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Cybersecurity Maturity Model Matures: DoD Adds New Requirements to Draft Cybersecurity Certification

Client Alert | 1 min read | 09.10.19

The Defense Department has released Revision 0.4 of its Cybersecurity Maturity Model Certification (CMMC) that, starting next year, independent auditors are to use to certify contractor compliance with DoD cybersecurity requirements.  Revision 0.4 more than doubles the number of cybersecurity controls across the CMMC’s five maturity “Levels.”  But the DoD emphasizes that it will further down-select these controls and that mature contractor processes may counteract gaps in the final controls’ implementation.  In addition to NIST SP 800-171 (the default standard under DFARS 252.204-7012), Revision 0.4 now incorporates requirements from the NIST Cybersecurity Framework, ISO 27001, and CIS Critical Security Controls, as well as from “additional DIB inputs.”  Notably missing is NIST SP 800-171B, which remains under review.

The DoD is requesting feedback on Revision 0.4 through September 25, 2019, and plans on releasing Revision 0.6 for comment in November 2019.   The final CMMC is expected in January 2020. 

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Client Alert | 3 min read | 04.26.24

CFIUS Proposes Enhanced Enforcement and Mitigation Rules and Steeper Penalties for Non-Compliance

On April 11, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) announced proposed amendments to its enforcement and mitigation regulations, marking the first substantive update to CFIUS’s mitigation and enforcement provisions since the enactment of the Foreign Investment Risk Review Modernization Act of 2018.  The Committee issued a notice of proposed rulemaking ("NPRM”) that would modify the regulations that apply to certain investments and acquisitions, as well as real estate transactions, by foreign persons as follows:...