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NASA Proposes Cyber Lock-Down On Contractors

Client Alert | 1 min read | 08.11.06

Following an outbreak of highly publicized information security breaches ripping through the federal government and prompting new OMB "get-tough" directives, NASA is proposing a new crackdown on contractors that "(1) have physical or electronic access to NASA's computer systems, networks, or IT infrastructure; or (2) use information systems to generate, store, or exchange data with NASA or on behalf of NASA." 71 Fed. Reg. 43408 (Aug. 1, 2006). Under these proposed rules, NASA contractors face a variety of new and expanded cyber requirements that generally add cost and risk to contract performance, including: (1) submitting IT "Security Plans" compliant with National Institute of Standards and Technology (NIST) SP 800-18; (2) performing "Risk Assessments" consistent with Federal Information Processing Standards Publication (FIPS) 199; (3) preparing contingency plans per NIST SP 800-34; (4) conducting annual IT security training; and (5) assuring that contractor personnel with access to NASA IT systems have National Agency Check with Inquiries (NACI) screening.

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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....