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DOD Proposed New Cybersecurity Rules

Client Alert | 1 min read | 03.08.10

On March 3, DoD issued a notice of, and requested comments on, proposed rules levying information security requirements for safeguarding unclassified "DoD information" and reporting security breaches when contractors and subcontractors may have such information "resident on or transiting" their information systems. The proposed rule not only mandates that contractors "shall provide adequate security to safeguard DoD information," but also (1) requires flowdown to subcontractors; (2) establishes extreme standards in some areas (e.g., "best level of security and privacy available"); (3) incorporates National Institute of Standards and Technology (NIST) standards in some areas, but not others; and (4) acknowledges that the contractor will still need to comply with all other applicable security standards, such as "CPI, PII, For Official Use Only, Privacy Act, ITAR, EAR, and HIPAA."

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Client Alert | 4 min read | 02.20.26

SCOTUS Holds IEEPA Tariffs Unlawful

On February 20, 2026, the Supreme Court issued a pivotal ruling in Trump v. V.O.S. Selections, negating the President’s ability to impose tariffs under IEEPA. The case stemmed from President Trump’s invocation of IEEPA to levy tariffs on imports from Canada, Mexico, China, and other countries, citing national emergencies. Challengers argued—and the Court agreed—that IEEPA does not delegate tariff authority to the President. The power to tariff is vested in Congress by the Constitution and cannot be delegated to the President absent express authority from Congress....