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Forget The Showers. April Brings Flurry of New Cyber Guidance.

Client Alert | 1 min read | 05.01.18

April has marked a busy month for those following the DoD’s approach to contractor cybersecurity. Earlier in the month, the DoD published a much-anticipated revision to their Frequently Asked Questions regarding DFARS 252.204-7012 and other cybersecurity requirements, reflecting feedback on various questions posed by industry over the past year and including new information regarding:

  • COTS and commercial items
  • Scope of covered defense information
  • Conflicts with foreign laws
  • Subcontractor flowdowns
  • System security plans (SSPs) and plans of action & milestones (POAMs)
  • Requirements for FIPS-validation, multifactor authentication, and marking
  • Cybersecurity requirements beyond NIST SP 800-171
  • Cloud service providers
  • Examples of cyber incidents
  • Guidance for small businesses
  • DCMA oversight

Then just weeks later, the DoD issued proposed guidance for evaluating contractor cybersecurity, including implementation of NIST SP 800-171. Importantly, contractors may comment on the draft guidance through May 31 – and would be well-served to familiarize themselves with the new FAQs before doing so.


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Client Alert | 4 min read | 03.25.26

NAIC Intensifies AI Regulatory Focus: What Health Insurance Payors Need to Know

The National Association of Insurance Commissioners (NAIC) is intensifying its oversight of how insurers use AI — and the pace of regulatory activity shows no signs of slowing. Over the past several months, the NAIC has published a formal Issue Brief staking out its position on federal AI legislation, launched a multistate AI Evaluation Tool pilot aimed at examining insurers’ AI governance programs, and continued to expand adoption of its AI Model Bulletin across state lines. These developments continue a trend towards enhancing regulation; the NAIC adopted AI Principles in 2020 and a Model Bulletin in 2023 clarifying that existing insurance laws apply to AI systems and establishing expectations for governance, documentation, testing, and third-party oversight. That Model Bulletin has now been adopted in approximately 24 states....

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