Cybersecurity Insights: Updates on CMMC Implementation and CUI Identification
Marti Arvin and Anthony Buenger on the CMMC Framework
The U.S. Department of Homeland Security (DHS) on Nov. 1, 2023, announced that cybersecurity readiness would be used as an evaluation factor for contracts involving the use of Controlled Unclassified Information (CUI). This...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, 2023, the U.S. Department of Homeland Security (DHS) issued a long-anticipated cybersecurity final rule (DHS Final Rule), which revises an existing clause and adds two new clauses to the Homeland Security...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, 2023, the U.S. Department of Homeland Security (DHS) issued a final rule that revises the Homeland Security Acquisition Regulation (HSAR) to implement security and privacy measures for contractors to safeguard...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
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
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
On December 28, 2016, the New York Department of Financial Services ("DFS") released a revised version of a proposed regulation that would require banks, insurance companies, and other financial services institutions...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
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
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