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Department of War Suspends CMMC Phase II Rollout, but Compliance Obligations Remain

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On July 13, 2026, the Department of War (DOW) issued a Memorandum announcing the immediate suspension of the Phase II rollout of...

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On July 13, 2026, the Department of War (DOW) issued a <a href="https://federalnewsnetwork.com/wp-content/uploads/2026/07/CIO-CMMC-Reform-Memo_26-P-1023.pdf">Memorandum</a> announcing the immediate suspension of the Phase II rollout of the Cybersecurity Maturity Model Certification (CMMC) program while a CMMC Reform Task Force conducts a 60-day review. This means government contractors will not be required to obtain a third-party assessment for CMMC Level 2 certification (or DIBCAC assessment for Level 3 certification) unless and until the DOW reinstates the requirement or imposes a new one.Read the full <a href="https://govcon.mofo.com/topics/department-of-war-suspends-cmmc-phase-ii-rollout-but-compliance-obligations-remain" target="_blank">blog post</a>.

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Sandeep Nandivada is a partner in the Litigation Department of Morrison Foerster’s Washington, D.C. office. Sandeep’s practice focuses on civil litigation, complex internal investigations, and government contracts compliance, including matters related to cybersecurity and artificial intelligence. His clients note that he “stands out for his strategic thinking and mastery of complex problem-solving. Sandeep’s leadership inspires confidence, and his collaborative approach ensures that every project benefits from both strategic insight and meticulous attention to detail” (The Legal 500 US 2025).Sandeep’s civil litigation practice focuses on bid protests, contract claims, subcontract disputes, and False Claims Act matters. He has litigated numerous protests before the Government Accountability Office, U.S. Court of Federal Claims, and the Small Business Administration Office of Hearings and Appeals across an array of subject matters—including some of the largest and most-high profile public procurements. Sandeep also has supported clients on significant claims, requests for equitable adjustments, and subcontract disputes involving a variety of performance or cost related issues.In addition, Sandeep has extensive experience conducting investigations with False Claims Act, Anti-Kickback Act, Procurement Integrity Act, and suspension and debarment implications. He has advised clients regarding procurement fraud, anti-corruption, procurement integrity, defective pricing, and cybersecurity, and has assisted clients with voluntary and mandatory disclosures under the FAR. Sandeep also was seconded to Northrop Grumman as Investigations Counsel.Sandeep also regularly advises clients on FAR and DFARS compliance issues, particularly issues related to cybersecurity, commercial item contracting, Buy American Act and Trade Agreements Act compliance, and organizational conflicts of interest. He also works with clients to evaluate and develop ethics and compliance programs.Sandeep is ranked as “Up and Coming” in Government Contracts by Chambers USA and was named a “Rising Star” in 2020 by Law360 and National Law Journal, as well as DCA Live in 2018. He also has been named a Recommended Lawyer by The Legal 500 and as “One to Watch” by Best Lawyers. He is active in the American Bar Association’s Public Contract Law Section, currently serving as vice-chair on both the Cybersecurity, Privacy, and Emerging Technology Committee and the Procurement Fraud and False Claims Committee. In 2026, Sandeep was named to Law360’s Aerospace & Defense editorial board.Sandeep graduated With Honors from the George Washington University Law School, where he was Editor-In-Chief of The George Washington Journal of Energy and Environmental Law, Vice President of Internal Competitions for the Moot Court Board, a legal writing fellow, and a member of the Alternative Disputes Resolution Board. He received his undergraduate degree from Cornell University with Distinction in all Subjects in History.Sandeep is admitted to practice in Virginia, the District of Columbia, and before the U.S. Court of Federal Claims, the U.S. District Court for the Eastern District of Virginia, the U.S. Court of Appeals for the Federal Circuit, and the U.S. Court of Appeals for the Fourth Circuit.<h4>Representative Experience</h4><h5>Litigation</h5><ul><li>Successfully protested award of $45B Department of Energy contract for nuclear waste cleanup at the Hanford site in Washington State on behalf of Hanford Tank Disposition Alliance, LLC.</li></ul><ul><li>Successfully protested award of $10B Joint Enterprise Defense Infrastructure (“JEDI”) Contract on behalf of Amazon Web Services, Inc. </li><li>Successfully resolved notice of potential debarment for Department of Defense contractor without any administrative penalties or sanctions.</li><li>Successfully defended award of LOGCAP V contract and associated task orders to Vectrus Systems Corporation.</li><li>Successfully protested $87.4 million contract award based on agency’s failure to identify organizational conflicts of interest for the awardee.</li><li>Successfully defended award of IDIQ contract for Transformation Twenty-One Total Technology Next Generation procurement.</li><li>Successfully resolved False Claims Act and Procurement Integrity Act allegations, without litigation, on behalf of government contractor.</li><li>Represented large defense contractor in response to agency show cause letter and in certified claim against agency, and successfully negotiated favorable settlement.</li></ul><h5>Investigations</h5><ul><li>Conducted internal investigations for multiple clients concerning data breaches, including counseling such clients on remediation and reporting obligations.</li><li>Conducted internal investigation regarding major defense contractor’s accounting and business systems practices, including representing client’s interests with the Defense Contract Audit Agency and advising client executives regarding proposed changes and remedial actions.</li><li>Conducted internal investigation concerning allegations of fraudulent billing, including submission of mandatory and supplemental disclosures to agency inspectors general.</li><li>Conducted internal investigation for major defense contractor responding to subpoena from federal agency seeking commercial cost data, including successfully negotiating the scope of the subpoena.</li><li>Conducted internal investigation regarding major defense contractor’s compliance with export control laws and regulations.</li><li>Conducted internal investigation for major defense contractor regarding contract performance issues.</li><li>Conducted internal investigation for major defense contractor concerning Procurement Integrity Act compliance.</li><li>Conducted Foreign Corrupt Practices Act investigation for multinational corporation.</li></ul><h5>Compliance</h5><ul><li>Conducted multiple multi-national government contracts compliance review and associated risk assessment for a Global Fortune 500 company, including recommending process improvements and policy changes.</li><li>Conducted multinational compliance review regarding conflicts of interest and anti-kickback policies.</li><li>Counseled major government contractor regarding cybersecurity disclosure obligations.</li><li>Counseled clients regarding compliance with applicable Pay-to-Play, Lobbying, and Revolving Door restrictions.</li></ul>

Sandeep Nandivada

Partner

Markus Speidel is an associate in Morrison Foerster’s Government Contracts & Public Procurement Group, in Washington, D.C. Markus assists clients across a wide range of contract matters, including contract claims and disputes, bid protests, compliance counseling, and investigations.Markus has litigated pre- and post-award bid protests before the U.S. Government Accountability Office (GAO), the U.S. Court of Federal Claims (COFC), and federal agencies. He has represented clients before the Armed Services Board of Contract Appeals (ASBCA), helped clients prepare requests for equitable adjustment (REAs) and certified claims, and assisted in resolving prime-subcontractor disputes across a diverse range of industries, including aerospace, defense, intelligence, cybersecurity, and telecommunications.   Markus has experience supporting clients’ internal and external investigations into Procurement Integrity Act and revolving door concerns. His practice also involves counseling clients on various compliance and regulatory issues, including Contractor Performance Assessment Reporting System (CPARS), the Creating Helpful Incentives to Produce Semiconductors (CHIPS) Act, Small Business Innovation Research (SBIR) funds, and intellectual property rights. Markus speaks on and regularly writes about domestic preference requirements and cybersecurity.Markus graduated from the University of Washington, with a B.S. in biology and a B.A. in history and science. He received his J.D. from The George Washington University Law School, where he was awarded the Murray J. Schooner Scholarship for Government Procurement Law. During law school, Markus worked as a law clerk with the firm’s Government Contracts Group and as a research assistant to the Nash & Cibinic Professor of Government Contract Law, Steven Schooner. Prior to practicing law, Markus taught high school science, including AP physics and chemistry. He earned a Ph.D. in education from the University of Hawaii. Markus is admitted to practice in Washington, D.C.

Markus Speidel

Associate

Government Contracts + Public Procurement

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