This summer, defense contractors have received two very different signals about federal cybersecurity compliance. On one front, the Department of Justice (DOJ) is continuing to pursue False Claims Act (FCA) liability for contractors that misrepresent their cybersecurity posture—now with two settlements in quick succession targeting noncompliance with NIST SP 800-171 requirements. On the other, the newly renamed Department of War suspended the next phase of the Cybersecurity Maturity Model Certification (CMMC) program. Neither development changes the baseline obligations contractors already have, but together they illustrate how fluid—and consequential—this space remains.
