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DoD Issues Long-Awaited Interim Rule on Cyber Requirements and Cloud Services

Client Alert | 1 min read | 09.03.15

As discussed in our recent blog post, on August 26, DoD published an Interim Rule that would expand the already onerous requirements of the DFARS Safeguarding Clause by broadening its application to "covered defense information" and by requiring subcontractors to report cyber incidents directly to DoD. As discussed in a separate blog post, the Interim Rule also seeks to ensure uniformity in the DoD's IT acquisition and use of cloud computing services by adding T&C's, including that, unless otherwise authorized, cloud service providers must maintain all government data within the U.S., outlying areas, or DoD premises.


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Client Alert | 7 min read | 10.27.26

New Developments in DOJ Whistleblower Policies and HHS Disclosures: Key Takeaways for General Counsel, Chief Compliance Officers, and Boards

On October 20, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division announced a new whistleblower rewards initiative, the Fraud Whistleblower Incentive Program (WHIP). Assistant Attorney General Colin M. McDonald issued a directive earlier this month directing Division leadership to design and implement policies and programs that incentivize whistleblowers to bring forward credible information pertaining to fraud. The new WHIP incentive pays awards of $10,000 to $30,000 for qualifying tips at or around the time criminal charges are filed or unsealed, rather than years later at case resolution....