Civil Law

“DOJ’s $2 Million Honeywell Settlement Under the Civil Cyber-Fraud Initiative: What Compliance Failures Mean for Defense Contractors

Key Takeaways

  • DOJ used the FCA to settle with Honeywell Aerospace Inc. for $ 2,042,518 over allegations that a Honeywell business unit submitted claims for payment under a DoW contract while failing to comply with NIST SP 800-171 cybersecurity requirements incorporated through DFARS 252.204-7012, reinforcing that cybersecurity compliance failures can create significant FCA exposure for defense contractors.
  • The settlement arose from a 2022 qui tam whistleblower action filed by a former Honeywell employee, and DOJ reported a record
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Civil Law

New Restrictions on Defense Contractors Retaining Outside Consultants Will Take Effect This Month

In January 2025, Covington issued a client alert noting that the National Defense Authorization Act (“NDAA”) for Fiscal Year (“FY”) 2025, which sets annual spending and policy for the Pentagon, introduced new China-related prohibitions on defense contractors and their consultants. The provision is finally set to take effect on June 30, 2026. This client alert provides an update on the new restriction and suggested compliance steps defense contractors, and consultants who work with defense contractor clients, might consider taking before the … Read the rest

Civil Law

Defense Contractor Prohibition on Greenhouse Gas Emissions Disclosures

Department of Defense contractors are not permitted to “disclose a greenhouse gas inventory or any other report on greenhouse gas emissions.”

As governments across the United States are beginning to regulate greenhouse gas emissions, looking at the back story and teasing out the broad impact of this prohibition is worth our time.

We blogged, Government Proposes Federal Contractors and Their Suppliers Disclose GHG Emissions describing the November 14, 2022, proposed Federal Supplier Climate Risks and Resilience Rule that proposed to … Read the rest