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The FAR Regulators Enter the Cyber Fray

Client Alert | 1 min read | 08.28.12

On the heels of the latest demise of cyber legislation, the FAR Council has proposed new cybersecurity regulations for safeguarding government information ("other than public information") residing on or transiting through contractors' systems. While lacking some of the detail (such as certain NIST standards) contained in a predecessor proposal by DOD, the proposed FAR rule establishes broad requirements for basic cybersecurity safeguards for "all Federal contractors and appropriate subcontractors," including mandates for  (1) "the best level of security and privacy available, given facilities, conditions, and environment"; (2) "at least one physical and one electronic barrier" for such information; (3) "sanitization" prior to disposal of information and electronic media; and (4) "intrusion protection," such as "updated malware protection services."

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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....