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ARTICLE · 30 JANUARY 2024

DoD's New Year Resolution: A Cybersecurity Maturity Model Certification Program (CMMC) Proposed Rule

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On December 26, 2023, the Department of Defense (DoD) released the highly anticipated proposed rule for the Cybersecurity Maturity Model Certification Program (CMMC), a cybersecurity...

United StatesTechnology
Evan D. Wolff
Evan D. Wolff
Michael G. Gruden, CIPP/G
Michael G. Gruden, CIPP/G
Maida Oringher Lerner
Maida Oringher Lerner
Nkechi Kanu
Nkechi Kanu
Jacob Harrison
Jacob Harrison
Alexis Ward
Alexis Ward

On December 26, 2023, the Department of Defense (DoD) released the highly anticipated proposed rule for the Cybersecurity Maturity Model Certification Program (CMMC), a cybersecurity regulatory program that will likely impact most of the government contractor community. Every contractor who handles sensitive data such as Controlled Unclassified Information (CUI) or Federal Contract Information (FCI) during DoD contract performance will be covered by this regulation. While the CMMC program builds upon the security requirements included in Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012, CMMC will bring greater scrutiny to contractors' cybersecurity compliance and potentially greater consequences for failure to comply in the era of the Department of Justice's Civil Cyber Fraud Initiative and False Claims Act litigation. If finalized as proposed, the rule will significantly impact the CMMC regime, notably by requiring senior company

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