News & Analysis as of

Controlled Unclassified Information (CUI) False Claims Act (FCA)

Sheppard Mullin Richter & Hampton LLP

What a Year! Cybersecurity Recap and 2026 Forecast for Government Contractors

As we welcome 2026, it is a good time for government contractors to reflect on their cybersecurity posture and the major shifts in federal data protection policy from 2025. Last year was more than just a year of evolution in...more

Holland & Knight LLP

CMMC Affirmation Trap: FCA Exposure for Defense Contractors and Acquirers

Holland & Knight LLP on

Defense contractors subject to Cybersecurity Maturity Model Certification (CMMC) compliance under government contracts will be subject to False Claims Act (FCA) liability risks going forward. The CMMC program went live on...more

Alston & Bird

DOJ Cybersecurity Enforcement Pace Shows No Signs of Slowing Down Going Into 2026

Alston & Bird on

As 2025 drew to a close, the United States Department of Justice (DOJ) announced significant developments in cases relating to the allegedly deficient cybersecurity practices of two Department of Defense (DoD) contractors. ...more

White & Case LLP

From 2025 Upheaval to 2026 Strategy: Key Regulatory Risks and Opportunities for Government Contractors

White & Case LLP on

2025 has been an exceptionally active year for U.S. government contractors and grant recipients. The combination of executive orders, regulatory changes and legislative updates that have reshaped procurement, industrial...more

Akin Gump Strauss Hauer & Feld LLP

DoD Begins Phased Implementation of CMMC Final Rule: Key Actions for Contractors

On November 10, 2025, the Department of Defense (DoD), also referred to as the Department of War (DoW), officially began rolling out its Cybersecurity Maturity Model Certification (CMMC) Final Rule, marking the start of the...more

Alston & Bird

CMMC Brings New Era of Cybersecurity Compliance for Defense Contractors

Alston & Bird on

Our Privacy, Cyber & Data Strategy Team breaks down the Department of Defense’s finalized Cybersecurity Maturity Model Certification (CMMC) rule, which establishes a tiered compliance framework that will soon be mandatory for...more

Bradley Arant Boult Cummings LLP

The Importance of Colleges and Universities Complying with Government Contracting and Grant Rules

Colleges and universities are increasingly engaged in complex relationships with the federal government — through contracts, cooperative agreements, and research grants that fund everything from infrastructure and...more

Hogan Lovells

Recent developments in FCA cybersecurity enforcement for government contractors

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The U.S. Department of Justice (“DOJ”) has kept busy in pursuing cybersecurity-related fraud in government contracts resulting in seven settlements. These settlements illustrate the continuing need for contractors to...more

Guidepost Solutions LLC

November 10th is Coming: Is Your CMMC Clock Ticking?

Guidepost Solutions LLC on

The Department of Defense (DoD) has finalized its game-changing Cybersecurity Maturity Model Certification (CMMC) rules, ushering in a new era of accountability for the Defense Industrial Base. The timeline is now very short:...more

Troutman Pepper Locke

Preparing For What DOD Cybersecurity Audits May Uncover

Troutman Pepper Locke on

The U.S. Department of Defense released the final rule implementing the Cybersecurity Maturity Model Certification on Sept. 9. Through the program, the DOD seeks to enhance protections for sensitive information. Originally...more

Ice Miller

Cybersecurity is Now Foundational to Doing Business with the Department of Defense

Ice Miller on

Notwithstanding Executive Orders to reduce federal rules affecting industry in effect today, the Department of Defense (DOD) recently enacted new regulations by finalizing the Cybersecurity Maturity Model Certification (CMMC)...more

Cohen Seglias Pallas Greenhall & Furman PC

Final CMMC Rule Takes Effect on November 10, 2025

On September 9, 2025, the Department of Defense issued a long-awaited final rule regarding the Cybersecurity Maturity Model Certification (CMMC). This final rule which has been published in the Federal Register and amended...more

Womble Bond Dickinson

Final Rule on Cybersecurity Maturity Model Certification (CMMC)

Womble Bond Dickinson on

The Cybersecurity Maturity Model Certification (CMMC) has been a long-anticipated framework designed to bolster cybersecurity across the defense industrial base. After extensive development and revisions, the Department of...more

BakerHostetler

Ready or Not, CMMC Is Here: DoD Issues Final Rule Establishing Contract Clauses Implementing CMMC Program

BakerHostetler on

The wait is over. Five years after the Department of Defense (DoD) first introduced the Cybersecurity Maturing Model Certification (CMMC) program, the companion Final Rule was published in the Federal Register on Sept. 10....more

Clark Hill PLC

Pentagon to officially implement CMMC 2.0 requirements in contracts by Nov. 10

Clark Hill PLC on

The Pentagon has published the new rule to the Federal Register titled “Assessing Contractors’ Implementation of Cybersecurity Requirements.” ...more

Fox Rothschild LLP

Final CMMC Rule Effective Nov 10, 2025: What Federal Contractors Need to Know

Fox Rothschild LLP on

On September 9, 2025, the Department of Defense (DOD) released its long-anticipated final rule implementing the Cybersecurity Maturity Model Certification (CMMC) program. As discussed previously, this rule marks a significant...more

Sheppard Mullin Richter & Hampton LLP

The Expanding Scope of FCA-Cybersecurity Liability

The inexorable expansion of the False Claims Act (“FCA”) to cover virtually all types of cybersecurity breaches and violations – to include allegedly poor practices and failure to fully adhere to security controls –...more

Offit Kurman

Non-Compliance with CMMC Could Put Your DoD Contracts at Risk

Offit Kurman on

This past month, the Department of Defense sent the final rule for the new Cybersecurity Maturity Model Certification (CMMC) program under the Federal Acquisition Regulation to the Office of Information and Regulatory Affairs...more

Blank Rome LLP

Beyond the Balance Sheet: The Continued Importance of Cybersecurity in M&A

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In our August 1 post, we discussed how companies that acquire government contractors can inherit the False Claims Act (“FCA”) exposure based on their targets’ cybersecurity violations. Now, the Department of Justice (“DOJ”)...more

Mintz - Health Care Viewpoints

“False” Sense of Security: DOJ Announces False Claims Act Settlements Related to Failure to Comply with Cybersecurity Requirements

On July 31, 2025, the United States Department of Justice (DOJ) announced a pair of settlements with companies accused of having violated the False Claims Act (FCA) by falsely representing their compliance with certain...more

A&O Shearman

DoD Cybersecurity Maturity Model Certification requirements go into effect

A&O Shearman on

On December 16, 2024, the new Cybersecurity Maturity Model Certification (CMMC) 2.0 program from the U.S. Department of Defense (DoD) will go into effect. CMMC 2.0 aims to improve cybersecurity standards within the defense...more

Schwabe, Williamson & Wyatt PC

DoD Contractors: It’s Go Time for CMMC

On December 16, the U.S. Department of Defense’s Cybersecurity Maturity Model Certification Program (CMMC) final rule (the “CMMC Program Rule”) will become effective, to codify the CMMC requirements and assessment processes....more

Polsinelli

CMMC 2.0: Department of Defense Publishes Final Rule to Establish its Cybersecurity Maturity Model Certification 2.0 Program

Polsinelli on

After years in the making, on October 15, 2024, the U.S. Department of Defense (DoD) published its final rule to establish the Cybersecurity Maturity Model Certification (CMMC) Program, amending Title 32 of the Code of...more

Miles & Stockbridge P.C.

DoD Issues Final Rule for CMMC Program, Finally Setting the Stage for Full Implementation

Miles & Stockbridge P.C. on

The Department of Defense (DoD) published a Final Rule earlier this month formally implementing the Cybersecurity Maturity Model Certification (CMMC) Program. This Final Rule is the culmination of five years of work to...more

Harris Beach Murtha

New Rule Requires Defense Contractors to Meet Cybersecurity Standards

Harris Beach Murtha on

The Office of Information and Regulatory Affairs (OIRA) recently cleared the final rule for the U. S. Department of Defense’s Cybersecurity Maturity Model Certification (CMMC) program, putting the agency one step closer to...more

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