Photograph of Michael G. Gruden, CIPP/G

Michael G. Gruden, CIPP/G


Michael G. Gruden is a counsel in Crowell & Moring's Washington, D.C. office, where he is a member of the firm’s Government Contracts and Privacy and 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.

Michael’s legal practice covers a wide range of counseling and litigation engagements at the intersection of government contracts and cybersecurity. His government contracts endeavors include supply chain security counseling, contract disputes with federal entities, suspension and debarment proceedings, mandatory disclosures to the government, prime-subcontractor disputes, and False Claims Act investigations. His privacy and cybersecurity practice includes cybersecurity compliance reviews, risk assessments, data breaches, incident response, and regulatory investigations. 

Government Contracts

Michael assists government contractors with federal contract compliance and administration matters throughout the contract lifecycle – from solicitation and award to audit, investigation, and termination. He advises clients on Federal Acquisition Regulations (FAR) provisions and clauses, as well as agency supplements such as the Defense Federal Acquisition Regulation Supplement (DFARS), Homeland Security Acquisition Regulations (HSAR), and others.


Michael has leveraged his procurement experience to advise numerous clients on DoD cybersecurity contract clauses. He has assisted clients in navigating the cybersecurity regulatory landscape by conducting compliance assessments, reviewing system security plans (SSPs) and plans of action and milestones (POAMs), and advising on Controlled Unclassified Information (CUI) marking guidance. Michael counsels clients on all aspects of cyber incident and data breach response, including working with forensic security consultants, conducting internal investigations, interacting with law enforcement, and complying with data breach notification laws. He also helps clients develop incident preparedness strategies and table-top exercises to assist companies in mitigating risks presented by data breach incidents.

Government Experience

Michael’s extensive federal procurement experience allows him to uniquely counsel his clients with a real-world perspective concerning contract evaluation and administration, as well as cybersecurity compliance.

U.S. Department of Defense

  • Branch Chief for Information Technology and Physical Security Acquisitions at Washington Headquarters Services (WHS), a 4th Estate DoD field activity responsible for the contracting needs of the Office of the Secretary of Defense (OSD) and the Pentagon Reservation. As an unlimited warrant Contracting Officer, Michael awarded, oversaw the award of or acted as the Source Selection Authority (SSA) of:
    • $500 million solicitation for information technology services spanning the entire Pentagon Reservation, where Michael worked with the Chief Information Officer and other Senior Executive Service members to develop the acquisition strategy and request for proposal (RFP).
    • Courtroom technology contracts at Guantanamo Bay, Cuba for 9/11 detainee military tribunals.
    • 24/7 global information technology support for the Office of the Secretary of Defense and their advance staff.
    • Travel agreements for the Secretary of Defense’s OCONUS and all CONUS travel.
    • Modernization of IT infrastructure for DoD’s primary alternate site, continuity of operations (COOP) facility.
    • Satellite tower construction and information technology development in the Asian Pacific to landmark drug, human, and weapon trafficking in concert with U.S. partnering nations.
    • Wargaming, modeling, and simulation contracts in support of war planning directorate of OSD.
    • Cooperative agreement for glass manufacturing facility in Afghanistan.
    • Security installation and repair services for electronic security systems and infrastructure throughout Pentagon Reservation. 
    • Meteorological and laboratory services for Chemical, Biological, Radiological, Nuclear (CBRNE) defense.
  • Michael was detailed for six months to the Office of the General Counsel, where he assisted attorneys in the defense of protests filed before the Government Accountability Office (GAO) and the U.S. Court of Federal Claims (COFC).

U.S. Department of Homeland Security

  • Acquisition Professional at DHS Headquarters supporting Science & Technology (S&T) Directorate and Homeland Security Advanced Research Projects Agency (HSARPA), among others; Contracting Officer at Immigration and Customs Enforcement (ICE). Collectively, Michael worked to:
    • Lead renovations for multiple DHS alternate site, continuity of operations facilities managing a suite of renovation construction contracts encompassing data centers, supervisory control and data acquisition (SCADA) systems, power grids, and water treatment facilities.
    • Administer Broad Agency Announcement (BAA) solicitation encompassing all program missions within S&T. Engaged with industry regarding the BAA, liaised between industry, members of Congress, the Executive Director of S&T, and program offices.
    • Award cybersecurity and CBRNE contracts for S&T and HSARPA.
    • Partner with the Office of Security to award essential IT software and hardware contracts.

During law school, Michael was an editor of the Journal of National Security Law & Policy.


  • Virginia Commonwealth University, B.A., Magna cum Laude With University Honors
  • Georgetown University Law Center, J.D.


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Government Contracts

Privacy and Cybersecurity

Litigation & Trial


Government Contracts Investigations

Privacy and Cybersecurity Investigations

National Security

Supply Chain Management

Supply Chain Security and Risk Management

CMMC Registered Provider Organization

Show more practices…

Government Contracts

  • Conducted internal investigations of government contractors, addressing a variety of issues relating to government contracts and regulations.
  • Prepared clients for supply chain management audits and assessments including Contractor Purchasing System Reviews (CPSR).
  • Assisted clients in suspension and debarment matters and drafted comprehensive responses to notices of proposed debarment.
  • Represented government contractors in bid protests before the Government Accountability Office (GAO).
  • Advised government contractors regarding organizational conflicts of interest and post-government employment restrictions.


  • Engaged in longstanding partnerships with multiple defense contractors to devise compliance strategies for DFARS 252.204-7012, including routine gap assessments and subsequent remediation plans.
  • Assisted major retailer with data breach notification reporting obligations and coordinated consumer and state notifications, as appropriate.
  • Helped clients assess and comply with cyber incident reporting obligations under DFARS 252.204-7012.
  • Conducted compliance assessments for clients and interpreted NIST SP 800-171 and NIST SP 800-53 regulatory requirements.
  • Advised clients on cloud service provider requirements under DFARS 252.204-7012 and DFARS 252.239-7010.
  • Counseled contractors regarding information security programs concentrating on Covered Defense Information (CDI), Controlled Unclassified Information (CUI), and Sensitive Security Information (SSI).
"Fiscal Year 2023 National Defense Authorization Act: Key Provisions Government Contractors Should Know," Government Contracting Law Report (March 10, 2023). Authors: Olivia Lynch, Stephanie L. Crawford, Rina M. Gashaw, Christopher D. Garcia, Michael G. Gruden, and Lyndsay A. Gorton.
" Experiencing Unexpected Outage and Generating Mistaken Emails as of March 8, 2023," Government Contracts Bullet Points (March 8, 2023). Contacts: Stephanie L. Crawford, Michael G. Gruden, CIPP/G
Client Alert / Newsletter
"Biden Administration Releases Comprehensive National Cybersecurity Strategy," Privacy Law Alert (March 6, 2023). Contacts: Evan D. Wolff, Matthew B. Welling, Jennie Wang VonCannon, CIPP/US, Maida Oringher Lerner, Alexander Urbelis, Christiana State, CIPP/US, CIPP/E, Neda M. Shaheen, Jacob Canter, Garylene (Gage) Javier, CIPP/US, Sarah Rippy, Alexis Ward, Maria Sokova, Michael G. Gruden, CIPP/G
Client Alert / Newsletter
"The Evolution of CMMC," National Contract Management Association, DC Chapter (February 15, 2023). Speaker: Michael Gruden.
"Webinar on FY2023 NDAA," Crowell & Moring Webinar, 2023 (February 8, 2023). Speakers: Stephanie L. Crawford, Christopher D. Garcia, Lyndsay A. Gorton, Michael G. Gruden, Alexandra Barbee-Garrett, Rina M. Gashaw, Rachel Schumacher
“FY2023 NDAA: Need-to-Know Provisions for Government Contractors” National Contract Management Association (January 18, 2023). Speakers: Michael Gruden, Olivia Lynch, Stephanie Crawford, Christopher Garcia, Lyndsay Gorton, Rina Gashaw, Alexandra Barbee-Garrett, and Rachel Schumacher.
"Cyber and Physical Attacks on the Electric Grid Should Prompt New Year’s Resolutions for the Energy Industry," Environment & Natural Resources Law Alert (January 13, 2023). Contacts: Tyler A. O'Connor, Evan D. Wolff, Matthew B. Welling, Maida Oringher Lerner, Deborah A. Carpentier, Michael G. Gruden, CIPP/G
Client Alert / Newsletter
"What Will the New Year Bring for Government Contractors?" Crowell & Moring Webinar, 2023. (January 12, 2023). Presenters: Crowell & Moring Government Contracts Group.
Crowell & Moring Elects 16 New Partners, Promotes Five to Senior Counsel, and 25 to Counsel (January 9, 2023)
Firm News / Announcement
"FY 2023 National Defense Authorization Act: Key Provisions Government Contractors Should Know," Government Contracts Bullet Points (December 28, 2022). Contacts: Alexandra Barbee-Garrett, Adelicia R. Cliffe, Stephanie L. Crawford, Maria Alejandra (Jana) del-Cerro, Christopher D. Garcia, Rina M. Gashaw, Lyndsay A. Gorton, Michael G. Gruden, CIPP/G, Jacob Harrison, Olivia Lynch, John E. McCarthy Jr., Per David Midboe, Rachel Schumacher, Zachary Schroeder, Robert J. Sneckenberg, Anuj Vohra, Alexis Ward, Darianne Young
Client Alert / Newsletter

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