Executive Briefing: Navigating the CMMC Phase II Suspension & False Claims Act Liability
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Executive Summary: What the July 13 Memorandum Means
On July 13, 2026, the Department of War temporarily suspended CMMC Phase II third-party audit requirements (C3PAO certifications) while establishing a 60-day CMMC Reform Task Force. While many Defense Industrial Base (DIB) contractors interpreted this headline as a reason to pause compliance, the contractual reality is the exact opposite.