News & Analysis as of

DFARS Corporate Counsel Cybersecurity

Wiley Rein LLP

DOJ Continues Crackdown on Cybersecurity Compliance with $1.25M FCA Settlement

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The Department of Justice (DOJ) secured another win for its Civil Cyber-Fraud Initiative last week when it resolved a False Claims Act (FCA) action[1] alleging Pennsylvania State University (Penn State) failed to comply with...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

Venable LLP

The New CMMC Rule: FAQs for Federal Contractors and Subcontractors

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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

Pillsbury Winthrop Shaw Pittman LLP

Proposed Rules Overhaul Cybersecurity Requirements for Government Contractors

The Federal Acquisition Regulation (FAR) Council has proposed two new cybersecurity rules that would impose significant obligations and risks for federal government contractors. The proposed rules impose substantial cyber...more

McGuireWoods LLP

DOJ and Aerojet Settle for $9 Million in Qui Tam Cybersecurity False Claims Act Case

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On July 8, 2022, the U.S. Department of Justice announced a $9 million settlement with federal government contractor Aerojet Rocketdyne, Inc. for alleged violations of the False Claims Act (FCA) in a case pending in the...more

Pillsbury Winthrop Shaw Pittman LLP

Contractor Settles Cybersecurity-Related False Claims Act Suit for $9 million

A seven-year long False Claims Act suit comes to an end after Aerojet Rocketdyne reaches a $9 million settlement agreement for its alleged false certification of compliance with cybersecurity requirements. In the settlement...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

Wiley Rein LLP

DOD Suspends CMMC Version 1.0 and Charts a New Course With “CMMC 2.0”

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WHAT: On November 4, 2021, the U.S. Department of Defense (DOD) announced the completion of a months-long internal review and significant changes to the strategic direction of its Cybersecurity Maturity Model Certification...more

ArentFox Schiff

DOJ's New Civil Cyber-Fraud Initiative and How a Pending Case Could Test Its Efficacy

ArentFox Schiff on

The Department of Justice recently announced a new initiative that aims to hold government contractors accountable when they fail to meet required cybersecurity standards. In announcing the “Civil Cyber-Fraud Initiative” in...more

Holland & Knight LLP

False Claims Act Meets Cybersecurity: DOJ's New Civil Cyber-Fraud Unit

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Earlier this week, the U.S. Department of Justice (DOJ) announced the launch of its new Civil Cyber-Fraud Initiative — an effort designed to harness the department's knowledge in civil fraud enforcement, government...more

McGuireWoods LLP

Ready or Not…Government Contractor Cybersecurity Requirements Roll Out This Month

McGuireWoods LLP on

New Department of Defense (DoD) regulations related to government contractor Cybersecurity requirements become effective November 30, 2020. The progressive steps to mandatory contractor Cybersecurity Maturity Model...more

Bass, Berry & Sims PLC

It’s Here! DoD Issues Interim Rule Launching Two Cyber Assessment Programs

Bass, Berry & Sims PLC on

For over a year, we have been discussing the Department of Defense’s (DoD) eventual implementation of a Cybersecurity Maturity Model Certification (CMMC) program for Defense contractors, most recently during a webinar in...more

Holland & Knight LLP

The Top 10 Compliance Challenges for 2020

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Attorneys Eric Crusius, Amy Fuentes, Kelsey Hayes and Vijaya Surampudi co-authored an article describing the major issues they expect government contracting professionals to face in the coming year. For example, the...more

Miles & Stockbridge P.C.

DOD Issues “Draft Version 0.6” of Its Cybersecurity Maturity Model Certification, Part of an Initiative That Likely Will Have...

Miles & Stockbridge P.C. on

On November 7, 2019, DOD issued “Draft Version 0.6” of its Cybersecurity Maturity Model Certification (CMMC) – a 90-page document that is available on DOD’s CMMC website.  Version 0.6 is a significant step forward, but there...more

Jones Day

The Stakes for Complying With DoD Cybersecurity Requirements Are Higher Than Ever

Jones Day on

The Situation: The United States government has been ramping up its efforts to protect sensitive data and is making clear it expects its contractors to protect data they receive and create. According to a recent Inspector...more

Baker Donelson

Failure to Comply with the Cybersecurity Requirements of Your Government Contracts Can Lead to False Claims Act Liability

Baker Donelson on

Two recent cases now prove that to avoid liability under the False Claims Act (FCA), government contractors must build and monitor information systems to protect government information and must also implement policies and...more

Holland & Knight LLP

DoD Issues Guidance for Compliance with Cybersecurity Regulations

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• In recently released guidance, the U.S. Department of Defense (DoD) confirms a "one size does not fit all" approach to contractor compliance with its cybersecurity clauses that cover the safeguarding of contractor networks,...more

Cooley LLP

Alert: DoD Contractors Required to Meet Cybersecurity Requirements by Year End

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The window for Department of Defense (DoD) contractors to bring themselves into compliance with cybersecurity requirements is closing. Specifically, changes to the Defense Federal Acquisition Regulation Supplement (DFARS)...more

Holland & Knight LLP

DoD's New Cybersecurity and Cloud Standards and Reporting Requirements

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The Department of Defense (DoD) released interim rules implementing provisions of the 2013 and 2015 National Defense Authorization Acts. The rules, released on Aug. 26, 2015, are effective immediately and establish the...more

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