It’s not really a Sunday read. For those companies in the US Global DIB the enclosed DCMA guidebook sets out the writings for the DoDs review of

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It’s not really a Sunday read. For those companies in the US Global DIB the enclosed DCMA guidebook sets out the writings for the DoDs review of supplier Contractor Purchasing Systems (CPSR).‚  Alongside the recent statement by Congressman Langevin, who cited the increased visibility and impact of ransomware attacks as a reason that ¢â‚¬Å“my colleagues see an urgency for new legislation now, in a way that wouldnt be possible a few years ago.

I see US Federal Agencies such as the Department of Justice, Treasury, Homeland Security and Commerce release several statements, guides and advisories on cyber security in the past 3 months. The DCMA guidebook is not so much a reverting read, as it is a document that sets out an audit framework by DCMA. Documenting the expectations for Defense contractor supplier purchasing systems to meet expectations for the management, oversight and assurance of supply chain procurement. Its scope impacts more than prime contractors in Tier 1, the guidebook articulates flow down requirements under clause 5.19.

A further observation is 5.18 (Internal Review/ Self Audit) is of interest. Outlining the ethical and code of conduct that contractors procurement systems must address and the oversight a contractor should make over its subcontractors. 5.18.4 should be noted and its mention of the FCA.

For those interested in the application of cybersecurity across the DIB, DFARS 252.204-7012 and the implementation of NIST SP 800-171. Section 5.24, Supply Chain Management Process should be digested. Safeguarding covered defence information as applied to contracts and subcontracts.

I would be interested in feedback on how far down the supply chain this goes?

Ted Dziekanowski‚ Brian McCarthy‚ Jason Spezzano

#ransomware‚ #fisma‚ #ofac‚ #theaugustagroup‚ #theaugustaplan‚ #cybersecurity‚ #supplychainriskmanagement‚ #cyberriskmanagement‚ #compliance‚ #regulatorycompliance‚ #regulatoryoversight‚ #esg‚ #scrm‚ #cscrm‚ #fca‚ #cybercompliance‚ #cyberregulation‚ #cybergovernance‚ #falseclaimsact‚ #afcea‚ #afceacyber‚ #aws‚ #dhs‚ #cisa‚ #appgai‚ #securitiesandexchangecommission

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