Cybersecurity Insights: Updates on CMMC Implementation and CUI Identification
Marti Arvin and Anthony Buenger on the CMMC Framework
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
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 Cybersecurity Maturity Model Certification (CMMC) Program has been a headache for many defense contractors since the idea was first introduced in 2019. The program seeks to protect unclassified information, including...more
The National Institute of Standards and Technology (NIST) released the third revision of its Special Publication (SP) 800-171, "Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations." This...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
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
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
Well, the wait is over. Just as 2023 came to a close, on December 26, 2023, the Department of Defense (“DoD”) published the much-anticipated Proposed Rule for the DoD’s Cybersecurity Maturity Model Certification (“CMMC”)...more
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
A recently unsealed False Claims Act qui tam complaint against Penn State is the latest in line with DOJ’s Civil Cyber-Fraud Initiative. The case is United States ex rel. Matthew Decker v. Pennsylvania State University,...more
Contractors that do business with the U.S. Department of Defense (DoD) and handle Controlled Unclassified Information (CUI) have been awaiting the issuance of a rule implementing the Cybersecurity Maturity Model Certification...more
For nearly two years, we have been reporting on this blog about the Department of Defense’s (DoD) Cybersecurity Maturity Model Certification (CMMC) program. CMMC is a training, certification, and third-party assessment...more
Defense contractors and their subcontractors and supply chains that have been preparing for the challenge of complying with the Cybersecurity Maturity Model Certification (CMMC) recently received some welcome news from the...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
On January 30, 2020, the U.S. Department of Defense (“DoD”) released Version 1.0 of its Cybersecurity Maturity Model Certification (“CMMC”) framework (CMMC overview here; CMMC Version 1.0 and appendices here). By 2026, DoD...more
January 2020 was a very important month for DOD’s Cybersecurity Maturity Model Certification (CMMC) initiative. Last week, on January 31, 2020, DOD issued CMMC “Version 1.0” to the public....more
On January 30, the US Department of Defense (DoD) released version 1.0 of the Cybersecurity Maturity Model Certification (CMMC) framework, which will require DoD contractors and subcontractors to obtain third-party...more
2019 has been a year of pivotal developments for defense contractors in the realm of cybersecurity compliance. The Department of Defense (DoD) issued six guidance memoranda to assist its acquisition personnel in developing...more
The Department of Defense (DoD) is planning to release Volume 1.0 of the Cyber Maturity Model Certification (CMMC) framework, which will affect the award and continued performance of all DoD contracts. In response to the...more
As predicted, a recent decision from the Federal District Court for the Eastern District of California is the first sign of a new, and potentially enormous wave, of Civil False Claims Act, 31 U.S.C. §§ 3729-33 (“FCA”) actions...more
The DoD clarifies its expectation for full compliance to protect Controlled Unclassified Information (CUI) residing on Contractor Systems from cyber incidents. A defense contractor’s updated and current System Security...more
On August 26, 2015, the Department of Defense (DoD) published a long-awaited Interim Rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to require “rapid” reporting of “cyber incidents” that result in...more