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
Earlier this year, the FAR Council issued a proposed rule to implement the Controlled Unclassified Information (CUI) Program as it relates to federal contracts. The proposed rule is "just one element of a larger strategy to...more
On January 15, 2025, the Federal Acquisition Regulatory Council (FAR Council) proposed two significant rule changes that could reshape compliance obligations for government contractors: one establishing standardized...more
The wait is finally over! After more than 14 years of anticipation, the Federal Acquisition Regulation (“FAR”) Proposed Rule on Controlled Unclassified Information (“CUI”) was released on January 15, 2025 and comes as part 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 (DHS) recently released a final rule (Final Rule), effective July 21, 2023, updating the Homeland Security Acquisition Regulation (HSAR) to include cybersecurity provisions aimed at...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
The National Institute of Standards and Technology (NIST) has released an initial public draft of NIST SP 800-171, Revision 3, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations. Compliance...more
In 2019, cybersecurity has become top-of-mind for most federal government contractors and agencies that share sensitive information. In addition to updated Department of Defense guidance and procedures for evaluating...more
On May 16, 2016, the Federal Acquisition Regulations (“FAR”) Council published the final FAR rule on Basic Safeguarding of Contractor Information Systems. The rule is intended to prescribe “the most basic level” of...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
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 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
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