US MANDATORY DISCLOSURE REQUIREMENTS FOR “CYBER INCIDENTS” IF FOREIGN PERSONS GAIN ACCESS TO CONTROLLED TECHNOLOGY

On 22nd October, Torres Law carried an article outlining where an export by defence contractors can be deemed to have taken place where a file has been uploaded that contains export-controlled data, has been inadvertently sent overseas or access has been allowed to unauthorised persons overseas.  It deals with additional requirements of the Defense Federal Acquisition Regulations Supplement (DFARS).  An export or “deemed export” of controlled technical data or technology may have taken place, further access must be prevented, and it must be reported as a “cyber incident” within 72 hours to the Department of Defense (DoD).

http://www.torrestradelaw.com/posts/DoD-Mandatory-Disclosure-Requirements-for-Export-045%3BControlled-Transfers-as-“Cyber-Incidents”/162

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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