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Draft NIST Guidance Highlights Supply Chain Fundamentals as Key Practices in Cyber Supply Chain Risk Management

Client Alert | 1 min read | 02.21.20

Last week, the National Institute of Standards and Technology (NIST) published the draft NISTIR 8276 “Key Practices in Cyber Supply Chain Risk Management” providing Key Practices and related recommendations for monitoring, controlling, and understanding how to conduct cyber – supply chain risk management (C-SCRM). The Eight Key Practices are general and apply equally, in practice, to both traditional supply chain management and C-SCRM, including:

  • Integrating SCRM across the organization,
  • Understanding the organization’s supply chain, and
  • Assessing and monitoring SCRM throughout the supplier relationship. 

Specific guidance includes, among others:

  • Increasing Board involvement in C-SCRM;
  • Understanding the cyber relationship with suppliers, including whether they process critical data; and
  • Using third-party assessments to evaluate suppliers.

The guidance should serve to remind organizations of the need to know their supply chain well and to have a purposeful approach to its management. Organizations have an opportunity to comment on this draft guidance until March 4, 2020.

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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. ...