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May 2025 Cybersecurity Developments Under the Trump Administration

By Susan B. Cassidy, Ashden Fein, Robert Huffman, Ryan Burnette, Kristen Chapman & Grace Howard on June 24, 2025
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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 Security Agency (“CISA”), which sits within the Department of Homeland Security (“DHS”), released guidance for AI system operators regarding managing data security risks.  We wrote about the guidance here.

The associated press release explains that the guidance provides “best practices for system operators to mitigate cyber risks through the artificial intelligence lifecycle, including consideration on securing the data supply chain and protecting data against unauthorized modification by threat actors.”  CISA published the guidance in conjunction with the National Security Agency, the Federal Bureau of Investigation, and cyber agencies from Australia, the United Kingdom, and New Zealand.  This guidance is intended for organizations using AI systems in their operations, including Defense Industrial Bases, National Security Systems owners, federal agencies, and Critical Infrastructure owners and operators. This guidance builds on the Joint Guidance on Deploying AI Systems Security released by CISA and several other U.S. and foreign agencies in April 2024.

The guidance’s stated goals include raising awareness of the potential data security risks of AI systems, providing best practices for securing AI, and establishing a strong foundation for data security in AI systems.  The first part of the guidance outlines a set of cybersecurity best practices that are specific to AI systems, after which the guidance provides additional detail on three separate risk categories for AI systems (data supply chain risks, maliciously modified data, and data drift) and describes mitigation recommendations for each risk category.  The guidance demonstrates that companies should focus on the security aspects of AI systems as they are being stood up, particularly given the rapid pace of AI adoption. 

NIST Drafts Revision to IR 8259: IoT Cybersecurity Guidance

On May 13, NIST announced the first revision to NIST IR 8259 as well as NIST IR 8572 its workshop summary report.  These updates provide timely cybersecurity guidance for the evolving Internet of Things (“IoT”) industry.  IoT products have exploded in number in recent years, and they do not fit into traditional categories of information technology.  For background, in 2020, Congress passed the Internet of Things Cybersecurity Improvement Act.  The legislation tasked NIST with developing cybersecurity guidelines to manage and secure IoT effectively and reviewing its guidance every five years.  As part of that review, NIST held two working group sessions over the previous six months and identified three key challenges.  NIST then drafted revision 1 of the NIST IR 8259 that incorporated the working group feedback.  The proposed draft expands the scope of the guidance from “IoT Devices” to “IoT Products and Product Components” which could include backends, companion applications, and specialty networking hardware.  Further, the revision focused on providing guidance to support IoT product cybersecurity through end-of-life.  Some of the updates focus on adding guidance “to help manufacturers anticipate product deployment and usage, clarify data management across IoT components, and share enhanced language on lifecycle and support expectations.”  Finally, NIST held a public forum discussion on June 18 to discuss the new draft as well as planned updates to NIST SP-213.

Susan B. Cassidy

Ms. Cassidy represents clients in the defense, intelligence, and information technologies sectors.  She works with clients to navigate the complex rules and regulations that govern federal procurement and her practice includes both counseling and litigation components.  Ms. Cassidy conducts internal investigations for government…

Ms. Cassidy represents clients in the defense, intelligence, and information technologies sectors.  She works with clients to navigate the complex rules and regulations that govern federal procurement and her practice includes both counseling and litigation components.  Ms. Cassidy conducts internal investigations for government contractors and represents her clients before the Defense Contract Audit Agency (DCAA), Inspectors General (IG), and the Department of Justice with regard to those investigations.  From 2008 to 2012, Ms. Cassidy served as in-house counsel at Northrop Grumman Corporation, one of the world’s largest defense contractors, supporting both defense and intelligence programs. Previously, Ms. Cassidy held an in-house position with Motorola Inc., leading a team of lawyers supporting sales of commercial communications products and services to US government defense and civilian agencies. Prior to going in-house, Ms. Cassidy was a litigation and government contracts partner in an international law firm headquartered in Washington, DC.

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Photo of Ashden Fein Ashden Fein

Ashden Fein advises clients on cybersecurity and national security matters, including crisis management and incident response, risk management and governance, government and internal investigations, and regulatory compliance.

For cybersecurity matters, Mr. Fein counsels clients on preparing for and responding to cyber-based attacks, assessing…

Ashden Fein advises clients on cybersecurity and national security matters, including crisis management and incident response, risk management and governance, government and internal investigations, and regulatory compliance.

For cybersecurity matters, Mr. Fein counsels clients on preparing for and responding to cyber-based attacks, assessing security controls and practices for the protection of data and systems, developing and implementing cybersecurity risk management and governance programs, and complying with federal and state regulatory requirements. Mr. Fein frequently supports clients as the lead investigator and crisis manager for global cyber and data security incidents, including data breaches involving personal data, advanced persistent threats targeting intellectual property across industries, state-sponsored theft of sensitive U.S. government information, and destructive attacks.

Additionally, Mr. Fein assists clients from across industries with leading internal investigations and responding to government inquiries related to the U.S. national security. He also advises aerospace, defense, and intelligence contractors on security compliance under U.S. national security laws and regulations including, among others, the National Industrial Security Program (NISPOM), U.S. government cybersecurity regulations, and requirements related to supply chain security.

Before joining Covington, Mr. Fein served on active duty in the U.S. Army as a Military Intelligence officer and prosecutor specializing in cybercrime and national security investigations and prosecutions — to include serving as the lead trial lawyer in the prosecution of Private Chelsea (Bradley) Manning for the unlawful disclosure of classified information to Wikileaks.

Mr. Fein currently serves as a Judge Advocate in the U.S. Army Reserve.

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Photo of Ryan Burnette Ryan Burnette

Ryan Burnette advises clients on a range of issues related to government contracting. Mr. Burnette has particular experience with helping companies navigate mergers and acquisitions, FAR and DFARS compliance issues, public policy matters, government investigations, and issues involving government cost accounting and the…

Ryan Burnette advises clients on a range of issues related to government contracting. Mr. Burnette has particular experience with helping companies navigate mergers and acquisitions, FAR and DFARS compliance issues, public policy matters, government investigations, and issues involving government cost accounting and the Cost Accounting Standards.  Prior to joining Covington, Mr. Burnette served in the Office of Federal Procurement Policy in the Executive Office of the President, where he worked on government-wide contracting regulations and administrative actions affecting more than $400 billion dollars’ worth of goods and services each year.

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Photo of Grace Howard Grace Howard

Grace Howard is an associate in the firm’s Washington, DC office. She represents and advises clients on a range of cybersecurity, data privacy, and government contracts issues including cyber and data security incident response and preparedness, regulatory compliance, and internal investigations including matters…

Grace Howard is an associate in the firm’s Washington, DC office. She represents and advises clients on a range of cybersecurity, data privacy, and government contracts issues including cyber and data security incident response and preparedness, regulatory compliance, and internal investigations including matters involving allegations of noncompliance with U.S. government cybersecurity regulations and fraud under the False Claims Act.

Prior to joining the firm, Grace served in the United States Navy as a Surface Warfare Officer and currently serves in the U.S. Navy Reserve.

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  • Posted in:
    Administrative, Government
  • Blog:
    Inside Government Contracts
  • Organization:
    Covington & Burling LLP
  • Article: View Original Source

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