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NISPOM Revised to Incorporate DSS and GCA Requirements

Client Alert | 1 min read | 08.08.18

On August 1, 2018, DoD published the National Industrial Security Program: Industrial Security Procedures for Government Activities (“Volume 2”), which finally replaces the 1985 Industrial Security Regulation much as the original National Industrial Security Program Operating Manual (NISPOM) had replaced the Industrial Security Manual applicable to contractors. Volume 2 prescribes security practices applicable to U.S. government activities and includes an extended discussion of facility security clearances (FCLs), including examples of documentation that sponsoring agencies can use to justify an FCL, an exception for continued FCL processing even if it cannot be completed in time to qualify the company for participation in a procurement action, and uniform criteria for identification of key management personnel for various business structures. Volume 2 also establishes detailed procedures for DSS oversight of contractor investigations of compromised information, DSS processing of limited access authorization, and DSS requirements for international security programs including foreign government and contractor access to U.S. classified information.

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Client Alert | 4 min read | 07.07.25

DOJ Data Security Program Update: Active Enforcement Begins This Week

The U.S. Department of Justice’s (DOJ) reprieve on civil enforcement of its Data Security Program (DSP), which imposes sweeping restrictions on bulk data transfers by U.S. entities to certain “countries of concern” and “covered persons,” is set to expire on July 8, 2025....