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Zero Hour: Contractors Face Increased FCA Exposure for Cybersecurity Noncompliance

Client Alert | less than 1 min read | 09.25.19

Along with the steady influx of cybersecurity requirements in federal procurement, contractors now face potential False Claims Act (FCA) liability in connection with cybersecurity noncompliance. Underscoring this risk was a recent FCA settlement, United States, ex rel. Glenn v. Cisco Sys. Inc., in which Cisco agreed to pay $8.6 million to settle allegations that it violated the FCA by selling products to the government that contained flawed software that was susceptible to data breaches. 

In an article published in Bloomberg Law, C&M attorneys discuss the intersection of the FCA and cybersecurity requirements as well as strategies to mitigate risk and defend against cybersecurity based FCA actions.

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Client Alert | 4 min read | 03.25.26

NAIC Intensifies AI Regulatory Focus: What Health Insurance Payors Need to Know

The National Association of Insurance Commissioners (NAIC) is intensifying its oversight of how insurers use AI — and the pace of regulatory activity shows no signs of slowing. Over the past several months, the NAIC has published a formal Issue Brief staking out its position on federal AI legislation, launched a multistate AI Evaluation Tool pilot aimed at examining insurers’ AI governance programs, and continued to expand adoption of its AI Model Bulletin across state lines. These developments continue a trend towards enhancing regulation; the NAIC adopted AI Principles in 2020 and a Model Bulletin in 2023 clarifying that existing insurance laws apply to AI systems and establishing expectations for governance, documentation, testing, and third-party oversight. That Model Bulletin has now been adopted in approximately 24 states....

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