Navigating Federal Cybersecurity Requirements and Enforcement for Government Contractors and Grant Recipients

This program will examine the evolving cybersecurity obligations facing companies performing government work, including new compliance developments across agencies, technical standards, certification requirements, and enforcement risk, including qui tam exposure.

Cyber incidents and data breaches present complex legal challenges across every industry, but federal contractors throughout the supply chain face heightened regulatory obligations and intensified enforcement scrutiny. Cybersecurity compliance for government contractors has moved on from an IT issue to a core contractual requirement directly tied to national security priorities and procurement eligibility. Counsel to primes and subcontractors must understand how overlapping regulatory frameworks, certification standards, and agency-specific mandates intersect.

During this course, our panel will provide a practical discussion of federal cybersecurity requirements, including regulatory frameworks administered by the U.S. Department of Defense (DoD), recent cybersecurity compliance initiatives and certification expectations implemented by the General Services Administration (GSA), and enforcement priorities advanced by the U.S. Department of Justice (DOJ). The program will address Controlled Unclassified Information (CUI), Federal Contract Information (FCI), subcontractor and grant recipient flow-downs, certification representations, and the expanding use of the False Claims Act to police cybersecurity compliance. 

The panel will also examine how evolving rules are reshaping risk allocation, disclosure obligations, and audit exposure. These include the Defense Federal Acquisition Regulation Supplement (DFARS) cybersecurity clauses and the Cybersecurity Maturity Model Certification (CMMC) framework, the growing application of foreign ownership, control, or influence (FOCI) requirements, along with GSA's expanding cybersecurity compliance expectations for schedule contractors and civilian agency vendors.  

Listen as our experienced panel shares practical strategies for advising clients on compliance program design, audit readiness, and enforcement mitigation.