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
The Order directs the revocation of any active or current security clearances held by former intelligence officials who worked with former President Biden on his 2020 presidential campaign and several specific individuals....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
On October 11, 2024, the United States Department of Defense (DOD) published a final rule implementing its Cybersecurity Maturity Model Certification (CMMC) program, which is designed to verify that defense contractors are...more
On August 22, 2024, the United States intervened in a whistleblower suit against the Georgia Institute of Technology, initially filed by current and former members of Georgia Tech’s cybersecurity team, alleging that Georgia...more
On May 14, the National Institute of Standards and Technology (NIST) released “Revision 3” to Special Publication 800-171 (Protecting Controlled Unclassified Information on Nonfederal Systems and Organizations) and 800-171A...more
On May 2, the Department of Defense (DOD) issued a class deviation to DFARS 252.204-7012 “to provide industry time for a more deliberate transition upon the forthcoming release of [National Institute of Standards and...more
The United States notified the U.S. District Court for the Northern District of Georgia that it plans to intervene in a False Claims Act case filed against Georgia Tech Research Corporation (Georgia Tech) by its Associate...more
In this episode, Wiley partners Gary Ward, Tracye Howard, and Craig Smith examine the ongoing developments related to implementation of the Cybersecurity Maturity Model Certification (CMMC) program. They discuss the current...more
On November 30, 2023, the Inspector General of the Department of Defense (“DoD IG”) released a Special Report: Common Cybersecurity Weaknesses Related to the Protection of DoD Controlled Unclassified Information on Contractor...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
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 Department of Defense Inspector General (DoDIG) recently released its “Audit of the DoD’s Implementation and Oversight of the Controlled Unclassified Information [CUI] Program” (DODIG-2023-078). The audit highlights some...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
Currently defense contractors who receive or create Controlled Unclassified Information (“CUI”) from or for the U.S. Department of Defense (“DoD”) are subject to several contract-based cybersecurity requirements, including...more
On June 16, 2022, the Department of Defense (DoD) issued a memorandum to its contracting officers emphasizing their obligation to monitor compliance by DoD contractors with the cybersecurity requirements of their contracts....more
WHAT: On November 4, 2021, the U.S. Department of Defense (DOD) announced the completion of a months-long internal review and significant changes to the strategic direction of its Cybersecurity Maturity Model Certification...more
America’s data is under attack. Solar Winds and other recent headline-grabbing stories have demonstrated that foreign adversaries are eager to hack into computer systems for a wide range of purposes. The US Department of...more
People like to say that cybersecurity threats are constantly evolving. So perhaps it’s fitting that cybersecurity compliance is undergoing a significant evolution of its own this year, too. That evolution is the arrival of...more
Federal government lessees seeking to occupy high-security spaces in foreign-owned buildings will be required to obtain complete beneficial ownership and impose access restrictions on owners and property managers. The...more