Morgan Lewis Government Contractor Guidebook

YOUR GUIDE TO THE ISSUES THAT MATTER TO GOVERNMENT CONTRACTORS
Recent developments in government contracting highlight increased scrutiny of domestic sourcing and country-of-origin certifications, anticipated enforcement of cybersecurity requirements, and Small Business Administration activity focused on small business program compliance. These developments reflect continued alignment of procurement and enforcement priorities with supply chain security, data protection, and program integrity, directly impacting contractors across the federal marketplace.
The US Department of Defense (DOD) has implemented the Cybersecurity Maturity Model Certification (CMMC) program as of November 2025. The final rule implementing CMMC established new cybersecurity requirements for federal contractors and subcontractors and, resultingly, heightened the risks of noncompliance, including potential False Claims Act (FCA) risks.