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Ryan Burnette

Ryan Burnette is a government contracts and technology-focused lawyer that advises on federal contracting compliance requirements and on government and internal investigations that stem from these obligations. Ryan has particular experience with defense and intelligence contracting, as well as with cybersecurity, supply chain, artificial intelligence, and software development requirements.

Ryan also advises on Federal Acquisition Regulation (FAR) and Defense Federal Acquisition Regulation Supplement (DFARS) compliance, public policy matters, agency disputes, and government cost accounting, drawing on his prior experience in providing overall direction for the federal contracting system to offer insight on the practical implications of regulations. He has assisted industry clients with the resolution of complex civil and criminal investigations by the Department of Justice, and he regularly speaks and writes on government contracts, cybersecurity, national security, and emerging technology topics.

Ryan is especially experienced with:

Government cybersecurity standards, including the Federal Risk and Authorization Management Program (FedRAMP); DFARS 252.204-7012, DFARS 252.204-7020, and other agency cybersecurity requirements; National Institute of Standards and Technology (NIST) publications, such as NIST SP 800-171; and the Cybersecurity Maturity Model Certification (CMMC) program.
Software and artificial intelligence (AI) requirements, including federal secure software development frameworks and software security attestations; software bill of materials requirements; and current and forthcoming AI data disclosure, validation, and configuration requirements, including unique requirements that are applicable to the use of large language models (LLMs) and dual use foundation models.
Supply chain requirements, including Section 889 of the FY19 National Defense Authorization Act; restrictions on covered semiconductors and printed circuit boards; Information and Communications Technology and Services (ICTS) restrictions; and federal exclusionary authorities, such as matters relating to the Federal Acquisition Security Council (FASC).
Information handling, marking, and dissemination requirements, including those relating to Covered Defense Information (CDI) and Controlled Unclassified Information (CUI).
Federal Cost Accounting Standards and FAR Part 31 allocation and reimbursement requirements.

Prior to joining Covington, Ryan served in the Office of Federal Procurement Policy in the Executive Office of the President, where he focused on the development and implementation of government-wide contracting regulations and administrative actions affecting more than $400 billion dollars’ worth of goods and services each year.  While in government, Ryan helped develop several contracting-related Executive Orders, and worked with White House and agency officials on regulatory and policy matters affecting contractor disclosure and agency responsibility determinations, labor and employment issues, IT contracting, commercial item acquisitions, performance contracting, schedule contracting and interagency acquisitions, competition requirements, and suspension and debarment, among others.  Additionally, Ryan was selected to serve on a core team that led reform of security processes affecting federal background investigations for cleared federal employees and contractors in the wake of significant issues affecting the program.  These efforts resulted in the establishment of a semi-autonomous U.S. Government agency to conduct and manage background investigations.

This is the seventh blog in a series of Covington blogs on cybersecurity policies, executive orders (“EOs”), and other actions of the Trump Administration.  The sixth blog is available here and our initial blog is available here.  This blog describes key cybersecurity developments that took place in August, September

Continue Reading August, September, and October 2025 Cybersecurity Developments Under the Trump Administration

Now that the final Cybersecurity Maturity Model Certification (CMMC) Program and Procurement Rules have been issued by the Department of War (DoW) (see our CMMC Toolkit for in-depth analysis of these Rules) and the CMMC Program is set to begin in earnest, there is some uncertainty in industry as to

Continue Reading How Will DoW Determine Which Level of CMMC Applies to My Agreement?

On September 15, 2025, the Office of the Director of National Intelligence (“ODNI”) issued the first public exclusion and removal order (the “Order”) under the framework established by the Federal Acquisition Supply Chain Security Act of 2018 (“FASCSA”).  The Order applies to all products and services produced or provided by Acronis AG as well as all subordinate, subsidiary, or affiliated organizations doing business under various names in support of Acronis AG.  The exclusionary Order has two immediate impacts on the federal supply chain.  First, federal contractors entering into new contracts or following contractual modifications are prohibited from supplying products or services from Acronis to agencies that are either subject to the Order or that have otherwise adopted it (“Covered Agencies”).  Second, contractors are prohibited from using products or services from Acronis in the performance of new and modified contracts with Covered Agencies.  In addition, certain agencies must remove these products and services from particular information systems.

Although the prohibitions apply to new contract awards, all contractors to Covered Agencies that have the applicable FASCA FAR clause (FAR 52.204-30) in their agreements must conduct diligence to determine whether they have provided or used any prohibited products or services in the performance of their contracts.  Following this review, the clause requires contractors to report the use of prohibited products or services to Covered Agencies.

Additional detail on the FASCSA exclusionary process and this first public Order is provided below.Continue Reading First Order Issued under the Federal Acquisition Supply Chain Security Act, Triggering Immediate Requirements on Contractors

This blog post discusses the Department of Defense’s (“DoD”) new cybersecurity rule that imposes certain cybersecurity requirements on relevant DoD contractors and subcontractors. The post will be of interest to all DoD contractors, subcontractors, and possibly affiliates of contractors that may be impacted by the new rule’s cybersecurity requirements.

On

Continue Reading Cybersecurity Maturity Model Certification (CMMC) Program Procurement Final Rule Announced

This is the sixth blog in a series of Covington blogs on cybersecurity policies, executive orders (“EOs”), and other actions of the Trump Administration.  The fifth blog is available here and our initial blog is available here.  This blog describes key cybersecurity developments that took place in July 2025. 

Continue Reading July 2025 Cybersecurity Developments Under the Trump Administration

This is part of an ongoing series of Covington blogs on the AI policies, executive orders, and other actions of the Trump Administration.  This blog describes AI actions taken by the Trump Administration in July 2025, and prior articles in this series are available here.

White House Issues AI

Continue Reading July 2025 AI Developments Under the Trump Administration

This is the fifth blog in a series of Covington blogs on cybersecurity policies, executive orders (“EOs”), and other actions of the Trump Administration.  The fourth blog is available here and our initial blog is available here.  This blog describes key cybersecurity developments that took place in June 2025. 

Continue Reading June 2025 Cybersecurity Developments Under the Trump Administration

This is the fourth blog in a series of Covington blogs on cybersecurity policies, executive orders (“EOs”), and other actions of the new Trump Administration.  This blog describes key cybersecurity developments that took place in May 2025. 

CISA Releases AI Data Security Guidance

On May 22, the Cybersecurity and Infrastructure

Continue Reading May 2025 Cybersecurity Developments Under the Trump Administration

On June 6, 2025, President Trump issued an Executive Order (“Sustaining Select Efforts to Strengthen the Nation’s Cybersecurity and Amending Executive Order 13694 and Executive Order 14144”) (the “Order”) that modifies certain initiatives in prior Executive Orders issued by Presidents Obama and Biden and highlights key cybersecurity priorities for

Continue Reading White House Issues New Cybersecurity Executive Order

On May 22, 2025, the Cybersecurity and Infrastructure Security Agency (“CISA”), which sits within the Department of Homeland Security (“DHS”) released guidance for AI system operators regarding managing data security risks.  The associated press release explains that the guidance provides “best practices for system operators to mitigate cyber risks through

Continue Reading CISA Releases AI Data Security Guidance