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.
Contacts
Partner, Crowell Global Advisors Senior Director
- Washington, D.C.
- D | +1.202.624.2698
- Washington, D.C. (CGA)
- D | +1 202.624.2500
Insights
Client Alert | 4 min read | 12.31.25
Raising the Bar: New York Expands Consumer Protection Law with FAIR Business Practices Act
New York Governor Kathy Hochul has signed into law the most significant update to New York’s consumer protection law in 45 years — the Fostering Affordability and Integrity through Reasonable Business Practices Act, or FAIR Business Practices Act — expanding the scope of the state’s authority to now challenge unfair and abusive business practices. The measure, backed by New York Attorney General (“AG”) Letitia James and signed on December 19, 2025, amends New York’s General Business Law § 349, giving regulators new tools to protect consumers and promote fair marketplace practices.
Client Alert | 4 min read | 12.30.25
Client Alert | 6 min read | 12.30.25
Investor Advisory Committee Recommends SEC Disclosure Guidelines for Artificial Intelligence
Client Alert | 2 min read | 12.29.25
FYI – GAO Finds Key Person “Available” Despite Accepting Employment with a Different Company
