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An article well worth reading if you supply products and services to the Federal government. The enclosed article points to the use of the FCA as part of the wider toolkit being adopted by the President of the US to oversight and assure cyber security. Especially those contractors and subcontractors that supply the DoD and under DFARS clauses are obliged to implement cybersecurity practices.
The recent announcement by the DoJ of its new Civil Cyber-Fraud Initiative is clear. The DoJ intends to move ahead with legal oversight and assurance of contractors adoption of cybersecurity standards, if they receive federal funds. An action I am sure they will be willing to test in court. For contractors who provide products and services to Federal Government the use of the False Claims Act has some precedent. By the DoJs own admission it recovered $2.2Billion in 2020 from organisations that has resulted in fraud or miss-use.
Whilst it is opinion, it is well worth considering. DFARS 252.204-7012 has been a contractual requirement since 2017. Both the GAO and DoD inspector General have documented the low level of DFARS 7012 compliance by the Defence Industry Base (DIB) in implementing NIST SP 800-171.
Another pause for thought. Between 2017 and November 2020 DIB contractors self-attested their 171 compliance. From November 2020 contractors and their subcontractors had to input their 171 compliance scores into SPRS (DFARS 252.204-7019), pending a potential audit by DCMA (DFARS 252.204-7020). How will it be viewed if there is a significant difference between these assessment?
Ted Dziekanowski‚Â Brian McCarthy‚Â Jason Spezzano
#ransomware‚Â #fisma‚Â #ofac‚Â #theaugustagroup‚Â #theaugustaplan‚Â #cybersecurity‚Â #supplychainriskmanagement‚Â #cyberriskmanagement‚Â #compliance‚Â #regulatorycompliance‚Â #regulatoryoversight‚Â #esg‚Â #scrm‚Â #cscrm‚Â #fca‚Â #cybercompliance‚Â #cyberregulation‚Â #cybergovernance #falseclaimsact
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