DCMA’s Cybersecurity Oversight Takes Shape: Revised CPSR Guidebook Outlines DFARS Safeguarding Clause Audit Standards
Client Alert | 1 min read | 03.06.19
Following guidance issued by Under Secretary of Defense Lord, the Defense Contract Management Agency (DCMA) has revised its Contractor Purchasing System Review (CPSR) Guidebook to incorporate new standards DCMA auditors will use to assess contractor supply chain management under the DFARS Safeguarding Clause 252.204-7012. Notably, the new standards require contractors to “validate” that their subcontractors have information systems “that can receive and protect” Covered Defense Information (CDI) and to “determine” whether subcontractor systems are “acceptable.” Other new standards require contractors to demonstrate:
- How CDI is properly marked and securely transferred to subcontractors; and
- How subcontractor notifications regarding requests to vary from the NIST requirements and the submission of cyber incident reports are managed and documented.
The revisions also emphasize that 252.204-7012 is not an indiscriminate flowdown and applies only where the subcontractor will be utilized for operationally critical support or performing duties that involve CDI.
Contacts
Senior Counsel
She/Her/Hers
Partner
She/Her/Hers
Insights
Client Alert | 2 min read | 05.07.24
Department of Labor Finalizes Changes to Its Fiduciary Rules
On April 25, 2024, the Department of Labor (“DOL”) published a final rule (the “Final Rule”) regarding when providing investment advice results in the advisor becoming a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and the Internal Revenue Code of 1986, as amended (the “Code”). Under this guidance, an entity is a fiduciary if the provider of that advice to an ERISA plan or Individual Retirement Account:
Client Alert | 4 min read | 05.07.24
Client Alert | 3 min read | 05.07.24
Client Alert | 3 min read | 05.06.24
FTC Imposes $3.17 Million Civil Penalty for Violation of Prior Made in USA Order
