On June 4, 2026, Representatives Jay Obernolte and Lori Trahan released a discussion draft of the Great American Artificial Intelligence Act (GAAIA). The proposal has generated significant attention, but many organizations may be overestimating its practical significance for their day-to-day operations. The bill is directed primarily at developers of “frontier” AI models, so for most
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As Courts Wrestle With Tariff Refund Cases, Importers Should Confirm Submission of Key Information and Assess Options
Parallel proceedings in two U.S. Court of International Trade cases, Euro-Notions Florida, Inc. v. United States (No. 25-00595) and V.O.S. Selections, Inc. v. United States (No. 25-00066), are rapidly converging on what may be the central unresolved question in the IEEPA tariff refund process: must the government refund duties on entries that have liquidated and…
How Federally Funded Organizations Should Prepare for OMB Proposed Overhaul of Grants Oversight, DEI Bans, Easier Terminations
Key Takeaways
- The Office of Management and Budget (OMB) proposed sweeping revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards that, among other changes, would prohibit the use of federal funds to support DEI policies that violate federal anti-discrimination laws.
- The proposed rule introduces a broad discretionary termination provision, modeled
…
Canadian Steel Companies and Owner to Pay $19M to Settle False Claims Act Allegations Relating to Evaded Customs Duties
On May 20, 2026, the U.S. Department of Justice (DOJ) announced a settlement under the False Claims Act (FCA) with two Canada-based steel companies, Farjess Inc. and Royal Canadian Steel Inc., and their part-owner and president, Feroz Jessani, pursuant to which the companies and Jessani agreed to pay $19 million to resolve allegations that they…
DoW Proposed Rule Would Impose New FOCI Disclosure and Risk Mitigation Requirements on Thousands of Defense Contractors
On May 7, 2026, the Department of War (DoW) published a proposed rule that would dramatically expand the population of defense contractors that are required to disclose beneficial ownership and foreign ownership, control, or influence (FOCI) information to the Defense Counterintelligence and Security Agency (DCSA) and to mitigate identified FOCI risks. At present, DCSA addresses…
New Executive Order Mandates Shift to Fixed-Price Contracting, Requires Review of Largest Cost-Reimbursement Contracts
On April 30, 2026, President Trump signed an Executive Order titled “Promoting Efficiency, Accountability, and Performance in Federal Contracting” (the “Order”), directing executive branch agencies to default to fixed-price contracts and contracts that tie contractor profit to performance-based metrics in federal procurement. The Order also requires agencies to review and, to the maximum…
Monitor Upcoming Negotiations of Education Department’s AIM Committee to Inform Public Comments on Accreditation Amendments
Stakeholders negotiating sweeping amendments to federal accreditation regulations proposed by the U.S. Department of Education (ED) will begin their final session to achieve consensus on May 18, 2026.
A week-long effort in April revealed deep divisions among negotiators on the Accreditation, Innovation, and Modernization (AIM) Committee of the ED. Debates broke out over the ED’s…
DOJ’s New West Coast Strike Force Puts Health Care Providers on Notice
On April 30, 2026, the Department of Justice’s (“DOJ”) National Fraud Enforcement Division (“Fraud Division”) announced the formation of the West Coast Health Care Fraud Strike Force, a multi-district enforcement initiative spanning Arizona, Nevada, and the Northern District of California. [1] Announced by Assistant Attorney General Colin McDonald, the new Strike Force signals a significant…
FAR Council Issues Implementation Guidance for Executive Order 14398: New DEI Contract Clause Requirements for Federal Contractors
On April 20, 2026, the Federal Acquisition Regulatory (FAR) Council issued agency implementation guidance for Executive Order (E.O.) 14398, “Addressing DEI Discrimination by Federal Contractors,” which President Trump signed on March 26, 2026. The guidance introduces a new contract clause — FAR 52.222-90 — and establishes tight deadlines for agencies to incorporate the clause…
GSA AI Procurement Rules Would Introduce New Disclosure and Use-Rights Requirements for Federal Contractors
The General Services Administration (GSA) Federal Acquisition Service has released draft contract terms and conditions related to artificial intelligence (AI)-related procurements through a new proposed GSAR clause 552.239-7001, “Basic Safeguarding of Artificial Intelligence Systems (FEB 2026) (GSAR Deviation), that would impose material new requirements on contractors and service providers supplying artificial intelligence capabilities to the…