Report DFARS Compliance Fraud: Whistleblower Guide for Cybersecurity Violations

What Is DFARS 252.204-7012?

DFARS clause 252.204-7012 requires Department of Defense (DoD) contractors to:

• Safeguard Controlled Unclassified Information (CUI)

• Implement security controls specified in NIST SP 800-171

• Provide adequate incident reporting

• Use FedRAMP Moderate equivalent cloud environments for CUI

• Submit self-assessed scores to the SPRS database

False claims of compliance with these obligations can expose the government to cyber risk—and expose contractors to massive liability.

What Counts as DFARS Compliance Fraud?

Contractors commit DFARS compliance fraud when they:

• Submit SPRS scores without implementing required NIST 800-171 controls

• Claim to have secure cloud storage (FedRAMP Moderate), but use commercial systems like Google Drive or Microsoft OneDrive

• Fabricate or reuse outdated System Security Plans (SSPs) and Plans of Action and Milestones (POA&Ms)

• Fail to report breaches, unauthorized access, or insider threats

• Retaliate against staff who raise cybersecurity concerns

If a contractor knows it isn't compliant but says it is to win or keep a DoD contract, that’s fraud under the False Claims Act.

Why It Matters: National Security and Taxpayer Dollars

The DoD relies on contractors to secure military research, weapon systems, and personnel data. A single false attestation can compromise entire supply chains.

You’re not just blowing the whistle for personal justice—you’re defending national security.

Case Example: Whistleblower vs. University of Pennsylvania

In the Decker v. University of Pennsylvania lawsuit, a senior information officer revealed that:

• Penn reused generic compliance templates

• Stored CUI in non-FedRAMP cloud platforms

• Lacked proper risk assessments and internal audits

• Still submitted compliance certifications to DoD for contract eligibility

Despite knowing it didn’t meet DFARS/NIST requirements, Penn continued to receive federal funding—until a whistleblower stepped forward.

Case Example: Raytheon Technologies Fraud Allegations

In a separate case, United States ex rel. Doe v. Raytheon, a former engineering director disclosed that Raytheon:

• Gave full admin privileges to all users on the “DarkNet” platform

• Continued to use pirated software for defense systems

• Knew it wasn’t compliant with NIST 800-171

• Chose to lie rather than delay submission or seek a waiver

• Retaliated against internal employees trying to correct the violations

These actions allegedly defrauded the U.S. government out of billions and created enormous cyber risk.

Who Can Report DFARS Compliance Fraud?

Potential whistleblowers include:

• Cybersecurity engineers

• CIOs and CISOs

• IT and network administrators

• Compliance officers

• DoD subcontractors

• University research staff

• Former employees with access to internal documentation

If you’ve been pressured to sign a compliance attestation you knew was false—or saw one submitted despite known gaps—you likely qualify.

What Kind of Evidence Is Needed?

To report DFARS fraud effectively, you’ll want to gather:

• Internal communications (emails, chats, memos)

• Screenshots of non-compliant systems or SPRS entries

• SSPs or POA&Ms showing missing or incomplete controls

• Internal audit reports or meeting notes

• Documentation of retaliatory behavior after raising concerns

• Statements of Work or contract language referencing DFARS clause 252.204-7012

The more documentation you have, the more viable your False Claims Act case becomes.

What Are the Rewards?

If your whistleblower case results in a successful recovery, you can receive:

• 15% to 25% of the government’s recovery (if the DOJ joins your case)

• Up to 30% if the government doesn’t intervene and you win on your own

• Damages for retaliation (e.g., back pay, reinstatement, attorneys' fees)

Whistleblower rewards often reach into the hundreds of thousands or millions of dollars depending on the contract value involved.

Your Rights Under the Law

The False Claims Act includes powerful protections for whistleblowers. If you’ve faced:

• Termination

• Demotion

• Harassment

• Denied promotions or projects

…you can sue for damages under 31 U.S.C. § 3730(h).

Even if you're still employed, you can report confidentially and under seal with the help of a specialized attorney.

How to Report DFARS Compliance Fraud

Here’s how the process works:

1. Confidential Consultation
   Speak with a False Claims Act attorney to assess your case.

2. Collect and Preserve Evidence
   Secure key documents, emails, and reports legally.

3. File a Sealed Complaint
   Your attorney will file a complaint with the Department of Justice under seal—meaning it’s not publicly disclosed.

4. DOJ Review and Investigation
   The DOJ will investigate and decide whether to intervene.

5. Litigation or Settlement
   If successful, the government recovers money—and you get a share.

Why Choose a DFARS Whistleblower Attorney?

False Claims Act cases based on DFARS violations are complex and involve both federal contract law and cybersecurity frameworks. A qualified cybersecurity whistleblower law firm will help you:

• Maximize your recovery

• Avoid retaliation

• Comply with whistleblower rules

• Navigate sealed court filings

• Present your case persuasively to the DOJ

Act Now—Don't Let Fraud Go Unpunished

If you know your company is lying about DFARS compliance, don’t stay silent. The longer fraud continues, the greater the risk to national security—and the less likely you are to be the first to report it. Contact The Whistleblower Advocates today. 

Be the one who steps up. The government will thank you—and so will your future.