NISPOM Revised to Incorporate DSS and GCA Requirements
Client Alert | 1 min read | 08.08.18
On August 1, 2018, DoD published the National Industrial Security Program: Industrial Security Procedures for Government Activities (“Volume 2”), which finally replaces the 1985 Industrial Security Regulation much as the original National Industrial Security Program Operating Manual (NISPOM) had replaced the Industrial Security Manual applicable to contractors. Volume 2 prescribes security practices applicable to U.S. government activities and includes an extended discussion of facility security clearances (FCLs), including examples of documentation that sponsoring agencies can use to justify an FCL, an exception for continued FCL processing even if it cannot be completed in time to qualify the company for participation in a procurement action, and uniform criteria for identification of key management personnel for various business structures. Volume 2 also establishes detailed procedures for DSS oversight of contractor investigations of compromised information, DSS processing of limited access authorization, and DSS requirements for international security programs including foreign government and contractor access to U.S. classified information.
Contacts
Partner
She/Her/Hers
Insights
Client Alert | 8 min read | 09.09.25
On September 5, 2025, the Federal Trade Commission (“FTC”) withdrew its appeals of decisions issued by Texas and Florida federal district courts, which enjoined the FTC from enforcing a nationwide rule banning almost all noncompete employment agreements. Companies, however, should not read this decision to mean that their noncompete agreements will no longer be subjected to antitrust scrutiny by federal enforcers. In a statement joined by Commissioner Melissa Holyoak, Chairman Andrew Ferguson stressed that the FTC “will continue to enforce the antitrust laws aggressively against noncompete agreements” and warned that “firms in industries plagued by thickets of noncompete agreements will receive [in the coming days] warning letters from me, urging them to consider abandoning those agreements as the Commission prepares investigations and enforcement actions.”
Client Alert | 7 min read | 09.08.25
California’s Climate Disclosure Laws Continue to Roll Forward
Client Alert | 3 min read | 09.08.25
RADV Audits: Implications and Recommendations for Medicare Advantage Organizations
Client Alert | 3 min read | 09.04.25
