On the 29th of September 2020 the US Department of Defence released its Interim Final Ruling (ruling) for DFARS Case D041, effective 30th November

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On the 29th of September 2020 the US Department of Defence released its Interim Final Ruling (ruling) for DFARS Case D041, effective 30th November 2020. Improving the protection of Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) across the DoDs Defence Industry Base (DIB).

The ruling puts in place the mechanisms for the oversight, assurance, and certification of cyber security to be applied by the DIB. Defined by NIST SP 800 – 171 and CMMC practices. Whilst there is no specific focus on the International DIB, the requirements to adhere to DFRAS 252.204 – 7012 and FAR regulations, including the additional oversight, assurance and the contractual obligations will have a significant impact.

This paper examines the ruling and the associated Regulatory Impact Analysis (RIA). Highlighting the impact of the regulatory changes to contractors and subcontractors, and importantly the significant implications on the international Defence Industry Base (DIB).

Thanks to Matthew Titcombe, Jason Spezzano and Kris Carter for their valued contribution to this paper.

#cmmc #defenceindustry #supplychain #cybersecurity #cyberrisk #cyber #cio #cisa #cmmccoe #dfars #insurance #cyberinsurance #enisa #parava #asdeurope #cyberdefense

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