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Update: DOJ and CISA Issue New National Security Program to Regulate Foreign Access to Sensitive Data

On January 8, 2025, the U.S. Department of Justice (Department or DOJ) issued new rules required by then-President Biden’s February 2024 Executive Order (EO) 14117 to establish a new regulatory framework aimed at “Preventing...more

Chinese AI Firm DeepSeek Triggers a Wide U.S. Policy Response

Policymakers and technologists have expressed concern that DeepSeek, a Chinese AI company with connections to the Chinese Communist Party (CCP) and the potential to share user data with China Mobile, could be putting U.S....more

CISA 2015 Reauthorization – Are Changes on the Horizon?

As we noted in Federal Cybersecurity Policy in 2025: What to Watch in Changing Times, key parts of the Cybersecurity Information Sharing Act of 2015 (CISA 2015), the United States’ foundational cybersecurity information...more

FAR Council Unveils Long-Anticipated Rule for Controlled Unclassified Information

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

CYBER UPDATE: White House Seeks Regulatory Harmonization While Exploring a Pilot for Reciprocity Amid Proliferation of Regulations

Companies, particularly those in “critical infrastructure” sectors, have seen a dramatic increase in cybersecurity regulatory requirements in just the past few years – and the White House is looking to move faster. At the...more

FCC Releases Draft NPRM to Secure Equipment Authorization Testing Labs

On May 1, the Federal Communications Commission (FCC or Commission) released a draft Notice of Proposed Rulemaking (draft NPRM or Draft) regarding the Commission’s equipment authorization program. The bipartisan proposal –...more

New White House Policy Previews Increased Cybersecurity Oversight and Regulation

On April 30, 2024 the White House updated the foundational U.S. government policy that defines critical infrastructure (CI) sectors and establishes a coordination structure within the federal government to support owners and...more

DOJ Kicks Off Work to Regulate Foreign Access to Sensitive Personal Data Under New EO

On March 5, 2024, the Department of Justice (DOJ) issued an Advance Notice of Proposed Rulemaking (ANPRM) regarding Access to Americans’ Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern. The...more

Commerce Considers Regulating Connected Vehicles to Protect Against Foreign Adversaries

On March 1, 2024, at the direction of President Biden, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an Advanced Notice of Proposed Rulemaking (ANPRM) seeking public comment on the proposed...more

FCC Continues Push to Establish IoT Cyber Trust Mark Program

On February 22, 2024, the Federal Communications Commission (FCC or “Commission”) released a Public Draft of a Report and Order that, if adopted, would establish a voluntary labeling program for Internet of Things (IoT)...more

What Contractors Need to Know About DOD’s National Defense Industrial Strategy

WHAT: On January 11, 2024, the U.S. Department of Defense (DOD) published its National Defense Industrial Strategy (NDIS). In line with DOD’s continued emphasis on modernizing and strengthening the supply chain and...more

SEC Breach Reporting Rules Effective as of December 18

For most filers, the U.S. Securities and Exchange Commission’s (SEC) new Form 8-K rules for reporting material cybersecurity incidents took effect yesterday, December 18, 2023. The rule has been controversial and created some...more

Important NDAA Provisions for Contractors and Their Supply Chains

On December 14, 2023, the House of Representatives passed the National Defense Authorization Act for Fiscal Year 2024 (NDAA), following the Senate’s passage a few days earlier. The President is expected to sign the NDAA into...more

Cyber Incident Reporting Guidance: DOJ Explains How It Will Determine if a Public Disclosure Poses Substantial National Security...

The cyber reporting landscape is rapidly shifting. Many agencies are developing rules, and a major player has been the U.S. Securities and Exchange Commission (SEC), with important questions arising about implementation of...more

Intelligence Gathering and FISA Section 702: Lots of Heat Obscures Important Practical Issues

As heated debate continues over possible changes to the Foreign Intelligence Surveillance Act (FISA), which is poised to expire later this month, we wanted to provide some perspective on a few practical issues. As former DOJ...more

FCC Sets January Deadline for International Section 214 Authorization Holders to Submit Foreign Interest Holder Information

On December 8, 2023, the Federal Communications Commission (FCC or Commission) released its anticipated information collection to update the Commission’s records regarding the foreign ownership of international Section 214...more

SEC Cyber Reporting Mandates: How to Request a National Security or Public Safety Delay

On December 18, the Securities and Exchange Commission's (SEC) new disclosure requirements go into effect and will require public companies to publicly report material cybersecurity incidents within four days of making a...more

DHS Calls for Critical Harmonization of Cyber Incident Reporting

On September 19, 2023, the Department of Homeland Security (DHS) released a Report to Congress (Report) on the Harmonization of Cyber Incident Reporting to the Federal Government. The Report reflects on the 52 in-effect or...more

FCC Provides Guidance on International Section 214 Information Collection

The Federal Communications Commission’s (FCC or Commission) Office of International Affairs (OIA) recently released an Order in the agency’s ongoing proceeding related to its adoption of an Order and Notice of Proposed...more

A New White House Project on Responsible AI Sends a Message to the Private Sector, Including Contractors

It is hardly news that artificial intelligence (AI) has captured attention across the federal government. Wiley’s multidisciplinary AI team has been involved in efforts at the National Institute for Standards and Technology...more

CISA Seeks Comments on New Security Attestation for Software Procurements

On April 27, 2023, the Cybersecurity and Infrastructure Security Agency (CISA) of the U.S. Department of Homeland Security (DHS) issued a Notice of Agency Information Collection Activities to solicit public comments on a...more

FCC To Propose Sweeping Changes to Regulation of International Telecommunications Service

On March 30, 2023, the Federal Communication Commission (FCC or Commission) released a draft Order and Notice of Proposed Rulemaking on international section 214 authorizations (the Draft Order and Draft NPRM), which governs...more

National Cybersecurity Strategy Outlines A New Era of Cybersecurity Regulation

On March 2, 2023, the White House Office of the National Cyber Director (ONCD) released the National Cybersecurity Strategy (“Strategy”). The Strategy outlines the Administration’s priorities for cyber regulations and policy....more

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