Bryan Dewan
Areas of Focus
Overview
Bryan Dewan focuses on helping government contractors navigate a range of legal issues, including but not limited to cybersecurity and other Federal Acquisition Regulation compliance counseling, False Claims Act investigations, bid protests and other government contracts litigation, and mergers and acquisitions.
Career & Education
- Office of the Federal RegisterNational Archives and Records Administration Intern, 2023
- Office of the Federal Register
- The George Washington University Law School, J.D., with high honors, Order of the Coif, government procurement law, 2025
Public Contract Law Journal: editor-in-chief
- Colgate University, B.A., magna cum laude, political science (high honors) and computer science, 2017
- The George Washington University Law School, J.D., with high honors, Order of the Coif, government procurement law, 2025
- District of Columbia
Bryan's Insights
Client Alert | 4 min read | 09.21.26
In a First, District Court Dismisses FCA Cybersecurity Complaint for Lack of Materiality
In recent years, the U.S. federal government has taken significant interest in the cybersecurity compliance of its contractor base. In 2025 alone, the U.S. Department of Justice’s (DOJ) Civil Cyber-Fraud Initiative recovered more than $50 million across nine False Claims Act (FCA) cybersecurity fraud settlements, and it has secured almost 20 settlements since its launch in October 2021. Because most defendants facing FCA liability for alleged cybersecurity noncompliance enter into pre-litigation settlements, the last court decision in a cybersecurity FCA case was in 2022. However, earlier this month, on September 2, 2026, in United States ex rel. Pannek v. Archer Daniels Midland Co., No. 23-cv-15145, 2026 WL 2593317 (N.D. Ill. Sept. 2, 2026), Judge Sunil R. Harjani of the U.S. District Court for the Northern District of Illinois granted a motion to dismiss on materiality grounds and offered additional guidance on what a plaintiff must allege to adequately state an FCA cybersecurity claim.
Client Alert | 2 min read | 09.11.26
New ISOO Guidance Directs Federal Agencies to Provide More CUI Guidance to Contractors
Client Alert | 5 min read | 07.21.26
Insights
Department of War Immediately Suspends CMMC Phase II Requirements, Launches 60-Day Reform Review
|07.22.26
Crowell & Moring's Government Contracts Legal Forum
All Things Protest: Blue & Gold and Late is Late
|07.13.26
Crowell & Moring's Government Contracts Legal Forum
Time for a Change: FedRAMP Fundamentally Revamps Program With Consolidated Rules for 2026
|07.13.26
Crowell & Moring's Government Contracts Legal Forum
All Things Protest: Final Proposal Revisions and Federal Circuit Opinions
|06.01.26
Crowell & Moring's Government Contracts Legal Forum
FedRAMP Solicits Public Comment on Overhaul to Incident Communications Procedures
|04.22.26
Crowell & Moring’s Government Contracts Legal Forum
All Things Protest: Challenging Agency Evaluations of Proposals
|04.09.26
Crowell & Moring’s Government Contracts Legal Forum
All Things Protest: Corrective Action at the Court of Federal Claims
|03.03.26
Crowell & Moring’s Government Contracts Legal Forum
DHS Announces Virtual Town Halls on CIRCIA Final Rule
|02.20.26
Crowell & Moring’s Government Contracts Legal Forum
Fastest 5 Minutes: Cybersecurity, Resellers, IP
|02.03.26
Crowell & Moring’s Government Contracts Legal Forum
All Things Protest: NDAA, GAO’s Annual Bid Protest Report, and an OCI Sustain
|12.29.25
Crowell & Moring’s Government Contracts Legal Forum
Practices
Bryan's Insights
Client Alert | 4 min read | 09.21.26
In a First, District Court Dismisses FCA Cybersecurity Complaint for Lack of Materiality
In recent years, the U.S. federal government has taken significant interest in the cybersecurity compliance of its contractor base. In 2025 alone, the U.S. Department of Justice’s (DOJ) Civil Cyber-Fraud Initiative recovered more than $50 million across nine False Claims Act (FCA) cybersecurity fraud settlements, and it has secured almost 20 settlements since its launch in October 2021. Because most defendants facing FCA liability for alleged cybersecurity noncompliance enter into pre-litigation settlements, the last court decision in a cybersecurity FCA case was in 2022. However, earlier this month, on September 2, 2026, in United States ex rel. Pannek v. Archer Daniels Midland Co., No. 23-cv-15145, 2026 WL 2593317 (N.D. Ill. Sept. 2, 2026), Judge Sunil R. Harjani of the U.S. District Court for the Northern District of Illinois granted a motion to dismiss on materiality grounds and offered additional guidance on what a plaintiff must allege to adequately state an FCA cybersecurity claim.
Client Alert | 2 min read | 09.11.26
New ISOO Guidance Directs Federal Agencies to Provide More CUI Guidance to Contractors
Client Alert | 5 min read | 07.21.26




