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It’s Arrived! FAR Final Rule Addressing “Basic Safeguarding of Contractor Information Systems”

After nearly four years of planning and comments, DoD, GSA, and NASA issued a final rule today amending the Federal Acquisition Regulations (“FAR”) with a new Subpart 4-19 and a new contract clause 52.204-21 addressing the...more

DoD Reveals its Cybersecurity Discipline Implementation Plan (or How 1940s War Department VD Training Can Help Your 21st Century...

“If our country is to successfully defend our right to live the American way, it needs every one of you, and requires you in the best possible condition. Any [company] who willfully, or through neglect fails to maintain...more

Be Alert: Ransomware Attacks on the Rise

Big name companies, government agencies and individuals are all falling victim to “ransomware” attacks in record and still-rising numbers. Recently, Hollywood Presbyterian Hospital’s communications capabilities were disabled...more

Perspective: What Will Be the Defining Cybersecurity Issues In 2016?

As data breaches and their related obligations and liability risks continue to pile up with every passing year, we asked attorneys writing on JD Supra to answer the question: What will be among the defining issues for...more

Department of Defense Provides Government Contractors a Grace Period for Compliance with Key Cybersecurity Requirements

In response to industry concerns and comments, on December 30, 2015, the Department of Defense issued a new interim rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) cybersecurity rules promulgated...more

Government Forces Awaken: The Rise of Cyber Regulators in 2016

As the sun sets on 2015, but before it rises again in the New Year, we predict that, in the realm of cyber and data security, 2016 will become known as the “Rise of the Regulators.” Regulators across numerous industries and...more

Are You Overcomplicating Your Cybersecurity Processes?

Yes. I just asked that. For many, the response is likely “Yes! Of course we are! It’s *&^%$% cybersecurity – it’s complicated!” To which I would respond “Touché. It is…but it needn’t be overly complicated.” So, of...more

Have DoD Contractors and Subcontractors Been Drafted? Once Voluntary Defense Industrial Base CS/IA Regulations Now Mandatory and...

When last we left the Department of Defense, they had issued a rather wide-reaching interim DFARS rule addressing cybersecurity practices, data retention, and cloud services purchasing guidance. Now, effective October 2,...more

FTC v. Wyndham: The Third Circuit Recognizes FTC Authority to Regulate Commercial Cyber Security Practices

In 2014, the United States Court of Appeals for the Third Circuit ruling in FTC v. Wyndham Worldwide Corporation agreed to hear an immediate appeal on two issues: “whether the FTC has authority to regulate cybersecurity under...more

DoD Addresses Cybersecurity Preparedness, Incident Reporting, and Cloud Computing Acquisitions with new DFARS interim rule

Announced and effective today, August 26, 2015, DoD has issued an interim rule that significantly expands existing DFARS provisions and clauses requiring contractors and subcontractors to report cyber incidents. The interim...more

The Baby and the Bathwater: The Department of Commerce’s Bureau of Industry and Security (BIS) Intrusion and Surveillance Software...

If you are not aware, please take note that the July 20, 2015 deadline is fast approaching for comments to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) proposed rule on the export control of certain...more

Ransoming Sensitive Personal Information: Will OPM’s Data Breach Trigger Your Insider Threats?

Perhaps it’s the books I’ve been reading or the television shows I’ve been watching, but my mind can’t seem to stop linking the recent barrage of cybersecurity attacks with those ne’er-do-wells that plagued the Caribbean from...more

ALERT: NIST Issues Final Guidance on Federal Contractor Cybersecurity Standards for Controlled Unclassified Information

On June 19, 2015, the National Institute of Standards and Technology (NIST) published the final version of guidance for federal agencies to ensure sensitive information remains confidential when stored outside of federal...more

Another Prologue to Cybersecurity Regulations: Controlled Unclassified Information (“CUI”) – What Contractors Need to Know and Why...

Government contractors should take note of a proposed new rule that could impose significant new data storage obligations when finalized. The Federal Government is taking another baby-step towards cybersecurity regulation...more

The FCC Takes a Seat at the Cyber-Regulation Table

The FCC recently slid up its chair to the fiscal feast that is cyber security and data breach regulation and took a hefty piece of the pie. In late October the FCC announced that it charged a record $10 million fine against...more

12/4/2014

Cyber-Breach & NISPOM Conforming Change 2 – It’s What’s on the Inside That Counts

Most companies are worried about external threats – things that are coming at their people, their group, their company, their government, all from an outside actor. Like government’s with an eye on counter-intelligence,...more

Shopping for the Cloud Made Easy – GSA’s Special Item Number Project for Cloud Computing and Request for Comments

On November 18, 2014, the General Services Administration (“GSA”) hosted an Industry Day seeking feedback on its proposal to add a Cloud Computing Special Item Number (“SIN”) on its IT Multiple Award Schedule 70 (“MAS...more

Federal Register Round Up – June/July 2014

DOD Proposed Rules Seeking Contractor Business System Rule Self Assessments - The Department of Defense issued a proposed rule on July 15th that would revise the DFARS Business Systems Rule by requiring contractors...more

“They’re Here” – What You Need to Know Now About the Chilling New DoD Counterfeit Parts Rule … and its NASA “Spinoff”

If you are a contractor that interacts with both the Department of Defense and “electronic parts,” it is time to grab the caffeinated beverage of your choice, crack open 79 FR 26,092, and begin the bone-tingling read that is...more

The Cybersecurity Race: Executive Branch Takes The Lead While Congress Watches From The Bleachers

The federal government sector has been abuzz lately with whispers and shouts about pending cybersecurity regulations, frameworks, and requirements. This attention is not particularly surprising, especially given the recent...more

Robert Frost and Cybersecurity - Two Roads Diverging

Like Frost’s nameless traveler in “The Road Not Taken,” our Government finds itself confronted with two diverging roads in the cybersecurity realm. The first offers moderation, deliberation, and evolution. The second, speed....more

10/1/2013

Details: Highlights from the August & September 2013 Federal Register

1. Repeal of Sunset Dates for Protest Authority Over Certain Task Orders - Effective September 3, 2013, FAR 16.505 was amended to eliminate the sunset dates for protests against the issuance of an order under a...more

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