Anthony Pappas

Tony is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement practice. He received his J.D. from the William & Mary Law School, where he served as a staff member for the William & Mary Bill of Rights Journal.

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Years in the Making, Suspended in a Day: DoD/W Halts CMMC Phase II but Keeps Baseline Cybersecurity Obligations

By Michael Barnicle, Hilary Cairnie, Peter Jeydel, Lu Reyes, Bryan Williamson, Bonnie Gill, Anthony Pappas & Trey Smith on July 16, 2026

Posted in Cybersecurity and Data Privacy, State Attorneys General

DoD suspended CMMC Phase II on July 13, 2026, halting the November 10, 2026, deadline and all related implementation milestones pending a comprehensive reform review by a newly established CMMC Reform Task Force.
CMMC Level 2 (C3PAO) and Level 3 (DIBCAC) third-party assessment requirements are suspended, and active solicitations and contracts must be

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Anthony Pappas

Years in the Making, Suspended in a Day: DoD/W Halts CMMC Phase II but Keeps Baseline Cybersecurity Obligations

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