Carlton Fields – The DOJ’s settlement of allegations under the False Claims Act against Verizon Business Network Services LLC emphasizes the agency’s continued efforts to enforce cybersecurity compliance against federal contractors.
Companies that do business with the government can minimize their exposure to cybersecurity-related False Claims Act liability by taking a few key steps:
- Carefully reviewing their assurances to the government when entering into and renewing federal government contracts.
- Proactively investigating and ensuring compliance with the cybersecurity requirements that apply to their federal government contracts.
- Equipping their personnel with adequate cybersecurity training that would allow them to identify potential issues and report and remediate the issues upon discovery.
- In consultation with counsel, evaluate whether to make a self-disclosure and the potential consequences of that action.
- If making a self-disclosure, work with counsel to reveal the extent of any noncompliance to the government.
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