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President Trump’s Cyber Mandate: Analysis of Executive Order on Strengthening U.S. Cybersecurity

President Trump issued a cybersecurity Executive Order, “Sustaining Select Efforts to Strengthen the Nation’s Cybersecurity” (Trump EO), along with a corresponding Fact Sheet on June 6, 2025. The Trump EO clears some of the...more

DOD Mandates Use of Software Acquisition Pathway for Software Development Procurements

WHAT: Department of Defense (DOD) Secretary Pete Hegseth issued a memorandum titled “Directing Modern Software Acquisition to Maximize Lethality” that is intended to reform DOD’s procurement involving software development....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

Updates on Cybersecurity Requirements for Government Contractors

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

DOD Seeks Contractor Disclosures of Foreign Access to Software Source Code

WHAT: The U.S. Department of Defense (DOD) issued a proposed rule to implement Section 1655(a) and (c) of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2019 (Pub. L. 115-232). The proposed rule would...more

DOD Crystalizes CMMC 2.0 Program Rule

WHAT: On October 15, 2024, the U.S. Department of Defense (DOD) will publish the final CMMC 2.0 Program rule. DOD’s final rule outlines the mechanisms that DOD will use to prescribe cybersecurity standards for safeguarding...more

Policy Patches: An Update on Software Security Regulation

So far, 2024 has been another very busy year for U.S. cybersecurity regulation. Among the top priorities has been software security, as we previewed early this year. Companies that sell software to the federal government or...more

Cybersecurity Updates: NIST Publishes SP 800-171 Revision 3. What Changed, and What Comes Next?

In May 2024, the National Institute of Standards and Technology (NIST) published Special Publication 800-171 Rev 3, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations, and the accompanying...more

Not So Fast, NIST: DOD Issues Class Deviation to Retake Control Over What Cybersecurity Requirements Apply to its Contracts

WHAT: On May 2, 2024, the U.S. Department of Defense (DOD) issued a Defense Federal Acquisition Regulation Supplement (DFARS) class deviation related to the cybersecurity standards required for covered contractor information...more

What Does CISA’s Secure Software Development Form Mean for Contractors?

WHAT: The U.S. Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (CISA) published the final version of its Secure Software Development Attestation Common Form (Common Form) and announced...more

DOD Publishes Video Overview of CMMC Program and Logistics

WHAT: On February 16, 2024, the U.S. Department of Defense (DOD) posted a 40-minute video overview of DOD’s proposed requirements for the Cybersecurity Maturity Model Certification (CMMC) program. The video is available here,...more

DOD Proposed Rule Solidifies Plans for CMMC 2.0 Program: Security Requirements, Assessments, Affirmations, and Some Flow-Down...

WHAT: The U.S. Department of Defense (DOD) has issued a proposed rule setting forth the requirements for its long-anticipated Cybersecurity Maturity Model Certification 2.0 (CMMC) program. The proposed rule primarily...more

Update: FAR Council Proposes Pair of Major Cybersecurity Rules for Government Contracts

WHAT: As we previously reported here, on October 3, 2023, 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...more

FAR Council Proposes Pair of Major Cybersecurity Rules for Government Contracts

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

DHS Updates CUI Safeguarding and Incident Reporting Requirements for Contractors

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

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

Cybersecurity Updates: What We’ve Learned About CMMC 2.0 So Far

Last November, the U.S. Department of Defense (DOD) announced sweeping changes to the Cybersecurity Maturity Model Certification (CMMC) program in a new “version 2.0.” Although we are still awaiting the interim regulations,...more

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