Key Public Policy Developments Around the World
January brought several significant, long-awaited developments in the U.S. semiconductor policy space, marking an inflection point in how the Administration is deploying trade tools to advance national security and industrial policy objectives.
On January 14, 2026, the White House issued Presidential Proclamation 11002 (the “Proclamation”) and an accompanying Fact Sheet adopting …
On January 13, 2026, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) issued a final rule, titled Revision to License Review Policy for Advanced Computing Commodities (the “BIS Rule”), that implements a more favorable license application review policy for exports from the United States of certain advanced computing…
Continue Reading U.S. Commerce Department Revises License Review Policy for Exports of Certain Advanced Computing Commodities to China and MacauCompanies find themselves in the most dynamic regulatory environment in recent memory. That is due in part to changes President Trump has made to the way the White House interacts with the agencies. By dramatically increasing the number, tempo, and detail of executive orders, Trump has strengthened presidential control of the executive branch. The White House has never mattered more in regulatory policy-making, and companies should adjust their advocacy efforts accordingly.Continue Reading The Trump Administration’s Enhanced Use of Executive Orders
On December 19, New York Governor Kathy Hochul (D) signed the Responsible AI Safety & Education (“RAISE”) Act into law, making New York the second state in the nation to codify public safety disclosure and reporting requirements for developers of frontier AI models. Prior to signing, Governor Hochul secured several…
Continue Reading New York Governor Signs Frontier AI Safety LegislationOn December 11, President Trump signed an Executive Order on “Ensuring a National Policy Framework for Artificial Intelligence” (“AI Preemption EO”), the culmination of months of efforts by Republican lawmakers to assert federal primacy over AI regulation. The AI Preemption EO, which follows the release of a draft version in…
Continue Reading President Trump Signs Executive Order to Block State AI LawsAccording to reports published on November 19, the White House has prepared a draft Executive Order to preempt state AI regulations in lieu of a uniform national legislative framework, marking a significant escalation in federal efforts to assert control over AI regulation. The draft Executive Order, titled “Eliminating State…
Continue Reading White House Drafts Executive Order to Preempt State AI LawsIf you are the general counsel of a Fortune 500 company, you might be excused if you express bewilderment in response to reports about the successes of U.S. “tort reform.” In the past 5-8 years, both the plaintiffs’ bar and governmental authorities seem to have added an extra digit to…
Continue Reading Dealing with an Extra Digit: Latest Developments in Excess Liability Insurance Coverage and “Bermuda Form” Arbitrations for Catastrophic ExposuresThe Commerce Department today published a Request for Information (RFI) inviting the public to submit comments on U.S. artificial intelligence exports. The RFI asks stakeholders to weigh in on aspects of the Department’s new “American AI Exports Program,” an initiative intended to “promot[e] the export of full-stack American AI technology…
Continue Reading Commerce Department Solicits Feedback on AI Exports ProgramOn October 22, 2025, the U.S. government imposed property-blocking sanctions on Russia’s two largest oil companies, Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”), by designating these entities, as well as 34 Russia-based Rosneft and Lukoil subsidiaries, to the List of Specially Designated Nationals and Blocked…
Continue Reading U.S. and UK Sanctions Target Russia’s Two Largest Oil Companies; EU Issues Significant New Russia and Belarus Sanctions PackageOn October 17, 2025, the General Services Administration (“GSA”) announced that it plans to issue a Mass Modification to GSA’s Multiple Award Schedule (“MAS” or “Schedule”) Solicitation[1] and Schedule contracts in November 2025 (“Refresh”). Periodically, GSA may issue a Mass Modification to Schedule contracts to uniformly impose changes to the contract terms applicable to all Schedule contract holders, often as a result of changes in applicable law, regulation, or policy. This approach also ensures that existing Schedule contracts have consistent terms, even though with the evergreen nature of the Solicitation those contracts have been entered into at different times and are at different stages of performance.
This Refresh (i.e., Refresh #30) will implement several significant changes with the goal to align the GSA Schedule with recent developments in the Revolutionary FAR Overhaul (“RFO”).[2] Although the full text of the Refresh is not yet available, GSA’s Refresh outline provides insight into the changes that are to come as GSA seeks to gain implementation experience with the RFO clauses, provisions, and ordering procedures through its Schedule contracts. Given GSA’s leadership of the RFO process, and this year’s Executive Order to consolidate domestic procurement of common goods and services in GSA to the extent permitted by law,[3] it is no surprise that it has acted quickly to revise its long-term government-wide contracting vehicle according to these recent developments.
Along with the Refresh announcement, GSA opened a 10 business day comment window on buy.gsa.gov, which we expect will close on October 31, 2025. Schedules contractors will be expected to accept the Refresh no later than 90 days from its release which is expected sometime in November. Below we discuss relevant background on the RFO process as it relates to the Schedule and anticipated changes to provisions and clauses in the Refresh. We will continue to watch for updates as GSA’s implementation of the RFO unfolds. Continue Reading Overhauling the GSA Schedule
