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.

Defense Innovation Unit, AI, Proposal Timeliness

This week’s episode covers DoD’s Defense Innovation Unit report about actions to maintain U.S. technological superiority, DOJ’s plans to address the dangers posed by AI technology by seeking sentencing enhancements for crimes committed using AI technology, and a GAO decision involving a situation in which an offeror’s proposal was

Salary-History Bans and Pay Transparency, Section 3610 of the CARES Act

This week’s episode covers a proposed rule on salary-history bans and pay transparency for job applicants and employees of federal contractors and subcontractors, a claim relating to Section 3610 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, new requirements for U.S.-based Infrastructure

Limitations on Subcontracting, National Defense Industrial Strategy, Suspension/Debarment

This week’s episode covers a proposed rule regarding limitations on subcontracting, DOD’s National Defense Industrial Strategy, a proposed rule seeking to amend the FAR in order to enhance consistency between the suspension and debarment procedures in the FAR and in the Nonprocurement Common Rule system, and is

NDAA, SDVOSB Eligibility, FedRAMP

This week’s episode covers highlights of the NDAA for FY24, a Class Deviation relating to SDVOSB eligibility, an ASBCA decision involving pandemic-related claims, and DOD guidance detailing what it means for a cloud service provider to FedRAMP Moderate baseline “equivalent,” and is hosted by Peter Eyre and Yuan Zhou. Crowell &

The Department of Defense recently issued a long-awaited final rule prohibiting DoD prime contractors from “flowing down” FAR and DFARS clauses in subcontracts for commercial products or services, unless flowdown is specified by regulation. This rule implements language, dating from the 2017 National Defense Authorization Act, intended to reduce administrative burdens on DoD contractors and subcontractors by adding a prohibition on extraneous flowdowns at DFARS 252.244-7000 Subcontracts for Commercial Products or Commercial Services.Continue Reading Be Careful What You Wish For: Limited Commercial Subcontract Flowdowns May Increase Administrative Burdens

This week’s episode covers a DoD final rule that revises DFARS 252.244-7000 (Subcontracts for Commercial Products or Commercial Services), a protest decision relating to key personnel, and a DOJ resolution demonstrating the application of the new safe harbor policy for voluntary self-disclosures made in connection with mergers and acquisitions, and is hosted by Peter Eyre

This week’s episode covers FedRAMP’s announcement about AI-related products, the White House’s next phase of the federal government’s enterprise procurement approach (the Better Contracting Initiative), NIST’s updates regarding protection of controlled unclassified information, and the HHS OIG publication of its General Compliance Program Guidance, and is hosted by Peter Eyre and Yuan Zhou. Crowell &

Artificial Intelligence, Small Business Subcontracting, JV Security Clearances

This week’s episode covers the Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, a final SBA rule allowing prime contractors to receive small business credit for lower-tier subcontracts in certain situations, and a notice providing guidance concerning joint ventures and access

This week’s episode covers the FAR clauses implementing the Federal Acquisition Supply Chain Security Act, updates to NASA’s Small Business Mentor Protégé Program, and DOJ’s new safe harbor policy for voluntary self-disclosures made in connection with mergers and acquisitions, and is hosted by Peter Eyre and Yuan Zhou. Crowell & Moring’s “Fastest 5 Minutes” is

This week’s episode covers two proposed rules implementing Executive Order 14028, “Improving the Nation’s Cybersecurity,” the Department of Labor’s announcement of a change in the minimum wage rates for federal contractors, and the White House directive that federal agencies incorporate interim Social Cost of Greenhouse Gases estimates into the procurement function, and is hosted by