News & Analysis as of

Department of Defense (DOD) Cyber Incident Reporting

Holland & Knight LLP

The Pentagon's CMMC Program Takes a Big Step Forward

Holland & Knight LLP on

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

Wiley Rein LLP

CMMC 2.0 Update: DOD Proposed Rule Introduces Standard Terms for Contracts Subject to CMMC 2.0, Including Yet Another 72-Hour...

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WHAT: The U.S. Department of Defense (DOD) just published the second of two proposed rules setting forth key requirements for its long-anticipated Cybersecurity Maturity Model Certification (CMMC) 2.0 program. The earlier...more

McCarter & English Blog: Government Contracts...

CISA’s CIRCIA Proposed Rule: Another Player Enters the Reporting Regime

Cyber incidents involving critical infrastructure pose a serious risk to the US. In March 2024, the Environmental Protection Agency and the National Security Advisor warned state governors about potential attacks on drinking...more

Clark Hill PLC

DOD Issues Class Deviation Regarding Cyber Security Requirements

Clark Hill PLC on

Earlier this month (on May 2, 2024) the Defense Department (DOD) issued Class Deviation—Safeguarding Covered Defense Information and Cyber Incident Reporting effective that day....more

Mayer Brown

US DoD Issues Class Deviation Delaying DFARS Implementation of Upcoming NIST SP 800-171, Revision 3

Mayer Brown on

On May 2, 2024, the Department of Defense (DoD) issued a class deviation to DFARS 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting. The deviation relates to contractors’ compliance with...more

McDermott Will & Emery

CMMC Level 3: Strict Scoping and Expansive Requirements

McDermott Will & Emery on

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

Sheppard Mullin Richter & Hampton LLP

CISA Cyber Incident Reporting for Critical Infrastructure Will Significantly Impact Government Contractors, Suppliers, and Service...

The Cybersecurity and Infrastructure Security Agency (“CISA”) recently released its new Proposed Rule pursuant to the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (“CIRCIA”), which was published in the...more

Bass, Berry & Sims PLC

Final Rule Expands Defense Industrial Base Cybersecurity Program Eligibility Criteria

On March 12, the Department of Defense (DOD) promulgated a final rule that expands the eligibility criteria for the Defense Industrial Base (DIB) Cybersecurity Program, a voluntary initiative aimed at bolstering the DIB’s...more

Paul Hastings LLP

CISA Proposes Sweeping Cybersecurity Incident Reporting for U.S. Companies

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On March 27, 2024, the Cybersecurity & Infrastructure Security Agency (“CISA”) released proposed regulations requiring expansive new cybersecurity incident and ransomware payment reporting across sixteen “critical...more

Wiley Rein LLP

CISA’s Proposed Cyber Incident Reporting Requirements Would Hit a Range of Industries and Sectors

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The U.S. Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA) is publishing a proposed rule (Proposal or NPRM) that will require broad segments of industry to meet onerous and quick...more

Goodwin

DoD Significantly Expands Voluntary Cybersecurity Program for Defense Contractors

Goodwin on

The U.S. Department of Defense (DoD) published a finalized rule on March 12, 2024, which expands access to defense contractors who wish to participate in the Defense Industrial Base (DIB) Cybersecurity (CS) Program....more

Ankura

DOD Issues Memo on FedRAMP Requirements for Defense Contractors

Ankura on

On December 21, 2023, the Department of Defense (DoD) issued a memorandum (Memo) providing guidance and clarification on the security and cyber incident management requirements applicable for the use of external Cloud Service...more

PilieroMazza PLLC

Protecting Our Nation’s Data: Cybersecurity Compliance for Government Contractors

PilieroMazza PLLC on

In an era where digital threats are ever-evolving, ensuring the security of sensitive government data is paramount, especially for government contractors working on defense contracts. Join PilieroMazza’s Cy Alba and Daniel...more

Wiley Rein LLP

IG Report Finds Cyber Info Sharing Works but Barriers Remain – Implications for Incident Reporting?

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A recent Report to Congress from the Office of Inspector General (OIG) of the Intelligence Community addresses barriers to information sharing that Congress sought to promote in landmark 2015 legislation. This report may have...more

Bass, Berry & Sims PLC

Cyber Incident Reporting May Be “Material” for Federal Contractors

Bass, Berry & Sims PLC on

Last month, the Federal Acquisition Regulatory Council proposed new cybersecurity and incident reporting regulations for federal contractors on behalf of the Department of Defense (DoD), the General Services Administration...more

Morrison & Foerster LLP - Government...

The FAR Council’s Proposed Cybersecurity Overhaul: Lots Of Questions, But Only Some Answers

In what can best be described as a tsunami of cybersecurity regulation, the Federal Acquisition Regulation (FAR) Council—consisting of the Department of Defense (DoD), General Services Administration (GSA), and National...more

Wiley Rein LLP

FAR Council Proposes Pair of Major Cybersecurity Rules for Government Contracts

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WHAT: 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 Executive Order No. 14028 on Improving the Nation’s...more

Wiley Rein LLP

Biden Administration Looks at Harmonizing Cyber Regulations Amidst Flurry of New Activity

Wiley Rein LLP on

Cybersecurity continues to be top of mind for federal and state policymakers. This advisory identifies and analyzes some major recent developments that present opportunities and challenges in the coming months for a broad...more

Pillsbury Winthrop Shaw Pittman LLP

DHS Implements New Security and Privacy Measures for Controlled Unclassified Information

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

Wiley Rein LLP

DHS Updates CUI Safeguarding and Incident Reporting Requirements for Contractors

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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

McDermott Will & Emery

Shields Up: DoD Reminds Contracting Officers that DFARS Cyber Clauses Have Consequences

On June 16, 2022, the US Department of Defense (DoD) issued a memorandum (DoD Memo) “reminding” contracting officers that noncompliance with the Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012,...more

Fox Rothschild LLP

DOD Memo Identifies Penalties for Noncompliance with DFARS Cyber Requirements

Fox Rothschild LLP on

While Cybersecurity Maturity Model Certification 2.0 (CMMC 2.0) is still a work in progress, federal contractors should beware of the existing DFARS cybersecurity requirements. ...more

BakerHostetler

Reporting Cyberattacks: Challenges for US Government Defense Contractors

BakerHostetler on

A report published by the U.S. Government Accountability Office (GAO) on Dec. 8, 2021, highlights the complexity surrounding cybersecurity compliance for the Department of Defense (DOD) and its contractors. The GAO’s report...more

Akin Gump Strauss Hauer & Feld LLP

Twin DOJ Initiatives Tackle Cybersecurity Fraud and Cryptocurrency Enforcement

Key Points - On October 6, 2021, the DOJ announced two new initiatives: the Civil Cyber-Fraud Initiative and the National Cryptocurrency Enforcement Team. The Civil Cyber-Fraud Initiative will fight rising cyber threats...more

Stinson - Government Contracting Matters

A Sea Change in Handling of Government Contractor Cyber Incident Reporting?

In the wake of increasing cybersecurity threats and incidents, the U.S. Department of Defense (DoD) amended its Federal Acquisition Regulation Supplement (DFARS) in 2015 to issue the 252.204-7012, Safeguarding Covered Defense...more

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