Convergence of Counterfeit and Cyber Threats: Understanding New Rules on Supply : A Talk by Jeffery Chiow
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Jeffery Chiow (jchiow@rjo.com) of Rogers Joseph O'Donnell, PC will present on Convergence of Counterfeit and Cyber Threats: Understanding New Rules on Supply at the CALCE SMTA conference at College Park, Maryland on June 25th.
Abstract:
Section 818 of the National Defense Authorization Act of 2012 ("NDAA 2012") should be understood in the context that led to its enactment, and the harm that it sought to prevent. But as time has passed, since enactment of Section 818 late in 2011, the federal government's perception of the threat has changed and so too has the emphasis of policy and regulatory initiatives being taken in response. While DoD will continue to develop and implement rules to protect the military supply chain against counterfeit electronic parts that could cause premature system failure, the increasing emphasis of DoD and other federal agencies (including the GSA) will be on protection against those counterfeits that present cyber risks. The government's initiatives to protect the supply chain will naturally focus first on agencies responsible for critical infrastructure and those that perform national security functions. But measures to protect the supply chain against cyber threats will come to affect acquisition practices and contractor oversight for all federal agencies. This is because of the dependence of federal functions upon information and communications technology (ICT), the omnipresent use of electronic equipment that draws upon a global supply chain, and the vulnerability of that supply chain both to counterfeits and cyber attack.
Bio:
Mr. Chiow is a member of the firm's Government Contracts Practice Group. He provides counsel on business and compliance issues faced by government contractors and he assists clients in contract disputes and all manner of government investigations. Particular interests include cybersecurity, supply chain assurance, technology services contracting, schedule contracting and contingency contracting. Mr. Chiow is a USMC Combat Veteran of the wars in Iraq and Afghanistan where he flew combat missions in an F/A-18D. He was awarded eight air medals, one with Combat "V". Chiow gained valuable legal experience from internships including: the Department of Justice, Criminal Fraud Division; Judge Roger Titus of the Federal District Court for the District of Maryland; the National Science Foundation's Office of Inspector General, and legislative intern to a Member of the House of Representatives.
Section 818 of the National Defense Authorization Act of 2012 ("NDAA 2012") should be understood in the context that led to its enactment, and the harm that it sought to prevent. But as time has passed, since enactment of Section 818 late in 2011, the federal government's perception of the threat has changed and so too has the emphasis of policy and regulatory initiatives being taken in response. While DoD will continue to develop and implement rules to protect the military supply chain against counterfeit electronic parts that could cause premature system failure, the increasing emphasis of DoD and other federal agencies (including the GSA) will be on protection against those counterfeits that present cyber risks. The government's initiatives to protect the supply chain will naturally focus first on agencies responsible for critical infrastructure and those that perform national security functions. But measures to protect the supply chain against cyber threats will come to affect acquisition practices and contractor oversight for all federal agencies. This is because of the dependence of federal functions upon information and communications technology (ICT), the omnipresent use of electronic equipment that draws upon a global supply chain, and the vulnerability of that supply chain both to counterfeits and cyber attack.
Bio:
Mr. Chiow is a member of the firm's Government Contracts Practice Group. He provides counsel on business and compliance issues faced by government contractors and he assists clients in contract disputes and all manner of government investigations. Particular interests include cybersecurity, supply chain assurance, technology services contracting, schedule contracting and contingency contracting. Mr. Chiow is a USMC Combat Veteran of the wars in Iraq and Afghanistan where he flew combat missions in an F/A-18D. He was awarded eight air medals, one with Combat "V". Chiow gained valuable legal experience from internships including: the Department of Justice, Criminal Fraud Division; Judge Roger Titus of the Federal District Court for the District of Maryland; the National Science Foundation's Office of Inspector General, and legislative intern to a Member of the House of Representatives.