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Significant Revisions to Non-U.S. Content Disclosure and Financing Policies Proposed

Client Alert | less than 1 min read | 10.07.15

The Defense Security Cooperation Agency has informally circulated draft revisions to the August 2009 Guidelines for Foreign Military Financing of Direct Commercial Contracts, which would elaborate on, and in a number of instances significantly change, its policies with respect to the disclosure and financing of U.S., non-U.S., and now "host country" content. Please contact us if you would like to obtain a copy of the draft and/or participate in commenting on the proposal by the due date of November 16, 2015.


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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....

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