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One step at a time for U.S. DoD DIB contractors. As the DoD publishes a memo reminding contracting officers to enforce penalties for contractors that fail to comply with DFARS clause 252.204-7012 Ted Dziekanowski. That alongside DFARS 252.204-7019 and DFARS 252.204-7020 is the foundation of the DoD CMMC program. Expected to apply to DoD contracts by the mid 2023.
Following the D041 ruling defence contractors are required to submitted their compliance to NIST SP 800-171 under the DoDs Assessment Methodology (DAM) and NIST SP800-171A, to SPRS. Contractors are expected to ensure that subcontractors have implemented NIST SP 800-171 before they issue a subcontract. The DoD also implemented DoDi 5000.90 in 2020 requiring procurement officers to address risk management in procurement. A requirement that aligns procurement risk management to the DoDs fiduciary requirement to implement FISMA.
It is important that global DIB contracts and subcontractors pay attention to their contracts, and their implementation of NIST SP 800-171. The following months will be closely watched as the DoD and possibly the DoJ under its Civil Cyber Fraud Initiative, increase their focus on contractual compliance and maybe the False Claims Act.
The international DIB is in scope, as NIST cybersecurity compliance is a contractual requirement. For those expecting nothing to happen, other cybersecurity legislation is flowing from the U.S. and EU that will impact public firms that includes DIB contractors.
#departmentofdefense #departmentofjustice #DFARS #CMMC #falseclaimsact
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