1. Home
  2. |Insights
  3. |DCMA’s Cybersecurity Oversight Takes Shape: Revised CPSR Guidebook Outlines DFARS Safeguarding Clause Audit Standards

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.

Insights

Client Alert | 5 min read | 08.04.25

Labor Market Reforms in Belgium—Summer Agreement and New Program Act: Major Transformations on the Horizon

The Belgian federal government has taken two decisive steps in the implementation of its reform agenda. First, the adoption of the so-called Summer Agreement on July 21 outlines an ambitious fiscal and social overhaul. Second, the long-awaited Program Act was approved during the night of July 17 to July 18 and introduces a historic limitation on unemployment benefits. Together, these measures significantly redefine the Belgian labor market ecosystem. ...