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The Cyber Defense eMagazine March Edition for 2024

Cyber Defense eMagazine March Edition for 2024 #CDM #CYBERDEFENSEMAG @CyberDefenseMag by @Miliefsky a world-renowned cyber security expert and the Publisher of Cyber Defense Magazine as part of the Cyber Defense Media Group as well as Yan Ross, Editor-in-Chief and many more writers, partners and supporters who make this an awesome publication! 225 page March Edition fully packed with some of our best content. Thank you all and to our readers! OSINT ROCKS! #CDM #CDMG #OSINT #CYBERSECURITY #INFOSEC #BEST #PRACTICES #TIPS #TECHNIQUES

Cyber Defense eMagazine March Edition for 2024 #CDM #CYBERDEFENSEMAG @CyberDefenseMag by @Miliefsky a world-renowned cyber security expert and the Publisher of Cyber Defense Magazine as part of the Cyber Defense Media Group as well as Yan Ross, Editor-in-Chief and many more writers, partners and supporters who make this an awesome publication! 225 page March Edition fully packed with some of our best content. Thank you all and to our readers! OSINT ROCKS! #CDM #CDMG #OSINT #CYBERSECURITY #INFOSEC #BEST #PRACTICES #TIPS #TECHNIQUES

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a false record or statement material to a false or fraudulent claim.” Material is defined as “having a natural<br />

tendency to influence, or be capable of influencing, the payment or receipt of money or property.”<br />

Given how the government has structured the CMMC program and its assessment requirements, it is<br />

almost certain that the government will consider inaccurate CMMC certifications “material” <strong>for</strong> purposes<br />

of the FCA. Contractors at the CMMC Level 1 and CMMC Level 2 tiers should be especially careful to<br />

ensure they fully comply with all required security assessments. FCA penalties are considerable—<br />

potentially up to three times the government’s damages, plus a statutory penalty linked to inflation—and<br />

the Department of Justice has signaled an increased focus on the cybersecurity space by launching its<br />

Civil <strong>Cyber</strong>-Fraud Initiative in 2021.<br />

Conclusion<br />

<strong>The</strong> proposed rule provides contractors with the structure in which the three-tiered certification program<br />

will operate. Given the importance and complexity of the rule and the requirement to sift through more<br />

than 230 submitted comments, a final rule is unlikely to be published <strong>for</strong> a few months and maybe<br />

upwards of a year. However, contractors should begin digesting the requirements and consider<br />

implementing the necessary measures to comply with the obligations now, many of which mirror alreadyexisting<br />

obligations, be<strong>for</strong>e the official rollout begins to ensure compliance.<br />

About the Author<br />

Richard W. Arnholt, a member at Bass, Berry & Sims PLC in Washington, D.C.,<br />

advises government contractors on risk mitigation through ethics and compliance<br />

programs and on allegations of procurement fraud or misconduct. He can be reached<br />

online at rarnholt@bassberry.com and at our company website<br />

https://www.bassberry.com/professionals/arnholt-richard/<br />

Adam Briscoe, an associate at Bass, Berry & Sims PLC in Washington, D.C.,<br />

advises companies as they navigate the contracting process with federal, state, and<br />

local governments. He can be reached online at adam.briscoe@bassberry.com and<br />

at our company website https://www.bassberry.com/professionals/briscoe-adam/<br />

<strong>Cyber</strong> <strong>Defense</strong> <strong>eMagazine</strong> – <strong>March</strong> <strong>2024</strong> <strong>Edition</strong> 140<br />

Copyright © <strong>2024</strong>, <strong>Cyber</strong> <strong>Defense</strong> Magazine. All rights reserved worldwide.

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