The federal government’s response to Hurricanes Helene and Milton will increase its reliance upon government contractor support to perform critical tasks in the coming months. The Federal Emergency Management Agency and other federal, state, and local agencies charged with disaster response and recovery will look to contractors to provide everything from logistics to housing, construction

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.
Fastest 5 Minutes
OTAs, Consulting, SAM
This week’s episode covers a proposed rule updating the regulations relating to Other Transaction Agreements – specifically for prototype and production projects, a DoD proposed rule implementing Section 812 of the NDAA for FY24 relating to contracting for consulting services, and a bid protest decision regarding the FAR’s continuous SAM registration requirement…
Putting the “AI” in Compliance—DOJ Updates its Corporate Compliance Program Guidance to Address Emerging AI Risks and Leveraging Data
On Monday, September 23, 2024, the Department of Justice (DOJ), released an update to its Evaluation of Corporate Compliance Programs (ECCP) guidance. The ECCP guidance was last revised in March 2023, which brought a number of significant changes, including a focus on compensation and incentive structures (e.g., clawbacks), and third party messaging applications. This 2024 update, while not as significant in scope as its predecessor, nonetheless highlights the DOJ’s focus on new and emerging technologies, such as artificial intelligence (AI), as part of its evolving assessment of what makes a corporate compliance program truly effective, and how prosecutors should evaluate risk assessments and other management tools at the time of a corporate resolution.Continue Reading Putting the “AI” in Compliance—DOJ Updates its Corporate Compliance Program Guidance to Address Emerging AI Risks and Leveraging Data
Special Edition of the Fastest 5 Minutes
SBA Proposed Rule to Update Various SBA Small Business Programs
This special edition covers the SBA’s August 2024 proposed rule to update and clarify various small business programs, and is hosted by Yuan Zhou and Olivia Lynch. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government…
Fastest 5 Minutes
CMMC, DOJ, FedRAMP
This week’s episode covers DOD’s proposed rule regarding Cybersecurity Maturity Model Certification 2.0, DOJ’s new Corporate Whistleblower Awards Pilot Program, and an OMB memo that proposes updates to FedRAMP, and is hosted by Peter Eyre and Yuan Zhou. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief…
Fastest 5 Minutes
Clearances for Joint Ventures, Mentor-Protégé Program, GSA Schedule
This week’s episode covers a DoD memorandum establishing procedures for covered joint venture facility security clearances, an SBA notice relating to the Mentor-Protégé Programs, and an upcoming mass modification to all existing GSA Multiple Award Schedule contracts, and is hosted by Peter Eyre and Yuan Zhou. Crowell…
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FAR Part 40, Cyber Reporting, Bid Protest
This week’s episode covers a proposed rule to replace the phrase “significant deficiency” with “material weakness” for the government’s evaluation of contractor business systems, a GAO report on Defense Counterintelligence and Security Agency’s current cybersecurity policies and procedures, and a nationwide preliminary injunction that halts the U.S. Department…
Commerciality Guidance for Major Weapon System Procurements
On May 30, 2024, the Department of Defense (DoD) issued a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to implement Section 803 of the 2023 National Defense Authorization Act, which modified 10 U.S.C. § 3455 to provide additional guidance regarding data requirements needed to support determinations of commerciality and price reasonableness under procurements for major weapon systems. The rule applies to products that (i) have not previously been deemed commercial by the DoD; and (ii) are proposed as either a subsystem of a major weapon system or as a component or spare part of a major weapon system or subsystem. Continue Reading Commerciality Guidance for Major Weapon System Procurements
Special Edition of the Fastest 5 Minutes:
Federal Circuit Protest Ruling in Percipient.ai, Inc. v. United States
This special edition covers the Federal Circuit’s June 2024 protest decision in Percipient.ai, Inc. v. United States, and is hosted by Yuan Zhou and Anuj Vohra. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government…
Fastest 5 Minutes
Commerciality, Employee-Owned Businesses, Procurement Collusion Strike Force
This week’s episode covers a final rule regarding commerciality and price reasonableness under procurements for major weapon systems, a DOD pilot program involving employee-owned businesses, and an update on the Procurement Collusion Strike Force, and is hosted by Peter Eyre and Yuan Zhou. Crowell & Moring’s “Fastest 5…