Cybersecurity Insights: Updates on CMMC Implementation and CUI Identification
Marti Arvin and Anthony Buenger on the CMMC Framework
On January 15, 2025, the Department of Defense (DOD), General Services Administration (GSA), and the National Aeronautics and Space Administration (NASA) (collectively, “the FAR Council”) issued a long-anticipated proposed...more
After years of anticipation, the Federal Acquisition Regulation (FAR) Council has announced the arrival of its proposed rule to enhance the safeguarding of Controlled Unclassified Information (CUI) in federal contracts (the...more
Pursuant to DFARS 252.204-7012, DoD contractors are to implement the security requirements in NIST Special Publication (SP) 800-171 by December 31, 2017. NIST SP 800-171 includes security requirements for protecting...more
First and foremost, the proposed Department of Homeland Security (DHS) regulation to safeguard CUI is internally inconsistent or at the very least ambiguous. It appears to conflate the protection of CUI on a federal...more
This week, the Department of Homeland Security (“DHS”) issued three proposed rules expanding data security and privacy requirements for contractors and subcontractors. The proposed rules build upon other recent efforts by...more
The U.S. federal government announced on May 16, 2016, new Federal Acquisition Regulation (FAR) rules that set high-level standards for the basic safeguarding of contractor information systems that process, store or transmit...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
The Office of Management and Budget (OMB) released a draft guidance document on Aug. 11, 2015, titled “Improving Cybersecurity Protection in Federal Acquisitions” (the “OMB Guidance”). The OMB Guidance instructs agencies on...more
Federal government contractors handling Controlled Unclassified Information (CUI) should take notice of two recent executive agency actions. Combined, they lay the groundwork for a new cybersecurity clause to be added to the...more