Client Alerts & Newsletters

Just in Time for Spring: Revision 2 to NIST SP 800-171 Comes into Full Bloom

Mar.12.2020

The National Institute of Standards and Technology (NIST) recently released its final version of Revision 2 to the cybersecurity standard NIST Special Publication (SP) 800-171. While the security controls remain unchanged, Revision 2 now incorporates implementation guidance into each control.  Importantly though, such guidance remains non-binding and is not intended to extend the scope of the controls’ requirements.  

For future solicitations, Revision 2 will replace Revision 1 as the applicable standard under DFARS 252.204-7012. It remains to be seen how the finalization of Revision 2 will impact the Department of Defense’s Cybersecurity Maturity Model Certification (CMMC). Currently, many CMMC practices cite to Revision 1, while “Discussion” sections cite to the draft version of Revision 2.

Lastly, although introduced in draft form at the same time as Revision 2, the separate standard NIST SP 800-171B – describing enhanced security controls intended to mitigate the risks of Advanced Persistent Threats (APTs) – remains unfinalized.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Evan D. Wolff
Partner – Washington, D.C.
Phone: +1 202.624.2615
Email: ewolff@crowell.com

Kate M. Growley, CIPP/G, CIPP/US
Partner – Washington, D.C.
Phone: +1 202.624.2698
Email: kgrowley@crowell.com

Maida Oringher Lerner
Senior Counsel – Washington, D.C.
Phone: +1 202.624.2596
Email: mlerner@crowell.com

Michael G. Gruden, CIPP/G
Associate – Washington, D.C.
Phone: +1 202.624.2545
Email: mgruden@crowell.com

Christopher R. Hebdon
Associate – Washington, D.C.
Phone: +1 202.624.2645
Email: chebdon@crowell.com

Crowell & Moring LLP is an international law firm with approximately 550 lawyers representing clients in litigation and arbitration, regulatory and policy, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity, equity and inclusion. The firm has offices in Brussels, Doha, London, Los Angeles, New York, Orange County, San Francisco, Shanghai, and Washington, D.C.

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