This week Michael Gruden, counsel at Crowell & Moring, joins Off the Shelf, for a wide-ranging discussion focusing on cybersecurity and the CMMC journey. 

Gruden provides a cyber retrospective, outlining the evolution of government cybersecurity requirements to the present-day implementation of CMMC. A former contracting officer and Pentagon Branch Chief, Gruden shares his perspectives and insights on the key contracting considerations surrounding cybersecurity compliance. 

He also discusses the notable changes in the CMMC program outlined in the final rule along with the key features of the proposed DFARS rule that would implement CMMC in applicable defense contracts. 

Finally, Gruden discusses the legal risks associated with CMMC and then provides some compliance best practices for addressing those risks. 

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