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Privacy Perils Loom For DHS Contractors

Client Alert | less than 1 min read | 06.07.05

The Department of Homeland Security's (DHS) mission demands prodigious information access and sharing, yet privacy concerns -- stoked at federal, state, and international levels -- have ignited a host of challenges to homeland security initiatives, sometimes delaying or even stopping anti-terrorism programs. In "Privacy vs. Information Sharing: The Gathering Storm Over Homeland Security and How Contractors Can Reduce Their Risks" published in the Federal Contracts Report on May 31, 2005 (http://www.crowell.com/pdf/FederalContracts_Privacy.pdf), Crowell & Moring partner David Bodenheimer discusses these privacy perils, their impact on homeland security initiatives, and some ways to reduce these privacy risks.

Insights

Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....