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Matthew Ferraro

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Matthew F. Ferraro is a partner in Crowell & Moring’s Privacy and Cybersecurity Group, where he helps clients address complex regulatory matters at the intersection of advanced technology, national security, and crisis management. He advises leading organizations on high-impact matters related to artificial intelligence (AI) and other emerging technologies, cyberattacks, domestic and international privacy compliance, internal investigations, foreign direct investment reviews, and high-stakes crises.

Before joining the firm, Matthew served as the Senior Counselor for Cybersecurity and Emerging Technology to the Secretary of Homeland Security. As a principal advisor to the Secretary and a member of the U.S. Department of Homeland Security’s leadership team, he served at the heart of U.S. government policymaking around AI and cybersecurity. He assisted in the development and drafting of key AI, cyber, and technology policies and regulations; advised on the deployment of AI to fulfill the department’s missions; and counseled on cyber-incident responses and investigations. Matthew also helped establish and served as the Executive Director of the Artificial Intelligence Safety and Security Board, a flagship public-private advisory committee focused on AI’s use in critical infrastructure and chaired by the Secretary and composed of industry, nonprofit, and government luminaries.

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On June 5, 2026, President Trump issued National Security Presidential Memorandum (NSPM) 11 (NSPM-11) to accelerate AI adoption by the U.S. military and intelligence agencies. It directs updated AI management, acquisition, and use policies and seeks to compel AI companies to comply with Trump administration policies.  It calls for expanded training and enhanced security in collaboration with the private sector and orders the “termination for default or for convenience” of government contracts with AI companies that wish to limit how the government uses their products. NSPM-11 could also herald a major change in autonomous warfighting policy by directing the update of the Pentagon’s primary directive on autonomous weapon systems.

Continue Reading National Security Memorandum Aims to Accelerate Deployment of AI and Streamline Procurement Aligned to Administration Policies

On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities.  The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards.  The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed.  GSA requests comments by March 20, 2026.

An analysis of the proposed clause follows below.

Continue Reading AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems

On February 13, 2026, the U.S. Department of Homeland Security (DHS) announced upcoming virtual town hall meetings scheduled for March 2026 regarding the implementation of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA).  The meetings will allow industry stakeholders to provide input to DHS to refine the “scope and burden” of the forthcoming CIRCIA final rule.

Continue Reading DHS Announces Virtual Town Halls on CIRCIA Final Rule

In an important first, the yearly defense policy law, the National Defense Authorization Act (NDAA) for Fiscal Year 2026, directs the Department of Defense (DoD)  to develop and implement a framework addressing the cybersecurity and physical security of artificial intelligence and machine learning technologies (AI/ML) acquired by the Pentagon.

Continue Reading CMMC for AI? Defense Policy Law Imposes AI Security Framework and Requirements on Contractors

On December 18, 2025, the Fiscal Year 2026 National Defense Authorization Act (FY 2026 NDAA) (P.L. 119-60) was signed into law. The Act makes significant changes to defense acquisition, sourcing restrictions, and interactions between the Defense Industrial Base (DIB) and the Department of Defense (DOD). 

Continue Reading The FY 2026 National Defense Authorization Act

This week’s episode covers developments involving DOJ’s guidance for federal funding recipients regarding DEI and the White House AI Action Plan, and is hosted by Peter Eyre, Katie Erno, and Matthew F. Ferraro. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government contracts legal and regulatory…

On July 23, 2025, the White House released Winning the Race: America’s AI Action Plan (“the Plan”) the Trump Administration’s most significant policy statement on artificial intelligence to date.

Continue Reading White House AI Action Plan Seeks to Establish “Dominance,” Boost Innovation, and Scrutinize Regulations