Regulatory

On 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

Ahead of the July 2026 “joint review” of the U.S.-Mexico-Canada Agreement (“USMCA”), the United States, Mexico, and Canada have each launched public consultation processes to solicit input from stakeholders on the operation of the USMCA, and possible changes those governments should seek to the Agreement as part of the review.

Continue Reading The United States, Mexico, and Canada Launch Domestic Consultation Processes on Upcoming USMCA Review

In this increasingly growing digital landscape, companies are entrusted with vast amounts of sensitive personal information. From names and email addresses to browsing habits and location data, companies routinely collect users’ personal data all to enhance convenience and functionality, advertise products, personalize experiences for consumers, and improve services. Plaintiffs’ law…

Continue Reading Insurance Considerations for Privacy Class Action Lawsuits in This Technology Driven World

Brazil’s National Institute of Intellectual Property (“INPI”) initiated a public consultation on new guidance for the review of patent applications related to artificial intelligence (“AI”). The draft guidance document consolidates three previous INPI regulations and best practices adopted by other patent offices.

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Continue Reading Brazilian Government Opens Consultation on Artificial Intelligence-Related Patent Applications

On September 9, President Trump’s Make America Healthy Again (MAHA) Commission, chaired by HHS Secretary Kennedy, released its “Make Our Children Healthy Again Strategy Report” (Strategy Report) as directed by Executive Order 14212 (EO), which established the MAHA Commission. A draft of this report was leaked to the public about…

Continue Reading The Make Our Children Healthy Again Strategy Report: What it Says and Doesn’t Say about U.S. Food Regulation

On September 10, Senate Commerce, Science, and Transportation Committee Chair Ted Cruz (R-TX) released what he called a “light-touch” regulatory framework for federal AI legislation, outlining five pillars for advancing American AI leadership.  In parallel, Senator Cruz introduced the Strengthening AI Normalization and Diffusion by Oversight and eXperimentation (“SANDBOX”) Act…

Continue Reading Senator Cruz Unveils AI Framework and Regulatory Sandbox Bill

The United States and Colombia have historically maintained a strong bilateral partnership that has been the envy of much of Latin America. However, the bilateral relationship today is facing a test as U.S. and Colombian approaches to shared problems increasingly diverge. The next several months present milestones that will have…

Continue Reading U.S.-Colombia Relations Facing Key Decision Points with Implications for Businesses

On September 2, 2025, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) published in the Federal Register a final rule titled Relaxing Export Controls for Syria (the “Syria Export Controls Rule”). The rule eases certain export controls applicable to Syria under the Export Administration Regulations (“EAR”) by adding…

Continue Reading U.S. Commerce Department Eases Export Control Restrictions for Syria

We have reached the six-month anniversary of President Trump’s landmark executive order that extended the regulatory review process run by the White House’s Office of Information and Regulatory Affairs (OIRA) to regulations issued by independent agencies.[1]  This order marked an important change for many companies, especially in the financial services and energy sectors, whose regulators are now subject to White House regulatory review for the first time.

President Trump’s order left open many questions about how OIRA review of independent agency rules would work in practice.  Here at the six-month mark, we have seen enough such reviews to begin to answer these questions.  The bottom line for business is that OIRA and the independent agencies have begun to work out a harmonious relationship.  The independent agencies have acquiesced in OIRA review; indeed, nearly all major independent regulators have by now submitted rules for review.  Reviews—far from imposing major delays on independent agency rulemaking, as some feared—have been remarkably speedy, with both OIRA and the agencies themselves willing to dispense with formalities to expedite reviews.  In short, OIRA review is being integrated into the regulatory process of the independent agencies without undue disruption.Continue Reading OIRA Review of Independent Agency Rulemakings: What We Know So Far

On July 23, the White House released its AI Action Plan, outlining the key priorities of the Trump Administration’s AI policy agenda.  In parallel, President Trump signed three AI executive orders directing the Executive Branch to implement the AI Action Plan’s policies on “Preventing Woke AI in…

Continue Reading Trump Administration Issues AI Action Plan and Series of AI Executive Orders