Compliance Briefing — U.S. DOJ Civil Cyber-Fraud Initiative

Executive briefing: Deputy Attorney General Lisa Monaco announced the Civil Cyber-Fraud Initiative on 6 October 2021. The program uses the False Claims Act to pursue federal contractors and grant recipients that knowingly deliver deficient cybersecurity solutions or fail to report breaches.

Key provisions

• False Claims Act leverage. The DOJ will seek treble damages and penalties for entities that knowingly misstate compliance with cybersecurity requirements.
• Incident reporting obligations. Contractors must promptly disclose cyber incidents affecting government systems or data to avoid enforcement.
• Whistleblower incentives. Qui tam relators can report non-compliance and share in recoveries, increasing insider scrutiny of security controls.

Implementation guidance

• Compliance gap assessments. Map contracts against NIST 800-171, FedRAMP, and agency-specific clauses to evidence adherence.
• Incident response alignment. Update reporting playbooks to satisfy 52.204-21, DFARS 252.204-7012, and CMMC timelines.
• Documentation discipline. Maintain audit-ready records for security attestations, system security plans, and Plan of Action and Milestones (POA&M) tracking.

Enablement moves

• Brief executive leadership on False Claims Act exposure and budget remediation for inherited technical debt.
• Enhance supplier questionnaires and subcontractor monitoring to ensure downstream compliance.
• Coordinate with legal teams on privilege-protected tabletop exercises simulating DOJ inquiries.

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