Cybersecurity Insights: Updates on CMMC Implementation and CUI Identification
Marti Arvin and Anthony Buenger on the CMMC Framework
On January 15, 2025, the FAR Council finally released a proposed rule (the Rule)1 regulating the use and handling of controlled unclassified information (CUI) as a part of the general strategy to reduce threats of...more
WHAT: The FAR Council published a proposed rule to incorporate the Controlled Unclassified Information (CUI) Program into the acquisition process and, in doing so, seeks to more clearly define government and contractor roles...more
On January 15, 2025, the Federal Acquisition Regulation (“FAR”) Council issued its long-awaited “CUI Rule.” CUI, or Controlled Unclassified Information, is information that the government creates or possesses, or that an...more
The Department of Homeland Security amended its regulations due to the urgent need to protect Controlled Unclassified Information. On June 21, 2023, the Department of Homeland Security (DHS or Department) issued a final...more
On June 21, the Department of Homeland Security (DHS) published a final rule to implement security measures that safeguard controlled unclassified information (CUI) from unauthorized access and disclosure and improve incident...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
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
While all companies should be concerned with their cybersecurity posture, companies in the aerospace, defense, and government services (ADG) industry are potentially subject to greater risks due to the industry's highly...more
The Department of Homeland Security (DHS) has now officially entered the government data security fray with its own proposed rule (HSAR Case 2015-001; 82 FR 6429; Jan. 19, 2017) for safeguarding Controlled Unclassified...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
Is Controlled Unclassified Information Out of Control? The OMB apparently thinks so. On August 11, 2015, the Obama administration, through the Office of Management and Budget (OMB), which is the largest office within the...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 August 11, 2015, the Office of Management and Budget (“OMB”) released a draft policy memo entitled “Improving Cybersecurity Protections in Federal Acquisitions.” The purpose of the memo is to provide federal agencies with...more