The Wait Is Over: Final DFARS Safeguarding Rule Published Today
Client Alert | 1 min read | 10.21.16
Almost three years after its first iteration was published, DoD has finalized the DFARS Safeguarding Rule and corresponding DFARS clauses regarding the protection of “covered defense information” provided to or generated by defense contractors. Effective today, the Final Rule by and large reflects the same requirements of its interim versions and FAQs but with a few notable exceptions, including the definition of “covered defense information” now encompasses all forms of “controlled unclassified information” and thus aligns with the National Archive’s recent final rule, external cloud services housing covered defense information must comply with certain FedRAMP security requirements, and subcontractors must notify their primes when requesting variances from the security controls of NIST Special Publication 800-171.
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Insights
Client Alert | 14 min read | 03.13.26
AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems
On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities. The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards. The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed. GSA requests comments by March 20, 2026.
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
Client Alert | 3 min read | 03.12.26
