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Citing the threats posed by foreign adversaries and criminal organizations, and seeking enhanced accountability for companies that provide software and cloud services to the federal government, the Biden administration has...more
To dramatically scale up the Modernizing the Federal Risk and Authorization Management Program (FedRAMP) marketplace, the Office of Management and Budget (OMB) has completely rewritten FedRAMP’s vision, scope and governance...more
To kick off the New Year, Sheppard Mullin’s Governmental Practice Cybersecurity & Data Protection Team has prepared a cybersecurity-focused 2023 Recap (including links to all of the resources the team has put out over the...more
Inflation relief for defense contractors, a ban on procurement of products and services containing certain Chinese semiconductors, and codification of the Federal Risk and Authorization Management Program (FedRAMP) governing...more
For a whole decade, ACI’s U.S. Export & Reexport Compliance for Canadian Operations conference continues to stand apart as the only practical, comprehensive event of its kind for the export compliance community in Canada. ...more
The Situation: The United States government has been ramping up its efforts to protect sensitive data and is making clear it expects its contractors to protect data they receive and create. According to a recent Inspector...more
The Department of Defense (“DoD”) is seeking information related to potential sources for the implementation of Cloud Infrastructure for its “Acropolis” cyber defense program. The Acropolis is a secure and consolidated...more
Is this a Start of Something New for Third-Party Management? The demand for responsible cybersecurity in business is ubiquitous. The need to protect information is not limited to the financial services, insurance and...more
The DoD clarifies its expectation for full compliance to protect Controlled Unclassified Information (CUI) residing on Contractor Systems from cyber incidents. A defense contractor’s updated and current System Security...more
It’s almost here. After years of rulemaking, covered defense contractors will soon be fully subject to heightened cybersecurity standards for covered defense information (“CDI”) on IT systems under DFARS 252.204-7012, and...more
U.S. Department of Defense (DoD) contractors face new cybersecurity compliance requirements, including a significant deadline set for December 31, 2017. Most DoD contracts now include clauses imposing obligations on...more
This month marks an important waypoint for defense contractors subject to the new cybersecurity requirements imposed by the Department of Defense. For contractors subject to the requirements of Defense Federal Acquisition...more
For businesses that work with the U.S. Department of Defense (“DoD”), two important rules for safeguarding certain categories of sensitive information and reporting cyber incidents were recently finalized, updating the...more
On October 21, 2016, the Department of Defense (DoD) issued its final rule on Network Penetration Reporting and Contracting for Cloud Services, amending an interim version issued on August 26, 2015, and revised on December...more
Last week, the Department of Defense adopted as final, with several changes, its interim rule amending the DFARS on “Network Penetration Reporting and Contracting for Cloud Services.” The changes went into effect...more
On October 21, 2016, the Department of Defense (“DoD”) issued a final rule (the “final rule”) codifying the specific actions DoD contractors and subcontractors must take to adequately safeguard “covered defense information”...more
On October 21, 2016, the Department of Defense (DoD) issued a final rule following-up on the interim rules it had issued on August 26 and December 30, 2015, regarding safeguarding contractor networks and purchasing cloud...more
Cloud computing is ubiquitous in the federal market place. Many federal contractors either provide cloud computing services to the government or use cloud computing services when performing a federal contract. For cloud...more
On December 30, 2015, the Department of Defense (DoD) issued a second interim rule on Network Penetration Reporting and Contracting for Cloud Services, amending an earlier version issued on August 26, 2015. The new, amended...more
The United States Department of Defense (“DoD”) recently published two new rules that impose broader obligations to safeguard information that falls within specified categories of sensitive data and to report cyber incidents...more
The United States Department of Defense promulgated an “interim” rule, effective August 26, 2015, which placed imposing and costly burdens on all DoD contractors and subcontractors (including small businesses and commercial...more
The Department of Defense (DoD) issued an interim cybersecurity rule in August 2015 that, among other things, revises the existing Defense Federal Acquisition Regulation Supplement (DFARS) cybersecurity clause and increases...more
The U.S. Department of Defense (DOD) recently published an interim rule amending the Defense Federal Acquisition Regulation Supplement (DFARS).1 The interim rule, effective August 26, 2015, focuses on two issues. First, the...more
Companies doing business with the U.S. Department of Defense are facing new requirements for reporting data security breaches and for acquiring cloud computing services. The Interim Rule, effective August 26, 2015, amends the...more