To kick off the New Year (and as is now tradition, since we put out a similar Recap & Forecast last year), Sheppard Mullin’s Governmental Practice Cybersecurity & Data Protection Team has prepared a cybersecurity-focused 2024 Recap (highlighting major updates and including links to the resources we put out over the past year) and a 2025 Forecast (previewing what we expect to see in 2025). This Recap & Forecast covers the following six high-interest topic areas relating to cybersecurity and data protection:Continue Reading Governmental Practice Cybersecurity and Data Protection: 2024 Recap & 2025 Forecast Alert
Sidney Howe*
*Sidney Howe is a Cybersecurity Fellow in the Governmental Practice in the firm's Washington, D.C. office.
DoD Issues Proposed Rule for New Disclosures on Foreign Review of Computer Code
On November 15, 2024, the Department of Defense (“DoD”) issued a long-awaited Proposed Rule to implement Section 1655 of the National Defense Authorization Act for Fiscal Year 2019.Continue Reading DoD Issues Proposed Rule for New Disclosures on Foreign Review of Computer Code
Update – Penn State to Pay Up for Cyber-Related FCA Case
On October 22, 2024, the Department of Justice (“DOJ”) announced that Pennsylvania State University (“Penn State”) has agreed to pay $1,250,000 to settle a False Claims Act (“FCA”) case brought against the University approximately two years ago. The whistleblower in the case, former chief information officer of the Penn State Applied Research Laboratory, alleged that Penn State failed to comply with cybersecurity requirements in fifteen contracts and/or subcontracts with the Department of Defense (“DoD”) and National Aeronautics and Space Administration (“NASA”) between 2018 and 2023.Continue Reading Update – Penn State to Pay Up for Cyber-Related FCA Case
Countdown to Compliance: DoD Finalizes the CMMC Program Rule
On October 15, 2024, the Department of Defense (“DoD”) published the final version of its Cybersecurity Maturity Model Certification (“CMMC”) rule in Title 32 of the Code of Federal Regulations (the “Final Rule”). (Reminder, there are two CMMC rulemakings going on in parallel. This Final Rule updates DoD national security regulations while the other rulemaking effort under Title 48 will update the Defense Federal Acquisition Regulation (“DFARS”) and trigger requirements for DoD contractors.)Continue Reading Countdown to Compliance: DoD Finalizes the CMMC Program Rule