DCMA Revises Cyber Supply Chain Review: Updated Guidebook Modifies Audit Standards
Client Alert | 1 min read | 07.16.19
As anticipated, the Defense Contract Management Agency (DCMA) revised its Contractor Purchasing System Review (CPSR) Guidebook as of June 14, 2019, with the most significant updates to Appendix 24, Supply Chain Management Process, to further address supply chain compliance with DFARS 252.204-7012. As we previously noted, the CPSR Guidebook was revised earlier this year to address DoD guidance related to management and oversight of the supply chain in connection with DFARS 252.204-7012.
While much of the CPSR review criteria remain the same, noteworthy revisions include:
- Asking contractors to “show how they have determined” that their subcontractors have an adequate information system that can handle Covered Defense Information, versus the prior guidance to ask contractors to “validate” the adequacy of subcontractor systems.
- Broadening supply chain requirements by applying the Guidebook’s language to “subcontractors,” rather than just “first tier suppliers” as in the prior version.
- Clarifying that the CPSR review is focused only on the protection of “Covered Defense Information” and not “Controlled Unclassified Information” more broadly.
Contacts

Partner, Crowell Global Advisors Senior Director
- Washington, D.C.
- D | +1.202.624.2698
- Washington, D.C. (CGA)
- D | +1 202.624.2500
Insights
Client Alert | 9 min read | 01.06.26
Beyond the Checkout: Retail's 2026 Legal Minefield
2026 will be a significant year for retailers and e-commerce companies, with significant changes on the horizon that will affect the entire industry and ecosystem. Potential headwinds and developments in product safety, pricing, artificial intelligence, data privacy, website compliance, and environmental responsibility are expected. But amidst these changes, there are likely significant opportunities that retail and e-commerce businesses can capitalize on.
Client Alert | 6 min read | 01.06.26
California Privacy Agency Launches Data Broker Strike Force Amid Delete Act Crackdown
Client Alert | 4 min read | 01.05.26
Another Court Rules CASA Does Not Limit Universal Relief Available Under the APA
Client Alert | 7 min read | 01.05.26
Consideration of Artificial Intelligence in Arbitration Terms of Reference

