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DoD's Own Cyber Monday Deal: Releasing DFARS Cyber Enhancement Guidance

Client Alert | 1 min read | 11.27.18

Just in time for the holidays, the Defense Department published final guidance to the DoD acquisition community that details strategies to enhance existing cybersecurity requirements for Covered Defense Information (CDI) provided by the DFARS Safeguarding Clause 252.204-7012. The DoD’s guidance contains two documents that clarify how DoD will communicate their cybersecurity expectations to contractors, including where those expectations exceed what the DFARS Safeguarding Clause requires:

  • Guidance for Reviewing System Security Plans (SSPs) outlines how the DoD expects to evaluate contractor SSPs, including the preferred method of meeting each NIST security control and the anticipated consequences of not yet having implemented those controls.
  • Guidance for Assessing Compliance and Enhancing Protections provides objectives that requiring activities can tailor to assess contractors’ safeguarding of CDI, including how to incorporate compliance with NIST SP 800-171 and supply chain management as evaluation criteria in solicitations.

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Client Alert | 3 min read | 04.23.24

DOJ Promises NPAs to Certain Individuals Through New Voluntary Self-Disclosure Pilot Program

On April 15, 2024, the Acting Assistant Attorney General for the Criminal Division of the Department of Justice (“DOJ”) Nicole Argentieri announced a new Pilot Program on Voluntary Self-Disclosure for Individuals (“Pilot Program” or “Program”). The Pilot Program offers a clear path for voluntary self-disclosure by certain corporate executives and other individuals who are themselves involved in misconduct by corporations, in exchange for a Non-Prosecution Agreement (“NPA”). The Pilot Program specifically targets individuals who disclose to the Criminal Division at DOJ in Washington, D.C. information about certain corporate criminal conduct. By carving out a clear path to non-prosecution for those who qualify, DOJ has created another tool to uncover complex crimes that might not otherwise be reported to the Department. ...