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DOJ’s 90-Day Data Security Compliance Grace Period is Over: Are You Compliant?

The U.S. Department of Justice (“DOJ”) Data Security Program (“DSP”) 90-day enforcement grace period ended as of July 8, 2025. While the program became effective April 8, 2025, DOJ implemented a 90-day enforcement grace...more

DOJ Announces 90-Day Grace Period for Companies to Comply with New Data Security Rules on Foreign Adversary Access to U.S....

The U.S. Department of Justice (DOJ)’s new data security rule went into effect April 8, 2025. The rule creates what are effectively export controls and requires companies to take measures to prevent U.S. sensitive personal...more

DOJ Sues Georgia Tech Entities for Cybersecurity Failures in the Latest Civil Cyber Fraud Initiative (CCFI) Activity

On August 22, 2024, the United States Department of Justice (DOJ) filed a Complaint-In-Intervention (the “Complaint”) against the Georgia Institute of Technology (Georgia Tech) and Georgia Tech Research Corp. (GTRC). The...more

Latest Cyber-Related FCA Settlement Underscores the Breadth of DOJ’s Civil Cyber-Fraud Focus

On June 17, 2024, the Department of Justice (“DOJ”) announced the latest settlement under its Civil Cyber-Fraud Initiative (“CCFI”)... The settlement resulted in a total of $11,300,000 in payments from two consulting...more

Data, Deals, and Diplomacy: How the Bulk Data Executive Order Will Shape Future Contracts and Security Practices

For companies in the U.S. that hold certain personal data and U.S. Government-related data, rules stemming from recent Executive Order (“EO”) 14117 on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United...more

New Program Under Biden Executive Order to Prevent Access to American’s Sensitive Personal Data by Foreign Actors

The Biden Administration recently issued an Executive Order aimed at protecting American’s sensitive information and certain US Government data from threats posed by foreign actors. Of note is the Order’s focus on data...more

DoD IG Report Provides Insight Into Common Missteps When Protecting CUI

On November 30, 2023, the Inspector General of the Department of Defense (“DoD IG”) released a Special Report: Common Cybersecurity Weaknesses Related to the Protection of DoD Controlled Unclassified Information on Contractor...more

For Limited Use Only: Guidance on National Security Delay Determinations under the SEC Cyber Reporting Rule

On December 12, 2023, the Department of Justice (“DOJ”) issued guidance related to the process by which companies may request the United States Attorney General authorize delays of cyber incident disclosures, pursuant to a...more

Update – DOJ Declines to Intervene in Penn State Cyber-Related FCA Case

A few weeks ago, we discussed two recent cyber-related False Claims Act (FCA) cases. One of those cases is a qui tam lawsuit against Penn State and, as of the date of our article, we were waiting to see if DOJ would opt to...more

Recent Cyber-Related False Claims Act Activity Signals Contractors and Universities Should Examine Their Cybersecurity Practices...

In recent weeks, there has been an uptick in news of cyber-related False Claims Act (“FCA”) activity. For example, on September 1, 2023, the court unsealed a qui tam lawsuit against Penn State University relating to...more

ChatUSG: What Companies Doing Business with the Government Need to Know About Artificial Intelligence

While you were asking ChatGPT to create a 3-course menu for the upcoming book club you’re hosting or to explain the Rule Against Perpetuities, several federal government agencies announced initiatives related to the use of...more

Biden Administration Releases Highly Anticipated National Cybersecurity Strategy

On March 2, 2023, the Biden Administration released its National Cybersecurity Strategy. The Strategy represents the latest push by the Administration to focus on cybersecurity concerns, following the release of Executive...more

Well, That Didn’t Take Long – DOJ Announces its First Settlement of a Civil Cyber-Fraud Case

On March 8, 2022, just five months after the creation of the Department of Justice’s (“DOJ”) new Civil Cyber-Fraud Initiative (previously discussed...), the DOJ announced its first settlement of a cyber-related fraud case...more

2021 Cybersecurity Recap for Government Contractors (and What to Expect in 2022) – Part 2 of 4: Department of Justice (DOJ)...

As 2021 draws to a close, we wanted to share a recap of some of the most important cybersecurity developments we covered this past year along with some suggestions on what companies (particularly those that do business with...more

DOJ Announces Civil Cyber-Fraud Initiative To Enforce Contractor Cybersecurity Compliance

On Wednesday, October 6, 2021, the Department of Justice (“DOJ”) announced a new Civil Cyber-Fraud Initiative to enforce cybersecurity standards and reporting requirements. The Initiative will use DOJ’s civil enforcement...more

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