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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 Importantly, contractors may comment on the draft guidance through May 31 – and would be well-served to familiarize themselves with the new FAQs before doing so.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 | 3 min read | 04.14.26

DOJ’s False Claims Act Resolution Against IBM Signals Heightened Risk for Federal Contractors with DEI Programs

On Friday, April 10, 2026, the U.S. Department of Justice (DOJ) announced that International Business Machines Corporation (IBM) has agreed to pay just over $17 million to resolve allegations that it violated the False Claims Act (FCA) by failing to comply with federal anti-discrimination requirements incorporated into its federal contracts due to allegedly discriminatory diversity, equity, and inclusion (DEI) employment practices. This resolution marks the first FCA settlement secured by the DOJ under its Civil Rights Fraud Initiative, created in May 2025, and announced by then-Deputy Attorney General Todd Blanche as part of the administration’s coordinated efforts to target allegedly unlawful DEI practices. Per the agreement, the settlement is neither an admission of liability by IBM nor a concession by the United States that its claims are not well founded....