Heads up, federal contractors: DoD has announced “CMMC 2.0” with significant changes to program structure and requirements, including expanded self-attestation that heightens False Claims Act exposure.
DOD REVAMPS CYBERSECURITY MATURITY MODEL CERTIFICATION (“CMMC”) ROBUST ENFORCEMENT LIKELY USING THE FALSE CLAIMS ACT CMMC Program Overview The CMMC program enhances cyber protection standards for companies in the Defense Industrial Base. It is designed to protect sensitive unclassified information that is shared by the Department of Defense (“DoD”) with its contractors and subcontractors....
Read MoreOffice of Foreign Assets Control (“OFAC”) Sanctions Compliance Guidance for the Virtual Currency Industry
In mid-October 2021, OFAC issued sanctions compliance guidance (the “OFAC Guidance”) for the virtual currency industry, including tech companies, exchanges, administrators, miners, crypto wallet providers, and even users. OFAC issued the guidance to help the virtual currency industry mitigate the risks of transacting cryptocurrencies with a sanctioned country, entity, or individual. OFAC is the...
Read MoreLawmakers and Regulators Recognize Crypto and Blockchain Present Unique Problems for Traditional Enforcement Mechanisms
Congressional Democrats Seek Increased Oversight Into Crypto Matters Following Ransomware Attacks A group of Democratic senators and congressmen are calling on the Department of Justice, the State Department, the Department of the Treasury, and Homeland Security to beef up efforts to protect against the recent wave of ransomware attacks. The group, comprised of senators...
Read MoreDOJ Announces Creation of Cryptocurrency Enforcement Team
On October 6, 2021, the Department of Justice (“DOJ”) announced the creation of the National Cryptocurrency Enforcement Team (“NCET”) to investigate and prosecute criminal misuses of cryptocurrency. NCET’s particular focus will be on crimes committed by virtual currency exchanges, mixing and tumbling services, and money laundering infrastructure actors, to include the tracing and recovery...
Read MoreCivil Cyber-Fraud Initiative to Hold Government Contractors Responsible for Cybersecurity
On October 6, 2021, the Department of Justice (DoJ) announced the Civil Cyber-Fraud Initiative (the “Initiative”) to combat cyber threats, specifically to sensitive information and critical systems of the United States Government (USG). In launching the Initiative, Deputy Attorney General Lisa O. Monaco made clear that a primary focus of the Initiative is to...
Read MoreFAR Council, CAAC, and DoD Release COVID-19 Guidance
The FAR Council, the Department of Defense (“DoD”), and the Civilian Agency Acquisition Council (“CAAC”) have released guidance for federal government contractors on COVID-19 safeguards required by President Biden’s September 9, 2021, Executive Order 14042 (the “Order”) and the Safer Federal Workforce Task Force’s September 24, 2021, Guidance, COVID-19 Workplace Safety: Guidance for Federal...
Read More