To kick off the New Year, Sheppard Mullin’s Governmental Practice Cybersecurity & Data Protection Team has prepared a cybersecurity-focused 2023 Recap (including links to all of the resources the team has put out over the past year) and 2024 Forecast
Government Contracts & Investigations Blog
Latest updates on Developments Affecting Government Contracts & Investigations
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Treasury Announces Renewed Push for Investment Adviser AML Rules
The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent and comprehensive anti-money laundering (“AML”) and countering the…
Government Contracts Cost and Pricing: Accounting for Unallowable Costs
Welcome back to the Cost Corner, where we provide practical insight into the complex cost and pricing requirements that apply to Government contractors. This is the third article in a multi-part series on the Federal Acquisition Regulation (“FAR”) Cost Principles…
Bid Protest Hub – December 2023
Since our last Bid Protest Hub article in November, the Government Accountability Office (“GAO”) has published 37 bid protest decisions, two of which have resulted in decisions sustaining the protester’s challenge. As we enter into the new year, it remains…
For Limited Use Only: Guidance on National Security Delay Determinations under the SEC Cyber Reporting Rule
On December 12, 2023, the Department of Justice (“DOJ”) issued guidance related to the process by which companies may request the United States Attorney General authorize delays of cyber incident disclosures, pursuant to a new Securities and Exchange Commission (“SEC”)…
DoD IG Report Provides Insight Into Common Missteps When Protecting CUI
On November 30, 2023, the Inspector General of the Department of Defense (“DoD IG”) released a Special Report: Common Cybersecurity Weaknesses Related to the Protection of DoD Controlled Unclassified Information on Contractor Networks (the “Report”). Between 2018 and 2023, the…
Government Contracts Cost and Pricing: Allocation of Direct and Indirect Costs
Welcome back to the Cost Corner, where we provide practical insight into the complex cost and pricing requirements that apply to Government contractors. This is the second article in a multi-part series on the Federal Acquisition Regulation (FAR) Cost Principles…
New Year, New Rules: The CMMC Proposed Rule is Here
Well, the wait is over. Just as 2023 came to a close, on December 26, 2023, the Department of Defense (“DoD”) published the much-anticipated Proposed Rule for the DoD’s Cybersecurity Maturity Model Certification (“CMMC”) program (the “Proposed Rule”). It has…
New Year, (Potentially) New Definition for “Subcontract”
In addition to prohibiting the flow-down of non-mandatory FAR/DFARS clauses (which we talk about here), the Department of Defense (“DOD”) Final Rule in connection with the Defense Federal Acquisition Regulation Supplement (“DFARS”) Case 2017-D010 also touched on the decades-long…
It’s the Most Wonderful Time for New DOD Flow Down Policies: Flowing Down Too Many Clauses Will Get Prime Contractors More Than a Lump of Coal
On November 17, 2023, the Department of Defense (“DOD”) published a Final Rule – over five years in the making – addressing DOD policies regarding the applicability of laws to commercial products, commercial services, and commercially available off-the-shelf (“COTS”) products…