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FINANCIAL & CAPITAL MARKETS

Defense Federal Acquisition Regulation Supplement

Financial and capital markets firms with defense contracting exposure face a specific compliance pressure point where the Defense Federal Acquisition Regulation Supplement intersects with their vendor, subcontractor, and procurement obligations. The Defense Contract Audit Agency and the Office of the Under Secretary of Defense for Acquisition and Sustainment have both issued guidance tightening cybersecurity and supply chain integrity requirements that downstream financial intermediaries cannot treat as procurement-only problems. Compliance teams contracting with or servicing defense primes are now mapping their internal controls against DFARS clause 252.204-7012 to close gaps before contract renewals trigger formal attestation.

Watch

  • DFARS 252.204-7012 cybersecurity obligations for financial firms serving defense primes
  • Cybersecurity Maturity Model Certification 2.0 final rule: phased contractor compliance deadlines
  • Defense Contract Audit Agency scrutiny of subcontractor flow-down clause enforcement
  • Controlled Unclassified Information handling standards applied to financial transaction data
  • Proposed DFARS amendments expanding supply chain disclosure to indirect contractors

Recent material activity in Financial & Capital Markets

Active monitoring in place across Financial & Capital Markets. Material developments related to defense federal acquisition regulation supplement will appear here as they are published.