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July 2025 Cybersecurity Developments Under the Trump Administration

By Susan B. Cassidy, Ashden Fein, Robert Huffman, Ryan Burnette, Kristen Chapman & Grace Howard on August 22, 2025
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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. 

Trump Administration Issues AI Action Plan, including Actions Focused on Cybersecurity

On July 23, the White House released its Artificial Intelligence (“AI”) Action Plan, outlining the key priorities of the Trump Administration’s AI policy agenda.  The 28-page plan, titled “Winning the Race: America’s AI Action Plan,”  fulfills the core requirement of President Trump’s January 23 EO 14179 on “Removing Barriers to American Leadership in Artificial Intelligence,” which directed the Assistant to the President for Science & Technology, White House AI & Crypto Czar, and National Security Advisor to develop and submit an action plan for achieving the EO’s policy of sustaining and enhancing America’s global AI dominance.  We wrote about the AI Action Plan and three supplemental EOs accompanying the AI Action Plan here.

The AI Action Plan includes a focus on AI cybersecurity and secure-by-design AI.  The AI Action Plan provides that promoting resilient and secure AI development and deployment is a “core activity of the U.S. government,” and calls for all AI used in safety-critical or homeland security applications to be “secure-by-design, robust, and resilient,” able to detect performance shifts, and alert to malicious activities, such as data poisoning or adversarial example attacks.  To achieve these goals, the AI Action Plan calls for certain efforts that are focused specifically on bolstering critical infrastructure cybersecurity and promoting secure by design practices, including:

  • Establishing an AI Information Sharing and Analysis Center (AI-ISAC) to promote AI-security threat information and intelligence sharing across critical infrastructure sectors;
  • Issuing private sector guidance on responding to AI-specific vulnerabilities and threats;
  • Ensuring that known AI vulnerabilities are shared by Federal agencies to the private sector as appropriate, using existing cyber vulnerability sharing mechanisms;
  • The Department of Defense to refine its Responsible AI and Generative AI Frameworks, Roadmaps, and Toolkits; and
  • The Director of National Intelligence to publish an Intelligence Community Standard on AI Assurance under Intelligence Community Directive 505 on AI governance and management.

Recent Cybersecurity FCA Settlements Demonstrate Heightened FCA Risk to Government Contractors

The Government announced several Civil False Claims Act (“FCA”) settlements focused on cybersecurity in July, signaling a continued focus on cybersecurity civil fraud.  On July 14, 2025, the U.S. Department of Justice (“DoJ”) and General Services Administration (“GSA”) announced a $14.75 million settlement of FCA allegations against IT company Hill ASC Inc.  We wrote about this settlement here.  This settlement is consistent with the current Administration’s focus on “fraud, waste, and abuse” in government procurement and the DoJ FCA initiative focused on cybersecurity fraud.  This also follows the Department’s Criminal Division announcement of corporate procurement fraud as an enforcement priority. 

Soon thereafter, on July 31, 2025, DoJ announced a settlement agreement with Illumina, Inc., which agreed to pay $9.8 million to resolve claims arising from alleged cybersecurity vulnerabilities in genomic sequencing systems that the company sold to federal agencies.  We wrote about this settlement here.

These cases are the latest in a series of FCA settlements under the current administration that evidence DoJ’s continued focus on compliance with cybersecurity obligations for government contractors, particularly those that maintain sensitive data and personal information on behalf of federal customers. 

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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