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Upping the Cyber Oversight Ante: DoD Deploys DCMA to Audit Contractor Supply Chain Compliance

Client Alert | 1 min read | 01.28.19

The Defense Department has unveiled plans to audit contractors’ supply chain compliance with the DFARS Safeguarding Clause 252.204-7012. Under the auspices of 252.244-7001, Contractor Purchasing System Administration, Under Secretary of Defense Ellen Lord has directed the Defense Contract Management Agency (DCMA) to review contractors’ purchasing systems with the intent of verifying compliance with the Safeguarding Clause’s flowdown requirements. Notably though, the scope of DCMA’s review appears broader than the Clause’s textual requirements. Specifically, DCMA will review contractor procedures to:

  • Ensure that Tier 1 Level Suppliers are receiving properly marked Covered Defense Information (CDI), or instructions on how to do so; and
  • “Assess compliance” of Tier 1 Level Suppliers with both the Clause and NIST SP 800-171.

The memorandum is the latest signal from the DoD that it views the Safeguarding Clause’s flowdown requirements as more than a check-the-box exercise and an increasingly important piece of its overall cybersecurity.

Insights

Client Alert | 1 min read | 11.04.24

OFCCP Invites Federal Contractors to Object to Production of their “Type 2 EEO-1 Reports” in Response to New FOIA Request

On October 29, 2024, the Office of Federal Contract Compliance Programs (“ ”) published a notice in the Federal Register that it received two requests under the Freedom of Information Act (“ ”) for 2021 Type 2 EEO-1 Reports filed by federal contractors. The two requests came from the University of Utah and a non-profit organization named “As You Sow.” The notified federal contractors that the information might be protected from disclosure under Exemption 4, which protects disclosure of confidential commercial information, and requested that any entities that filed these reports and object to their disclosure submit objections by December 9, 2024. Objectors are strongly encouraged to use the portal. Alternatively, contractors may also submit written objections via email at OFCCPSubmitterResponse@dol.gov, or by mail. ...