Cybersecurity Insights: Updates on CMMC Implementation and CUI Identification
Marti Arvin and Anthony Buenger on the CMMC Framework
In our August 1 post, we discussed how companies that acquire government contractors can inherit the False Claims Act (“FCA”) exposure based on their targets’ cybersecurity violations. Now, the Department of Justice (“DOJ”)...more
On July 31, 2025, the United States Department of Justice (DOJ) announced a pair of settlements with companies accused of having violated the False Claims Act (FCA) by falsely representing their compliance with certain...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 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
The Department of Homeland Security (DHS) recently released a final rule (Final Rule), effective July 21, 2023, updating the Homeland Security Acquisition Regulation (HSAR) to include cybersecurity provisions aimed at...more
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
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
As of November 30, 2020, certain U.S. Department of Defense (“DoD”) prime contractors and subcontractors will need to complete a cybersecurity self-assessment prior to receiving new DoD contracts and prior to the exercise of...more
A major shift in cybersecurity requirements for Department of Defense (DoD) contractors is about to come into effect—earlier this month the DoD released for public comment the long-anticipated Version 0.4 of the draft...more
On October 4, 2016, a final rule implementing statutory requirements for Department of Defense (DoD) contractors and subcontractors to report cyber incidents that result in an actual or potentially adverse effect on a covered...more
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