Photo of M.Yuan Zhou

M. Yuan Zhou is a counsel in the Washington, D.C. office of Crowell & Moring, where she is a member of the firm's Government Contracts Group.

Yuan’s practice includes a wide range of investigatory, counseling, and transactional capabilities, including: internal investigations related to the False Claims Act, the Procurement Integrity Act, and other civil and criminal matters; compliance reviews and enhancing contractor compliance programs; representing clients in suspension and debarment proceedings; counseling on data rights issues, challenges, and disputes; mandatory disclosures; and providing government contracts due diligence in transactional matters. As part of the firm’s State and Local Practice, Yuan also counsels clients on state and local procurement issues, ranging from bid protests to contract negotiations with state agencies, and advises prime contractors and subcontractors on a variety of issues including prime/sub contract formation, disputes, and other government contracts issues.

This week’s episode covers the March 26 Executive Order titled “Addressing DEI Discrimination by Federal Contractors” and the March 31 OMB Memo titled “Reinforcing Transparency, Accountability, and Oversight of Federal Technology”, and is hosted by Peter Eyre and Yuan Zhou. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary

This week’s episode covers a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems, for inclusion in GSA Schedule solicitations and contracts involving AI, and is hosted by Peter Eyre and Yuan Zhou. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government contracts

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

This episode addresses efforts by various federal government agencies to audit and investigate purported ‘waste, fraud, and abuse’ in small business set-aside awards, and is hosted by Yuan Zhou, Olivia Lynch and Zach Schroeder. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government contracts legal and regulatory

This week’s episode covers developments regarding the Secure Software Development Attestation, GSA’s newly release CUI guidance, GSA’s RFI regarding resellers, and the Pentagon’s “patent holiday” pilot, and is hosted by Peter Eyre and Yuan Zhou. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government contracts legal

This week’s episode covers national fraud enforcement, an executive order focused on defense contracting, government investment strategies, GSA and transactional data reporting, and the Pentagon review of 8(a) awards, and is hosted by Peter Eyre and Yuan Zhou. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant

This week’s episode covers highlights of the Fiscal Year 2026 National Defense Authorization Act relating to defense acquisition, sourcing restrictions, and interactions between the Defense Industrial Base and the Pentagon, and is hosted by Peter Eyre and Yuan Zhou. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of

This week’s episode covers Pentagon’s Acquisition Transformation Strategy announced by Secretary Hegseth on November 7, and is hosted by Peter Eyre and Yuan Zhou. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government contracts legal and regulatory developments that no government contracts lawyer or executive should

On September 18, 2025, the Director of National Intelligence (DNI) issued the first order under the authority conferred by the Federal Acquisition Supply Chain Security Act (FASCSA), requiring exclusion and removal of products and services by an identified source.[1]
Continue Reading Off the (Supply) Chain: Director of National Intelligence Issues First Exclusion and Removal Order Under the Federal Acquisition Supply Chain Security Act