Archives: Global Defense Developments

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State Department Approves Possible Transaction to Weaponize Unmanned Aerial Systems

As reported by the Defense Security Cooperation Agency on November 4, 2015, the State Department approved a possible sale of equipment to Italy under the Foreign Military Sales (FMS) Program for weaponization of MQ-9s Reaper “drones” and associated equipment, parts and logistical support for an estimated cost of $129.6 million.  DSCA provided the required certification … Continue Reading

DFARS Final Rule Regarding Supply Chain Risk Issued

On October 30, DoD adopted as final, with changes, an interim DFARS rule that allows DoD to consider the impact of supply chain risk in specified types of procurements related to national security systems.  A copy of the rule is available here.  This final rule calls for contractors providing information technology to DoD, whether as … Continue Reading

Offsets and Export Controls

The DISAM Journal (published by the Defense Security Cooperation Agency (DSCA)) recently contained an interesting article that highlights the interplay between purchasing country offset requirements and US export controls.  According to the article, the US government has denied certain export licenses that are important to Lockheed’s offset requirements to support the indigenous KFX fighter program as part … Continue Reading

Comment Period for DFARS Network Penetration and Cloud Computing Rule Extended

Today’s Federal Register contains a notice indicating that the period for commenting on this important and complex interim final rule has been extended to November 20 – see For more information regarding the rule, see our prior posts regarding the rule and regarding DoD’s class deviation.… Continue Reading

DoD Issues Class Deviation Regarding Its Network Penetration Rule

On October 8, DoD issued a class deviation to the August 26 interim DFARS rule we reported on here which called for contractors working with covered defense information (which includes export-controlled information) to implement security requirements contained in NIST Special Publication (SP) 800-171.  The class deviation allows offerors up to nine (9) months, after contract award, … Continue Reading

Join Us for Steptoe’s Government Contractor Supply Chain Toolkit Webinar on October 20, 2015

Please join Steptoe’s Government Contracts Group for a webinar on its Government Contractor Supply Chain Toolkit.  The webinar covers a broad range of supply chain topics relevant to government contractors, including international regulatory issues such as export controls, anti-corruption and human trafficking. You can register for the webinar here.… Continue Reading

DoD Issues New Cyber-Reporting Rule for Contractors Participating in Defense Industrial Base (DIB) Cybersecurity Information Sharing Program and Modifies Eligibility for Program

Today DoD issued an interim final rule, effective immediately, which revised its DoD-DIB Cybersecurity (CS) Activities regulation to mandate reporting of cyber incidents that result in an actual or potentially adverse effect on a covered contractor information system or covered defense information residing therein, or on a contractor’s ability to provide operationally critical support.  This … Continue Reading

Government Contractor Supply Chain Toolkit

Supply chain risk management has become a key element of compliance programs for government contractors.  Contractors are facing increased demands to police their supply chains and the consequences of a failed supply chain risk management program can be severe. To help government contractors understand the legal and regulatory framework applicable to supply chain management and … Continue Reading

New DFARS Cyber Reporting Rule Issued (and Effective) Today Impacts Government Contractors and Subcontractors; Rule Also Addresses Cloud Computing

Today, DoD issued an interim rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to implement sections of the FY 2013 and 2015 Defense Authorization Acts that require contractor reporting on network penetrations.  Additionally, the rule implements DoD policy on cloud computing services.  The rule is effective immediately; comments are due on or before October … Continue Reading

Contractors: Are You Registered… in Afghanistan?

On June 18, 2015, the joint US/NATO mission in Afghanistan announced that the deadline for implementation of business license and visa requirements under the US-Afghan Bilateral Security Agreement (BSA) had been delayed until September 1, 2015.  The BSA became effective on January 1, 2015, but Afghan President Mohammad Ashraf Ghani initially delayed its implementation until … Continue Reading