In my view the DoD is laying the ground work for the CMMC program. Reaffirming DFARS clause 252.204-7012, the implementation of NIST SP 800-171 at a minimum, and the penalties for non compliance. Penalties that Include withholding progress payments; foregoing…
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…
Thank you for posting Rachel V. Rose, JD, MBA a timely post on the FCA, it’s recent application and the judicial process as it relates to the Whistleblower. I wonder if the process applies to Whistleblowers who are resident outside…
The False Claims Act (FCA) and its application to the DIB has been front and center with the Aerojet Rocketdyne and CHS FCA cases. The U.S. Federal drive for cybersecurity legislation, regulatory enforcement of the DoD DFARS/ CMMC program, the…
Thank you Ted Dziekanowski. One could argue that its not 1 weeks interest on the fine purported in the court papers of $19Billion. But it along with the CHS False Claims action reported in March, starts to build a pool…
This week sees the Aerojet Rocketdyne case go back to court on the 26th April. In what is seen as a test case for the US Department of Justice (DoJ), and its use of the False Claims Act (FCA) against…
With our dependency on digital and tech, chip manufacturing has to be the most important national capability. Is Europe’s lack of chip manufacturing capacity going to create a significant security risk in the not to distant future? With the US…
Could Gartner’s 2020 prediction that the impact of cyber-attacks on physical infrastructure through OT, with the loss of human life start be correct? As cyber legislation and corporate actions gains pace for example shareholder suits for failing to protect shareholder…
If you are going to read anything this week, read this. With amendments proposed to NDAA 2022 for FISMA 2021, FISMA is on the legislative and regulatory radar. There have been amendments made to FISMA 2014 by OMB, under Executive…
The US Government Accountability Office (GAO) has issued its assessment of the CMMC program, required under the 2021 NDAA. It’s a synopsis of the history and current state of the CMMC program, highlighting concerns raised by industry and the challenges…
