Photo of Kate M. Growley, CIPP/G, CIPP/USPhoto of Evan D. WolffPhoto of Michael G. Gruden, CIPP/G

The National Institute of Standards and Technology (NIST) recently released the final public draft of NIST Special Publication (SP) 800-172, formerly known as Draft NIST SP 800-171B. Building on the security requirements in NIST SP 800-171, the applicable standard under DFARS 252.204-7012, 800-172 provides 34 enhanced requirements to protect Controlled Unclassified Information (CUI) associated with critical programs or high value assets from the risks posed by advanced persistent threats (APTs).

Unlike prior drafts, 800-172 incorporates the protection strategy and desired effects on the adversary directly into the implementation guidance for each control. The Department of Defense (DoD) expects 800-172 to impact fewer than one percent of defense contractors. However, numerous requirements from Draft 800-171B were incorporated into the Cybersecurity Maturity Model Certification (CMMC) Levels 4 and 5, likely giving commenters the opportunity to affect future CMMC revisions.

Comments for the final public draft are due August 21, 2020.

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Photo of Kate M. Growley, CIPP/G, CIPP/US Kate M. Growley, CIPP/G, CIPP/US

Kate M. Growley (CIPP/US, CIPP/G) is a director in Crowell & Moring International’s Southeast Asia regional office. Drawing from over a decade of experience as a practicing attorney in the United States, Kate helps her clients navigate and shape the policy and regulatory…

Kate M. Growley (CIPP/US, CIPP/G) is a director in Crowell & Moring International’s Southeast Asia regional office. Drawing from over a decade of experience as a practicing attorney in the United States, Kate helps her clients navigate and shape the policy and regulatory environment for some of the most complex data issues facing multinational companies, including cybersecurity, privacy, and digital transformation. Kate has worked with clients across every major sector, with particular experience in technology, health care, manufacturing, and aerospace and defense. Kate is a Certified Information Privacy Professional (CIPP) in both the U.S. private and government sectors by the International Association of Privacy Professionals (IAPP). She is also a Registered Practitioner with the U.S. Cybersecurity Maturity Model Certification (CMMC) Cyber Accreditation Body (AB).

Photo of Evan D. Wolff Evan D. Wolff

Evan D. Wolff is a partner in Crowell & Moring’s Washington, D.C. office, where he is co-chair of the firm’s Chambers USA-ranked Privacy & Cybersecurity Group and a member of the Government Contracts Group. Evan has a national reputation for his deep technical…

Evan D. Wolff is a partner in Crowell & Moring’s Washington, D.C. office, where he is co-chair of the firm’s Chambers USA-ranked Privacy & Cybersecurity Group and a member of the Government Contracts Group. Evan has a national reputation for his deep technical background and understanding of complex cybersecurity legal and policy issues. Calling upon his experiences as a scientist, program manager, and lawyer, Evan takes an innovative approach to developing blended legal, technical, and governance mechanisms to prepare companies with rapid and comprehensive responses to rapidly evolving cybersecurity risks and threats. Evan has conducted training and incident simulations, developed response plans, led privileged investigations, and advised on hundreds of data breaches where he works closely with forensic investigators. Evan also counsels businesses on both domestic and international privacy compliance matters, including the EU General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA). He is also a Registered Practitioner under the Cybersecurity Maturity Model Certification (CMMC) framework.

Photo of Michael G. Gruden, CIPP/G Michael G. Gruden, CIPP/G

Michael G. Gruden is an associate in Crowell & Moring’s Washington, D.C. office where he is a member of the firm’s Government Contracts and Privacy & Cybersecurity groups. He possesses real-world experience in the areas of federal procurement and data security, having worked…

Michael G. Gruden is an associate in Crowell & Moring’s Washington, D.C. office where he is a member of the firm’s Government Contracts and Privacy & Cybersecurity groups. He possesses real-world experience in the areas of federal procurement and data security, having worked as a Contracting Officer at both the U.S. Department of Defense (DoD) and the U.S. Department of Homeland Security (DHS) in the Information Technology, Research & Development, and Security sectors for nearly 15 years. Michael is a Certified Information Privacy Professional with a U.S. government concentration (CIPP/G). He is also a Registered Practitioner under the Cybersecurity Maturity Model Certification (CMMC) framework. Michael serves as vice-chair for the ABA Science & Technology Section’s Homeland Security Committee.