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In his final days in office, President Biden signed an ambitious executive order to improve the federal government's approach to cybersecurity. Executive Order 14114 ("Executive Order"), issued January 16, 2025, titled...more
Over the last few years, the Federal Risk and Authorization Management Program (“FedRAMP”) Program Management Office (“PMO”) has released two draft guidance documents related to defining the applicable boundary for security...more
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
The Federal Acquisition Regulatory (FAR) Council on Oct. 3, 2023, issued two proposed rules to partially implement President Biden's Executive Order on Improving the Nation's Cybersecurity. The first proposed rule imposes...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
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
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
The U.S. Department of Defense (DoD) released interim rules on Aug. 26, 2015, setting forth (i) information system security requirements; (ii) mandatory cyber breach reporting; and (iii) cloud computing standards and...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
In a move that highlights the changing winds of federal cybersecurity policy, the Department of Defense (“DoD”) has issued an interim Rule (“Rule”) that imposes new security and reporting requirements on federal contractors,...more
The Department of Defense (DoD) released interim rules implementing provisions of the 2013 and 2015 National Defense Authorization Acts. The rules, released on Aug. 26, 2015, are effective immediately and establish the...more
On August 26, 2015, the Department of Defense (DoD) published a long-awaited Interim Rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to require “rapid” reporting of “cyber incidents” that result in...more
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