On Dec. 26, 2023, DoD published a proposed rule implementing the CMMC Program (the Proposed Rule). The regulations come more than three years after the release of the initial CMMC regulations (November 2020) and two years after the Biden administration announced the revised “CMMC 2.0” program (January 2021). The Proposed Rule largely reflects the CMMC 2.0 version of the program, although there are important details and clarifications added in the over-200-page rule.

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Tags: Data Privacy & Cybersecurity, Department of Defense, government contracts, GT Insight
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Photo of Eleanor M. Ross Eleanor M. Ross

Eleanor (Elle) Ross advises government contractors from a diverse range of industries on regulatory matters including compliance with government regulations, contract disputes, defense of claims, and government investigations. She litigates bid protests before the Court of Federal Claims and the Government Accountability Office.

Eleanor (Elle) Ross advises government contractors from a diverse range of industries on regulatory matters including compliance with government regulations, contract disputes, defense of claims, and government investigations. She litigates bid protests before the Court of Federal Claims and the Government Accountability Office. She advises clients in connection with an array of agreements and multi-award procurements, including challenging award decisions in a variety of fora.

Elle also counsels clients on federal and state compliance obligations, particularly in connection with cybersecurity (including CMMC and NIST requirements) and supply chain risk management practices. She works with clients to understand government regulations and to develop compliance plans and to implement those plans. She also assists with making mandatory and voluntary disclosures to federal agencies and represented clients in subsequent investigations and administrative proceedings. She manages sanctions proceedings against contractors, including cases alleging fraud and corruption.

Elle also represents clients in commercial contract disputes, both in mediation and in federal court.

Previously, Ms. Ross was a legal consultant to World Bank Office of Suspension and Debarment, where she reviewed cross-border investigations to determine contractor compliance with World Bank regulations.

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Photo of Cassidy Kim Cassidy Kim

Cassidy Kim focuses her practice on government contracts and procurement matters. Cassidy also advises clients on cybersecurity and privacy compliance issues. She has worked with clients operating in an array of industries to navigate these sectors of the law, including providers of critical…

Cassidy Kim focuses her practice on government contracts and procurement matters. Cassidy also advises clients on cybersecurity and privacy compliance issues. She has worked with clients operating in an array of industries to navigate these sectors of the law, including providers of critical government infrastructure solutions, enterprise cloud services, EdTech, and autonomous defense systems.

Cassidy advises clients on litigating bid protests and claims involving state and federal level government procurements, including before the Government Accountability Office, U.S. Court of Federal Claims, and the California Department of General Services. She also provides industry-specific counsel on the CCPA/CPRA, GDPR, NIST, and related privacy and cybersecurity matters. Cassidy has developed consumer-facing privacy disclosures, B2B data transfer agreements, and employee compliance procedures. She has also led strategy on responses to regulatory actions and advised on supply chain risk management practices.

Prior to Greenberg Traurig, Cassidy worked as counsel at the Federal Reserve Bank of San Francisco, where she managed negotiations and provided strategic advice on San Francisco Fed and other Federal Reserve System contracts and procurement efforts across core business groups.

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Photo of Jeffery M. Chiow Jeffery M. Chiow

Jeffery M. Chiow, Co-Chair of Greenberg Traurig’s Government Contracts Practice, represents clients in litigation and government investigations related to government contracts, including federal and state bid protests and claims. Many of the bid protests that he litigates involve enterprise critical matters with billions

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Jeffery M. Chiow, Co-Chair of Greenberg Traurig’s Government Contracts Practice, represents clients in litigation and government investigations related to government contracts, including federal and state bid protests and claims. Many of the bid protests that he litigates involve enterprise critical matters with billions of dollars at stake. Jeff has deep experience in the aerospace and defense sectors, as well as cybersecurity, technology services contracting, and schedule contracting. Prior to entering private practice, he was a U.S. Marine Corps weapons and sensors officer in the F/A-18D Hornet. This experience informs Jeff’s work with cutting-edge technology in the areas of space systems, cloud computing, weapons platforms and IT systems. Jeff also advises businesses on compliance matters, working with government contractors to develop tailored strategies for addressing complex business, legal, and regulatory issues. In particular, he is a recognized leader in the constantly-evolving area of cybersecurity, including compliance with DoD’s cyber and supply chain requirements and the CMMC initiative and related investigations and disclosures.

Jeff’s False Claims Act experience includes advising on alleged fraud involving federal grants, DOJ Civil Fraud investigations, and qui tam suits alleging hundreds of millions of dollars in damages. He conducts sensitive internal compliance investigations and counsels defense, health care, construction, and technology clients about potential civil and criminal liability as well as potential disclosure obligations.

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