On Oct. 21, 2024, the OMB Office of Information and Regulatory Affairs (OIRA) concluded its regulatory review of the long-awaited Federal Acquisition Regulation Controlled Unclassified Information Rule (FAR CUI Rule), clearing the proposed rule’s path for publication in the Federal Register in 2024.

The FAR CUI Rule is being issued pursuant to Executive Order 13556, which directed the National Archives and Records Administration (NARA), and later delegated the Information Security Oversight Office, to implement uniform CUI program requirements for all federal contracts. Fourteen years later, the final step of NARA’s three-part implementation plan has cleared OMB review and will be published for public review and comments.

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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.

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.

Photo of Olivia Bellini˘ Olivia Bellini˘

Olivia Bellini  ˘ is a Government Contracts Practice Law Clerk in Greenberg Traurig’s Northern Virginia office.

˘ Not admitted to the practice of law.