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Setting the Floor: New FAR Rule Defines Minimum Contractor Information System Safeguarding

Client Alert | 1 min read | 05.17.16

Shifting approaches, on May 16, 2016, the FAR Council concluded a long-running rulemaking with a final rule and a new clause, FAR 52.204-21, that will establish minimum security controls pulled from NIST Special Publication 800-171 over contractor information systems that may process, store, or transmit “Federal contract information,” defined as information provided to or generated under any government contract (except for COTS) that is not intended for public release. Future rules will address more specific controls applicable to more sensitive information such as Controlled Unclassified Information (CUI), but this rule focuses instead on establishing those baseline controls the FAR Council believes any prudent business would implement in relation to its information systems and does not replace more stringent security requirements like those in the DFARS Safeguarding Rule.

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Client Alert | 10 min read | 07.03.25

Focus on Transnational Cartels Continues: FinCEN Targets Three Mexican Financial Institutions with Special Measures, Restricting Their Access to U.S. Financial System

The Orders represent FinCEN’s first actions using new special measures authority under the Fentanyl Sanctions Act and FEND Off Fentanyl Act of 2024 (codified at 21 U.S.C. § 2313a) (the “Fentanyl Act”) and continue the Trump Administration’s broader efforts against transnational cartels and narcotics trafficking....