The Wait Is Over: Final DFARS Safeguarding Rule Published Today
Client Alert | 1 min read | 10.21.16
Almost three years after its first iteration was published, DoD has finalized the DFARS Safeguarding Rule and corresponding DFARS clauses regarding the protection of “covered defense information” provided to or generated by defense contractors. Effective today, the Final Rule by and large reflects the same requirements of its interim versions and FAQs but with a few notable exceptions, including the definition of “covered defense information” now encompasses all forms of “controlled unclassified information” and thus aligns with the National Archive’s recent final rule, external cloud services housing covered defense information must comply with certain FedRAMP security requirements, and subcontractors must notify their primes when requesting variances from the security controls of NIST Special Publication 800-171.
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Client Alert | 2 min read | 07.01.25
DoD Establishes New DOGE Approval Process for ITC&MS and A&AS Contracts
On June 23, 2025, the DoD issued a memorandum, “Implementation of Department of Government Efficiency Cost Efficiency Initiative,” to establish a new DOGE approval process for unclassified IT consulting and management services (ITC&MS) contracts or task orders (TOs), and advisory and assistance services (A&AS) contracts or TOs. The memorandum establishes a formal approval process, which directs DOGE to review and provide input for certain contract requirement packages included in Defense Secretary Pete Hegseth’s May 27, 2025 directive, “Implementation of Executive Order 14222 – Department of Government Efficiency Cost Efficiency Initiative” (“Contract Guidance”).
Client Alert | 10 min read | 07.01.25
Ninth Circuit Decision Underscores Increasing False Claims Act Risks to U.S. Importers
Client Alert | 8 min read | 06.30.25
Client Alert | 3 min read | 06.30.25
