirements under ISO 17011, which the CMMC-AB will be forced to comply with at some point in the future, per US Dept. of Defense mandate. The CMMC-AB is not fully accredited to ISO 17011 yet, so officially it is not yet required to respond to formal complaints; but the group’s repeated refusal to even acknowledge such complaints is raising additional questions on whether it can be trusted at all to investigate allegations of self-dealing and corruption.

The filing alleged multiple violations of the CMMC-AB’s published Code of Ethics which prohibit Board members from engaging in activities that could be seen as “self-dealing,” or for the purposes of self-enrichment. Multiple Board members operate companies that directly profit from CMMC consulting, with one Board member actively selling “templates” which can be used by companies to obtain CMMC certification.

The CMMC-AB would later be tasked with performing “witness audits” or adjudicating appeals from the very same companies who purchased the products of its Board members. The activities are explicitly prohibited by the various ISO accreditation rules, but the CMMC-AB seems uninterested in curbing the practices.

The group seems similarly oblivious as to the potential damage caused by the optics of the actions of its Board.  The refusal to simply acknowledge receipt of the complaint, nevermind process it, is troubling as it gives the appearance that the CMMC-AB is attempting to cover up the ethics violations.

Meanwhile, Board members such as Jeff Dalton, Ben Tchoubineh and Regan Edens are seen frequently participating in webinars promoted by companies who have purchased CMMC-AB certifications or “badges,” such as those for Registered Practitioners (RP). The practice of helping such companies, through promotional events, gain market share over those that may not have purchased such badges, is likewise under investigation as a potential conflict of interest.

The CMMC-AB already faces a Dept. of Justice investigation after it similarly refused to process a formal complaint alleging the group is in violation of the Americans with Disabilities (ADA) act, a Federal civil rights law.

Under the prior leadership of Undersecretary of Defense for Acquisition & Sustainment Ellen Lord, the CMMC-AB received considerable protection and promotion, and DoD officials including Kevin Fahey and Katie Arrington refused to take action against the allegations of lawbreaking and corruption. The A&S office is now restaffing under the Biden administration, and insiders say the new leadership is taking a more objective look at the CMMC program in general, and the CMMC-AB in particular.

Oxebridge will now escalate the complaint to the A&S office, but simultaneously file escalations with other agencies. It is still not clear if the A&S office has, itself, procedures on how to process formal complaints against the CMMC-AB.

The CMMC-AB and A&S offices are the subjects of over 15 separate complaints to Federal agencies, Congressional oversight committees, and various Inspectors General, alleging different aspects of fraud, waste, and abuse. A few of the filings allege not only unethical behavior, but illegal actions by the CMMC-AB including felony false claims and tax fraud.

UPDATE 14 March 2021: The CMMC Program Management Office under the OUSD (A&S) has responded by indicting they will be processing the complaints escalated to it. Shortly after, two Board members — Ben Tchoubineh and Nicole Dean — were reported to have resigned from the Board. It is not clear if the resignations are related to the ethics investigations.


ISO 17000 Series Consulting