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Moriah Daugherty

Moriah Daugherty advises clients on a broad range of cybersecurity and national security matters, with a particular focus on risk management and governance, regulatory compliance, incident response and crisis management, and internal and government investigations.

Moriah specializes in counseling clients on a variety of issues related to cybersecurity risk management and governance, including evaluating security controls, practices, and policies and preparing for cybersecurity incidents and data breaches, including the potential for related investigations, regulatory inquiries, and litigation. She regularly counsels clients on responding to a broad range of cybersecurity incidents, including breaches of personal data and incidents involving extortion and ransomware, targeting and theft of intellectual property by advanced persistent threats, and state-sponsored theft of sensitive U.S. government information.

Drawing on her government experience, Moriah leads cyber-related internal investigations and investigations conducted in response to government inquiries, whistleblower complaints, and threats of litigation, including matters involving allegations of noncompliance with U.S. government cybersecurity regulations and fraud under the False Claims Act.

Prior to becoming a lawyer, Moriah spent eight years working for the Federal Bureau of Investigation and U.S. Department of Justice.

On December 23, 2022, President Biden signed the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 (the “FY2023 NDAA”) into law.  As described in Covington’s Client Alert, FY23 NDAA: Provisions of Interest for Almost All Government Contractors, the FY23 NDAA contains provisions of interest for almost all U.S. Government contractors.  One provision likely to be of particular interest to U.S. contractors who provide or plan to provide cloud computing services to the U.S. Government is the FedRAMP Authorization Act (the “Act”), which codifies the Federal Risk and Authorization Management Program (“FedRAMP”).

Of note, the Act creates a “presumption of adequacy” that cloud providers with authorization from one agency can use that authorization with other agencies. This is an expansion compared to the current process which allows authorizations by the FedRAMP Joint Authorization Board, but not authorizations from individual agencies, to serve as the basis for an agency’s own authorization process.  It also creates the Federal Secure Cloud Advisory Committee, comprised of 15 members of the public and private sector, to provide recommendations regarding FedRAMP and the acquisition of cloud services more generally.Continue Reading FY2023 NDAA Makes Notable Changes to FedRAMP Program

On March 15, 2022, President Biden signed the Consolidated Appropriations Act 2022, a $1.5 trillion omnibus spending package to fund the government through September 2022.  The omnibus spending package includes the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (the “Act”), which establishes two cyber incident reporting requirements for
Continue Reading President Biden Signs Critical Infrastructure Ransomware Payment and Cyber Incident Reporting into Law

Almost a year after Assistant Secretary of the Navy James Geurts issued his September 28, 2018 memorandum (Geurts Memo) imposing enhanced security controls on “critical” Navy programs, the Navy has issued an update to the Navy Marine Corps Acquisition Regulations Supplement (NMCARS) to implement those changes more formally across the Navy.  Pursuant to this update, a new Annex 16 in the NMCARS provides Statement of Work (SOW) language that must be added into Navy solicitations and contracts where the Navy has determined “the risk to a critical program and/or technology warrants its inclusion.”  In addition to the technical requirements reflected in the Geurts Memo, the Navy has added Subpart 5204.73 to the NMCARS that, among other things, instructs Contracting Officers (COs) to seek equitable reductions or consider reducing or suspending progress payments for contractor non-compliance with the Annex 16 and DFARS 252.204-7012 (DFARS clause) requirements.
Continue Reading Navy Modifies Acquisition Supplement to Tighten Cybersecurity Requirements and Implement the Geurts Memorandum

On June 19, 2019, the National Institute of Standards and Technology (“NIST”) announced the long-awaited update to Special Publication (“SP”) 800-171 Rev. 1, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations, which includes three separate but related documents.
Continue Reading NIST Announces and Seeks Public Comment on 800-171 Update and Related Documents

On December 20, 2017, the National Institute of Standards and Technology (“NIST”) held a live webcast to discuss the draft updates to the Framework for Improving Critical Infrastructure Cybersecurity (“the Cybersecurity Framework”) and the Roadmap for Improving Critical Infrastructure Cybersecurity (“the Roadmap”). Although the webcast is not currently available online, NIST plans to publish a recording of the live webcast in early January 2018.

During this webcast, NIST provided an overview of the updates to Version 1.1 of the Cybersecurity Framework (“Version 1.1”), which were analyzed in previous blog posts on Inside Privacy and Inside Government Contracts. The webcast included a discussion of the following topics:
Continue Reading NIST Holds Webcast to Discuss Updates to Cybersecurity Framework

On December 5, 2017, the National Institute of Standards and Technology (“NIST”) announced the publication of a second draft of a proposed update to the Framework for Improving Critical Infrastructure Cybersecurity (“Cybersecurity Framework”), Version 1.1, Draft 2. NIST has also published an updated draft Roadmap to the Cybersecurity Framework, which “details public and private sector efforts related to and supportive of [the] Framework.”
Continue Reading NIST Releases Updated Draft of Cybersecurity Framework


Ahead of the upcoming December 31, 2017 deadline for federal defense contractors to implement National Institute of Standards and Technology (“NIST”) Special Publication 800-171 (“SP 800-171”), NIST has released a new draft publication designed to assist organizations in assessing compliance under SP 800-171, Draft Special Publication 800-171A, Assessing Security Requirements for Controlled Unclassified Information (“CUI”) (“SP 800-171A”).
Continue Reading NIST Releases New Draft Publication Designed to Assist Contractors In Assessing Compliance with NIST SP 800-171