Cybersecurity Insights: Updates on CMMC Implementation and CUI Identification
Marti Arvin and Anthony Buenger on the CMMC Framework
The recent National 8(a) Small Business Conference underscored pressing challenges and critical updates regarding the Cybersecurity Maturity Model Certification (CMMC) Program, now in an advanced phase known as CMMC 2.0. The...more
The FAR Council issued a proposed rule that would amend the several FAR provisions and add new clauses to provide guidance on the safe handling of CUI. Public comments on the proposed rule are being accepted until March 17,...more
On January 15, 2025, the FAR Council finally released a proposed rule (the Rule)1 regulating the use and handling of controlled unclassified information (CUI) as a part of the general strategy to reduce threats of...more
Earlier this year, the FAR Council issued a proposed rule to implement the Controlled Unclassified Information (CUI) Program as it relates to federal contracts. The proposed rule is "just one element of a larger strategy to...more
On January 15, 2025, the Federal Acquisition Regulatory Council (FAR Council) proposed two significant rule changes that could reshape compliance obligations for government contractors: one establishing standardized...more
The wait is finally over! After more than 14 years of anticipation, the Federal Acquisition Regulation (“FAR”) Proposed Rule on Controlled Unclassified Information (“CUI”) was released on January 15, 2025 and comes as part of...more
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
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
On January 15, 2025, the Department of Defense (DOD), General Services Administration (GSA), and the National Aeronautics and Space Administration (NASA) (collectively, “the FAR Council”) issued a long-anticipated proposed...more
On January 15, 2025, the Federal Acquisition Regulatory Council published a proposed rule (the FAR CUI Rule) that would amend the Federal Acquisition Regulation (FAR) to impose government-wide cybersecurity, training, and...more
Over the last two decades, federal contractors have been frustrated by the Government’s hodgepodge approach to regulating Controlled Unclassified Information (CUI). Various agencies have implemented differing definitions,...more
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
On January 15, 2025, the Federal Acquisition Regulation (“FAR”) Council issued its long-awaited “CUI Rule.” CUI, or Controlled Unclassified Information, is information that the government creates or possesses, or that an...more
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
On October 15, 2024, the Department of Defense (DoD) published the final rule for the Cybersecurity Maturity Model Certification (CMMC) Program that not only finalizes the long-anticipated CMMC Rule but also foreshadows what...more
After numerous fits and starts, on October 14, the Department of Defense (DoD) published a final rule implementing the Cybersecurity Maturity Model Certification (CMMC) program. Borne from documented deficiencies in the...more
Less than 10 months after the issuance of its proposed rule, DoD has issued this final rule establishing the CMMC program. DoD’s issuance of the final rule demonstrates the government’s continued commitment to...more
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
After a nearly five-year rulemaking process, the U.S. Department of Defense (DoD) published the Final Cybersecurity Maturity Model Certification 2.0 (CMMC) program rule in the Federal Register on Oct. 15, 2024, codified at 32...more
On October 15, 2024, the Department of Defense (DoD) published the long-anticipated first part of its final rule (the Final Rule) for the Cybersecurity Maturity Model Certification (CMMC) program. After the implementation of...more
On Tuesday, October 15, 2024, the U.S. Department of Defense (“DOD”) issued its final rule for its much anticipated Cybersecurity Maturity Model Certification (“CMMC”) program. The CMMC program will eventually require one of...more
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
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
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
Defense contractors and subcontractors that handle Controlled Unclassified Information (CUI) and do not have robust information-security system controls in place better get their house in order now if they want to do business...more