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U.S. Department of Commerce Implements New Export Controls to Combat Malicious Cyber Activities

Key Points - On March 7, 2022, new U.S. export controls applicable to “cybersecurity items” took effect based on an interim final rule published by BIS on October 21, 2021 (the “Cyber Rule”). The controls under the Cyber...more

Changes Coming to DOD’s Cybersecurity Maturity Model Certification under CMMC 2.0

On November 17, 2021, the U.S. Department of Defense (DOD) published an Advanced Notice of Proposed Rulemaking (ANPRM) previewing significant changes to its Cybersecurity Maturity Model Certification (CMMC) program.1 The...more

Twin DOJ Initiatives Tackle Cybersecurity Fraud and Cryptocurrency Enforcement

Key Points - On October 6, 2021, the DOJ announced two new initiatives: the Civil Cyber-Fraud Initiative and the National Cryptocurrency Enforcement Team. The Civil Cyber-Fraud Initiative will fight rising cyber threats...more

President Biden Issues Executive Order to Overhaul Cyber and Software Supply Chain Security and Expand Incident Reporting for...

Key Points - On Wednesday, May 12, 2021, President Biden issued EO 14,028, “Improving the Nation’s Cybersecurity.” The EO sets out an ambitious schedule of reviews and rulemakings that portend significant changes in the...more

CMMC and the Three “Cs”: Cost, Conflicts and Competition

A. Introduction and Key Take-Aways - The Department of Defense’s (DOD) Cybersecurity Maturity Model Certification (CMMC) program provides a metric for independent third parties to use in assessing and certifying the...more

OFAC Adds Iranian Bitcoin Exchangers’ Names and Wallet Addresses to SDN List, Ushers in “New Approach” to Sanctions Enforcement

• On November 28, 2018, OFAC designated two Iran-based individuals who helped exchange cryptocurrency (bitcoin) into fiat currency on behalf of alleged ransomware perpetrators who targeted U.S. businesses and municipal...more

Six Recent Government Supply Chain Risk and Cybersecurity Initiatives

• DoD and other government agencies will scrutinize contractors’ supply chain security plans and programs from proposal submission to contract closeout. • The 2019 NDAA as approved by Congress and DHS initiatives highlight...more

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