On October 11, 2024, the United States Department of Defense (DOD) published a final rule implementing its Cybersecurity Maturity Model Certification (CMMC) program, which is designed to verify that defense contractors are adequately protecting sensitive information from cybersecurity threats. The CMMC applies to contractors who process, store, or transmit Controlled Unclassified Information (CUI) or Federal

The Department of Defense Inspector General (DoDIG) recently released its “Audit of the DoD’s Implementation and Oversight of the Controlled Unclassified Information [CUI] Program” (DODIG-2023-078). The audit highlights some of DoD’s challenges in implementing the CUI Program and provides recommendations on how to make the program work better. The DoD’s response to the

FTC Eyes Vendor Oversight in Safeguards Rule SettlementOn December 15, 2020, the FTC announced a proposed settlement with Ascension Data & Analytics, LLC, a mortgage industry analytics company, related to alleged violations of the Gramm-Leach-Bliley Act’s (GLBA) Safeguards Rule. In particular, the FTC claimed that Ascension Data & Analytics’ vendor, OpticsML, left “tens of thousands of consumers[’]” sensitive personal information exposed “to