News & Analysis as of May 8, 2025

Subcontractors

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Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk... more +

Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now. less -

The “Prestige”: DoD Unveils NIST SP 800-171 Revision 3, Organizationally Defined Parameters

McCarter & English Blog: Government Contracts... on 4/28/2025

On April 15, 2025, the Department of Defense (DoD) released official guidance on Organizationally Defined Parameters (ODPs) appearing in the newly published NIST SP 800-171 Revision 3. At the same time, the DoD reaffirmed...more

Proposed Regulation on Controlled Unclassified Information Standardizes Process for CUI Identification and Handling Across Federal...

Morrison & Foerster LLP - Government... on 1/24/2025

The Federal Acquisition Regulation (FAR) Council issued its long awaited proposed rule on Controlled Unclassified Information (CUI) on January 15, 2025. The proposed rule establishes a common form to be used by all federal...more

They Did It. They Really Did It! The Arrival of the FAR CUI Proposed Rule

McCarter & English Blog: Government Contracts... on 1/17/2025

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

DoD Releases Final CMMC Program Rule, Formally Initiating Its Cybersecurity Program

Vinson & Elkins LLP on 11/22/2024

On October 15, 2024, the Department of Defense (“DoD”) released its final rule (the “Final Rule”) formally establishing the Cybersecurity Maturity Model Certification (“CMMC”) program, nearly three years after first...more

Updates on Cybersecurity Requirements for Government Contractors

Wiley Rein LLP on 11/22/2024

Part of the Biden Administration’s push to enhance U.S. cybersecurity capabilities has focused on imposing new requirements on government contractors. The 2023 National Cybersecurity Strategy suggested, for example, that...more

U.S. Department of Defense Set to Implement Its Cybersecurity Maturity Model Certification Program With Publication of New Rule

Paul Hastings LLP on 10/24/2024

On October 15, 2024, the Department of Defense (“DoD”) published the final version of its rule implementing the Cybersecurity Maturity Model Certification (“CMMC”) Program under Title 32 of the Code of Federal Regulations...more

Department of Defense Finalizes Rule Adding New Cybersecurity Requirements for Defense Contractors and Subcontractors

Snell & Wilmer on 10/23/2024

The U.S. Department of Defense (DOD) has published a Final Rule to implement the Cybersecurity Maturity Model Certification (CMMC) program, which establishes minimum cybersecurity requirements for nearly all DOD contracts....more

DOD Crystalizes CMMC 2.0 Program Rule

Wiley Rein LLP on 10/15/2024

WHAT: On October 15, 2024, the U.S. Department of Defense (DOD) will publish the final CMMC 2.0 Program rule. DOD’s final rule outlines the mechanisms that DOD will use to prescribe cybersecurity standards for safeguarding...more

CMMC Barrels Closer to Implementation with Latest Proposed Rule Establishing DFARS Contract Clauses

BakerHostetler on 9/11/2024

Cybersecurity Maturity Model Certification (CMMC) is coming — and now appears to be coming faster than many defense contractors believed. In the latest signal of CMMC’s forward momentum, the Department of Defense (DoD) issued...more

CMMC and DFARS 252.204-7021—Is the Sequel Better than the Original?

McCarter & English Blog: Government Contracts... on 9/6/2024

Sequels are rarely better than the films that precede them, and yet, sometimes a story is just too compelling to be limited to just one film. At the tail end of a summer full of Hollywood sequels, the Department of Defense...more

The Race to Full Implementation Continues: CMMC 2.0 Gains Even More Traction

Morris, Manning & Martin, LLP on 8/29/2024

As the presidential race rages on, so too does the race to fully implement the Cybersecurity Maturity Model Certification (CMMC) 2.0 program. The CMMC 2.0 program impacts Defense Industrial Base (DIB) contractors and...more

The Pentagon's CMMC Program Takes a Big Step Forward

Holland & Knight LLP on 8/22/2024

The U.S. Department of Defense (DOD) issued the proposed Defense Federal Acquisition Regulation Supplement (DFARS) rules that will implement the Cybersecurity Maturity Model Certification (CMMC) program. These rules, which...more

DOD’s CMMC 2.0 Program Takes Step Forward with Release of Contract Rule Proposal

Woods Rogers on 8/21/2024

The United States Department of Defense (DoD) took another big step on the path to instituting its highly anticipated Cybersecurity Maturity Model Certification 2.0 program (CMMC 2.0). Once finalized, CMMC 2.0 will establish...more

The Subcontractor Performed. The Prime Contractor Paid. But a Hacker Ended Up with the Money. Who Is Responsible?

Venable LLP on 6/6/2024

When hackers gain access to a subcontractor’s information systems and divert the prime contractor’s payment to themselves instead of to the subcontractor, does the prime contractor still have to pay the subcontractor?...more

DoD’s Proposed CMMC Rule: Groundhog Day… or a Final Rule in the Works?

McCarter & English Blog: Government Contracts... on 2/14/2024

On December 26, 2023, the Department of Defense (“DoD”) belatedly gifted defense contractors and subcontractors a Proposed Rule on the Cybersecurity Maturity Model Certification (“CMMC”) Program. DoD also released eight CMMC...more

CMMC 2.0: Defense Contractors Get Ready

Goodwin on 1/24/2024

The US Department of Defense (DoD) has issued a proposed rule to implement its long-awaited Cybersecurity Maturity Model Certification program (CMMC 2.0). This proposed rule — released on December 26, 2023, and published in...more

Department of Defense Delivers Highly Anticipated CMMC Proposed Rule

Pillsbury Winthrop Shaw Pittman LLP on 1/19/2024

The proposed rule requires contractors to make annual affirmations regarding their cybersecurity maturity, thus increasing their risk of False Claims Act Liability. The proposed rule allows for limited use of Plans of...more

CMMC From the Bottom Up: A Detailed Review of Level 1

McDermott Will & Emery on 1/9/2024

In this series of articles, we explore the different certification requirements of CMMC Level 1, 2 and 3, the impact on contractors and external service providers, and proposed next steps... On December 26, 2023, the US...more

An Overview Of The Defense Department’s Long-awaited Proposed Regulations For Its Cybersecurity Maturity Model Certification...

Morrison & Foerster LLP - Government... on 1/3/2024

The U.S. Department of Defense released a special holiday treat for government contractors and subcontractors last week in the form of long-promised proposed regulations for its Cybersecurity Maturity Model Certification...more

The New CMMC Rule: FAQs for Federal Contractors and Subcontractors

Venable LLP on 1/2/2024

The Department of Defense (DoD) delivered its proposed Cybersecurity Maturity Model Certification Program rule (CMMC) the day after Christmas this year, including several related guidance documents (listed here). The proposed...more

Department of Defense Releases Long-Awaited CMMC Proposed Rule

Holland & Knight LLP on 12/28/2023

Two years after announcing the second iteration of the U.S. Department of Defense's (DoD) Cybersecurity Maturity Model Certification (CMMC) program, the DoD released its proposed rule that, if adopted, will implement the...more

Update: FAR Council Proposes Pair of Major Cybersecurity Rules for Government Contracts

Wiley Rein LLP on 10/12/2023

WHAT: As we previously reported here, on October 3, 2023, the Federal Acquisition Regulatory Council (FAR Council) proposed a pair of major cybersecurity rules intended to implement key parts of President Biden’s May 2021...more

Weekly Update for Government Contractors and Commercial Businesses – June 2023 #3

PilieroMazza PLLC on 6/19/2023

Assessing Contractor Implementation of Cybersecurity Requirements (DFARS Case 2019-D041), Department of Defense (DOD), Proposed Rule - DOD is amending an interim rule to implement the Cybersecurity Maturity Model...more

Federal Drive with Tom Temin Interviews PilieroMazza’s Kevin Barnett on DOD Rule Updating SPRS Assessment Process for Federal...

PilieroMazza PLLC on 6/19/2023

The Department of Defense (DOD) issued a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) requiring Contracting Officers to use Supplier Performance Risk System (SPRS) assessments when...more

Weekly Update for Government Contractors and Commercial Businesses – March 2023 #2

PilieroMazza PLLC on 3/13/2023

LITIGATION & DISPUTE RESOLUTION - The FCA at the Supreme Court, Part 2 of 4: Addressing the Standard for Knowingly Submitting a False Claim - The False Claims Act (FCA) is seeing quite a bit of action at the Supreme...more

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