The Department of Justice (DOJ) has announced that Honeywell Aerospace Inc. agreed to pay over $2 million to resolve allegations that it was liable under the False Claims Act (FCA) for failing to comply with cybersecurity requirements in a Department of Defense contract. The government alleged that a Honeywell International business unit submitted false claims for payment by failing to comply with requirements in National Institute of Standards and Technology Special Publication 800-171 for one Honeywell network, as required by the contract and applicable regulation.
The resolution reflects the government’s position that cybersecurity duties in a federal contract can carry FCA consequences when a contractor seeks payment while allegedly failing to meet a required standard. The allegations arose from a qui tam (whistleblower) lawsuit filed by a former Honeywell employee, who will receive $375,823 as part of the settlement.
Compliance Priorities for Federal Contractors
Federal contractors should assign clear responsibility for each contractual cybersecurity requirement, test compliance against the current technical environment, and document decisions about any exceptions or remediation plans. Personnel responsible for contract administration, information security, legal review, and billing should have a defined process for escalating gaps that could affect representations to the government or requests for payment.
Written policies alone may not establish compliance. Contractors should retain contemporaneous evidence showing how required safeguards were implemented, tested, monitored, and corrected. System security plans, assessments, remediation records, access reviews, incident documentation, and communications about known gaps should accurately describe the contractor’s actual environment.
GWB represents businesses and individuals in connection with government investigations, cybersecurity matters, and False Claims Act litigation. If you need assistance with such a matter, contact us today.
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