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Upping the Cyber Oversight Ante: DoD Deploys DCMA to Audit Contractor Supply Chain Compliance

Client Alert | 1 min read | 01.28.19

The Defense Department has unveiled plans to audit contractors’ supply chain compliance with the DFARS Safeguarding Clause 252.204-7012. Under the auspices of 252.244-7001, Contractor Purchasing System Administration, Under Secretary of Defense Ellen Lord has directed the Defense Contract Management Agency (DCMA) to review contractors’ purchasing systems with the intent of verifying compliance with the Safeguarding Clause’s flowdown requirements. Notably though, the scope of DCMA’s review appears broader than the Clause’s textual requirements. Specifically, DCMA will review contractor procedures to:

  • Ensure that Tier 1 Level Suppliers are receiving properly marked Covered Defense Information (CDI), or instructions on how to do so; and
  • “Assess compliance” of Tier 1 Level Suppliers with both the Clause and NIST SP 800-171.

The memorandum is the latest signal from the DoD that it views the Safeguarding Clause’s flowdown requirements as more than a check-the-box exercise and an increasingly important piece of its overall cybersecurity.

Insights

Client Alert | 3 min read | 06.26.25

FDA Targets Gene Editing Clinical Trials in China and other “Hostile Countries”

In a somewhat ambiguous press release on Wednesday, June 18, 2025, the Food and Drug Administration (FDA) announced a halt and “immediate review” of new clinical trials where American patients’ cells are sent to China or other “hostile countries” for genetic engineering with the expectation that the cells will be infused back into U.S. patients.[1] A subsequent podcast published by the agency also said that therapies that involved cells that were sent to China for genetic engineering and intended for subsequent infusion into U.S. patients would not be approved going forward. The announcement said that there is “mounting evidence” that some clinical researchers failed to obtain informed consent from trial participants about the international transfer and manipulation of biological material....