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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. 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.

On Sept. 10, 2025, the Department Defense (DoD) issued a final rule amending the Defense Acquisition Regulation Supplement (DFARS) to implement the Cybersecurity Maturity Model Certification (CMMC) program for government contractors.
Continue Reading Recapping CMMC Level 3: Considerations for Government Contractors

Starting Nov. 10, 2025, contractors and subcontractors handling controlled unclassified information (CUI) may be required to have a current CMMC Level 2 self-assessment for new contracts and option exercises involving CUI.
Continue Reading Recapping CMMC Level 2: Considerations for Government Contractors

On Sept. 10, 2025, the Department Defense (DoD) issued a final rule amending the Defense Acquisition Regulation Supplement (DFARS) to implement the Cybersecurity Maturity Model Certification (CMMC) program for government contractors. This final rule established a November 10, 2025 go-live date for the start of phase 1 of CMMC. As we covered in our prior

In June 2025, the Cybersecurity and Infrastructure Security Agency (CISA) issued draft updated guidance for public comment on the Minimum Elements for a Software Bill of Materials (SBOM), which the National Telecommunications and Information Administration (NTIA) first published in 2021 for federal agencies in response to Executive Order 14028 on Improving the Nation’s Cybersecurity.
Continue Reading Software Bill of Materials Guidance for Government Contractors

Cybersecurity month starts with a critical compliance date for the Department of Justice (DOJ)’s Data Security Program (DSP). Starting on Oct. 6, any U.S. person or company handling Americans’ bulk sensitive or personal data or U.S. government-related data must implement a written data compliance program that lays out specified due diligence, audit, reporting, and recordkeeping processes for covered data transactions.
Continue Reading Incoming Deadlines and Requirements for DOJ’s Data Security Program on Oct. 6, 2025

On July 31, 2025, the Fraud Section of the U.S. Department of Justice’s Commercial Litigation Branch (Fraud Section) announced new settlement agreements with government contractors to resolve their respective False Claims Act (FCA) liabilities arising out of cyber fraud allegations.

Continue Reading DOJ Settles Cybersecurity FCA Claims With PE Firm and Government Contractors

DOJ’s new Data Security Program (DSP), effective April 8, 2025, imposes significant restrictions on U.S. government contractors and global companies that handle sensitive U.S. personal or government-related data. The DSP is currently subject to a 90-day initial enforcement period, After July 8, 2025, NSD will implement full enforcement of the DSP.
Continue Reading DOJ’s Data Security Program: Key Compliance Considerations for Impacted Entities

On Jan. 15, 2025, the Department of Defense (DoD), General Services Administration, and NASA, all members of the FAR Council, published a proposed FAR CUI Rule under Title 48 of the CFR. This proposed rule amends the Federal Acquisition Regulation (FAR) to implement the third and final piece of the National Archives and Records Administration’s