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DoD Previews New Third-Party Cyber Certification Requirements

Client Alert | 1 min read | 06.17.19

The Department of Defense is moving closer to a third-party certification to ensure compliance with its standard cybersecurity requirements – what is being called the “Cybersecurity Maturity Model Certification” (CMMC). While still in the early stages of development, the CMMC would likely require all contractors subject to DFARS 252.204-7012 to obtain a certification issued by an independent third party stating that the contractor has sufficiently implemented its required cybersecurity controls. Holding this certification would be a “go/no-go” condition to compete for relevant DoD work. Although NIST SP 800-171 is the default cybersecurity standard currently required under -7012, DoD is also exploring the creation of a new standard that would govern the certification. DoD is projecting that the CMMC will start appearing in solicitations as early as Fall 2020, but much work remains to be done – including potential revisions to -7012 – and will no doubt be informed by extensive industry engagement. 

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Client Alert | 3 min read | 02.13.26

Recent Developments in U.S. Merger Enforcement: HSR Rule Overturned and Leadership Changes at DOJ Antitrust Division

In October 2024, the FTC adopted a final rule that substantially modified the HSR form, requiring new categories of information and documents. The final rule was the most significant overhaul of the HSR premerger notification requirements in decades. The new requirements imposed additional time and expense on merging parties, with the FTC estimating that the new form would likely take triple the amount of time to complete than the previous form. Numerous groups, including the U.S. Chamber of Commerce, sued to challenge the rule....