On June 6, 2025, the Trump Administration released a new Executive Order (“EO”) on cybersecurity, Sustaining Select Efforts to Strengthen the Nation’s Cybersecurity and Amending Executive Order 13694 and Executive Order...more
6/10/2025
/ Biden Administration ,
Corporate Counsel ,
Cybersecurity ,
Executive Orders ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
NIST ,
Regulatory Requirements ,
Software ,
Supply Chain ,
Trump Administration
Last month, the federal government announced a major overhaul of the Federal Risk and Authorization Management Program (“FedRAMP”) called “FedRAMP 20x”. FedRAMP 20x is moving forward fast – with new authorizations, community...more
On March 24, 2025, the Federal Risk and Authorization Management Program (“FedRAMP”) announced a major overhaul of the program, which is being called “FedRAMP 20x.” The FedRAMP 20x announcement stated there are no immediate...more
To kick off the New Year (and as is now tradition, since we put out a similar Recap & Forecast last year), Sheppard Mullin’s Governmental Practice Cybersecurity & Data Protection Team has prepared a cybersecurity-focused 2024...more
1/8/2025
/ Artificial Intelligence ,
Compliance ,
Critical Infrastructure Sectors ,
Cybersecurity ,
Cybersecurity Maturity Model Certification (CMMC) ,
Data Protection ,
Department of Defense (DOD) ,
DFARS ,
Enforcement ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
FedRAMP ,
National Security ,
Reporting Requirements ,
Risk Management ,
Software
On November 15, 2024, the Department of Defense (“DoD”) issued a long-awaited Proposed Rule to implement Section 1655 of the National Defense Authorization Act for Fiscal Year 2019.
Section 1655 prohibits DoD from...more
12/16/2024
/ Comment Period ,
Computer Programs ,
Cybersecurity ,
Department of Defense (DOD) ,
DFARS ,
Disclosure Requirements ,
NDAA ,
Proposed Rules ,
Regulatory Agenda ,
Software ,
Source Code ,
Supply Chain
On March 11, 2024, the Cybersecurity and Infrastructure Security Agency (“CISA”) and the Office of Management and Budget (“OMB”) released the highly-anticipated Secure Software Development Attestation Form (also known as the...more
To kick off the New Year, Sheppard Mullin’s Governmental Practice Cybersecurity & Data Protection Team has prepared a cybersecurity-focused 2023 Recap (including links to all of the resources the team has put out over the...more
To kick off the New Year, Sheppard Mullin’s Governmental Practice Cybersecurity & Data Protection Team has prepared a cybersecurity-focused 2023 Recap (including links to all of the resources the team has put out over the...more
2/9/2024
/ Cloud Computing ,
Cybersecurity ,
Cybersecurity Maturity Model Certification (CMMC) ,
Data Protection ,
Data Rights ,
Data Security ,
Department of Defense (DOD) ,
Enforcement Actions ,
Federal Contractors ,
FedRAMP ,
Fraud ,
Privacy Laws ,
Software
The Cybersecurity and Infrastructure Security Agency (“CISA”) recently revised its Secure Software Development Attestation Common Form (after receiving over 110 comments on the initial draft), and is seeking additional...more
On October 3, 2023, the FAR Council released two long-awaited proposed rules for federal contractor cybersecurity stemming from the Biden Administration’s Cybersecurity Executive Order from May 2021 (Executive Order 14028)....more
10/5/2023
/ Biden Administration ,
Comment Period ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Protection ,
Data Security ,
Executive Orders ,
False Claims Act (FCA) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
OMB ,
Popular ,
Proposed Rules ,
Public Comment ,
Regulatory Agenda ,
Software ,
Technology Sector
On June 9, 2023, OMB released additional guidance on the implementation of OMB Memorandum M-22-18, Enhancing the Security of the Software Supply Chain through Secure Software Development Practice, which requires that federal...more
The Cybersecurity and Infrastructure Security Agency (CISA) is seeking public comment on the secure software development common self-attestation form to be completed by software producers that sell software to the federal...more
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
Yesterday we continued our series... with the Office of Management and Budget’s September 2022 memorandum requiring federal agencies to only use software from software producers that attest compliance with secure software...more
1/24/2023
/ Critical Infrastructure Sectors ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Federal Acquisition Regulations (FAR) ,
Government Agencies ,
NIST ,
OMB ,
Popular ,
Software ,
Supply Chain
Per Executive Order 14028, Improving the Nation’s Cybersecurity, the Office of Management and Budget (OMB) issued a memorandum on September 14, 2022 requiring federal agencies to only use software from software producers that...more
9/29/2022
/ Contract Solicitation ,
Cybersecurity ,
Executive Orders ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Information Technology ,
NIST ,
OMB ,
Software ,
Supply Chain ,
Third-Party
NIST recently released several key deliverables relating to cybersecurity. These focus on secure software development and new consumer labeling programs as contemplated by President Biden’s Executive Order 14028, which seeks...more
The National Institute of Standards and Technology (“NIST”) is seeking comments on its second draft of NIST SP 800-161 Rev. 1, “Cyber Supply Chain Risk Management Practices for Systems and Organizations,” published on October...more
11/11/2021
/ Biden Administration ,
Cybersecurity ,
Data Security ,
Executive Orders ,
Federal Contractors ,
Government Agencies ,
Information Technology ,
NIST ,
Risk Management ,
Software ,
Supply Chain ,
Technology
As called for in the May 12, 2021 Cybersecurity Executive Order (“EO”) released by the Biden Administration (discussed here), NIST met its deadline to release a definition of “critical software” within 45 days of the date of...more
The National Institute of Standards and Technology (“NIST”) is seeking comments on its draft NIST SP 800-161 Rev. 1, “Cyber Supply Chain Risk Management Practices for Systems and Organizations,” published on April 29, 2021....more
5/27/2021
/ Biden Administration ,
Critical Infrastructure Sectors ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Executive Orders ,
Information Technology ,
NIST ,
Popular ,
Software ,
Supply Chain ,
Technology
On May 12, 2021, the Biden Administration issued its much anticipated “Executive Order on Improving the Nation’s Cybersecurity.” Below are provisions we believe will be of most interest to contractors, as well as any company...more
5/19/2021
/ Biden Administration ,
Critical Infrastructure Sectors ,
Cybersecurity ,
Department of Homeland Security (DHS) ,
DFARS ,
Executive Orders ,
Federal Acquisition Regulations (FAR) ,
Information Technology ,
Internet of Things ,
NIST ,
OMB ,
Popular ,
Software ,
Supply Chain ,
Technology