Kevin Barnett

​ Key Takeaways: Phase II relief is limited. Contractors may no longer face an immediate Level 2 certification requirement, but their existing cybersecurity obligations remain in force. Self-assessments now matter even more. Contractors handling CUI must continue implementing NIST SP 800-171 controls, maintaining accurate documentation, submitting supportable assessments and making defensible compliance affirmations. Enforcement risk is shifting, not disappearing.

WASHINGTON — June 11, 2026 — BakerHostetler has once again been recognized as one of the best performing American law firms in the 2026 Legal 500 guide, with 153 attorney honors and 33 practice area commendations. These recognitions are a result of Legal 500’s assessment of hundreds of law firms across the United States, using a methodology involving in-depth market research, client and peer feedback and law firm submissions.

Key Takeaways The Department of Defense recently issued a proposed rule that would require any defense contractor with a contract above $5 million to undergo a review for foreign ownership, control or influence (FOCI). The proposed rule would significantly expand the current requirements for FOCI reviews, which apply only to classified contracts, and potentially require onerous mitigation to be completed shortly after contract award.