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Kickstarting AI in the Federal Government: OMB’s Policy to Implement Executive Order 14179

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On April 3, 2025, the Office of Management and Budget (OMB) issued two memoranda implementing President Trump’s Executive Order...

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On April 3, 2025, the Office of Management and Budget (OMB) issued two memoranda implementing President Trump’s <a href="https://www.federalregister.gov/documents/2025/01/31/2025-02172/removing-barriers-to-american-leadership-in-artificial-intelligence" target="_blank">Executive Order 14179, Removing Barriers to American Leadership in Artificial Intelligence</a>. <a href="https://www.whitehouse.gov/wp-content/uploads/2025/02/M-25-21-Accelerating-Federal-Use-of-AI-through-Innovation-Governance-and-Public-Trust.pdf" target="_blank">Memorandum M-25-21, Accelerating Federal Use of AI through Innovation, Governance, and Public Trust</a> (OMB Memo M-25-21) describes the federal government’s policy on promoting the responsible deployment of artificial intelligence (AI) to drive innovation, economic growth, and national security.Read the full <a href="https://govcon.mofo.com/topics/kickstarting-ai-in-the-federal-government-omb-s-policy-to-implement-executive-order-14179" target="_blank">blog post</a>.

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Sandeep Nandivada is a partner in the Litigation Department of Morrison Foerster’s Washington, D.C. office. Sandeep’s practice focuses on civil litigation, complex internal investigations, and government contracts compliance, including matters related to cybersecurity and data breaches.Sandeep’s civil litigation practice focuses on bid protests, contract claims, subcontract disputes, and False Claims Act matters. He has litigated numerous protests before the Government Accountability Office, U.S. Court of Federal Claims, and the Small Business Administration Office of Hearings and Appeals across an array of subject matters—including some of the largest and most-high profile public procurements. Sandeep also has supported clients on significant claims, requests for equitable adjustments, and subcontract disputes involving a variety of performance or cost related issues.In addition, Sandeep has extensive experience conducting investigations with False Claims Act, Anti-Kickback Act, Procurement Integrity Act, and suspension and debarment implications. He has advised clients regarding procurement fraud, anti-corruption, procurement integrity, defective pricing, and cybersecurity, and has assisted clients with voluntary and mandatory disclosures under the FAR. Sandeep also was seconded to Northrop Grumman as Investigations Counsel.Sandeep also regularly advises clients on FAR and DFARS compliance issues, particularly issues related to cybersecurity, commercial item contracting, Buy American Act and Trade Agreements Act compliance, and organizational conflicts of interest. He also works with clients to evaluate and develop ethics and compliance programs.Sandeep has been named a “Rising Star” in 2020 by Law360 and National Law Journal, as well as DCA Live in 2018. He also has been named a Recommended Lawyer by The Legal 500 and as “One to Watch” by Best Lawyers. He is active in the American Bar Association’s Public Contract Law Section, currently serving as Vice-Chair on both the Cybersecurity, Privacy, and Emerging Technology Committee and the Procurement Fraud and False Claims Committee.Sandeep graduated With Honors from the George Washington University Law School, where he was Editor-In-Chief of The George Washington Journal of Energy and Environmental Law, Vice President of Internal Competitions for the Moot Court Board, a legal writing fellow, and a member of the Alternative Disputes Resolution Board. He received his undergraduate degree from Cornell University with Distinction in all Subjects in History.Sandeep is admitted to practice in Virginia, the District of Columbia, and before the U.S. Court of Federal Claims, the U.S. District Court for the Eastern District of Virginia, the U.S. Court of Appeals for the Federal Circuit, and the U.S. Court of Appeals for the Fourth Circuit.<h4>Representative Experience</h4><h5>Litigation</h5><ul><li>Successfully protested award of $45B Department of Energy contract for nuclear waste cleanup at the Hanford site in Washington State on behalf of Hanford Tank Disposition Alliance, LLC.</li></ul><ul><li>Successfully protested award of $10B Joint Enterprise Defense Infrastructure (“JEDI”) Contract on behalf of Amazon Web Services, Inc. </li><li>Successfully resolved notice of potential debarment for Department of Defense contractor without any administrative penalties or sanctions.</li><li>Successfully defended award of LOGCAP V contract and associated task orders to Vectrus Systems Corporation.</li><li>Successfully protested $87.4 million contract award based on agency’s failure to identify organizational conflicts of interest for the awardee.</li><li>Successfully defended award of IDIQ contract for Transformation Twenty-One Total Technology Next Generation procurement.</li><li>Successfully resolved False Claims Act and Procurement Integrity Act allegations, without litigation, on behalf of government contractor.</li><li>Represented large defense contractor in response to agency show cause letter and in certified claim against agency, and successfully negotiated favorable settlement.</li></ul><h5>Investigations</h5><ul><li>Conducted internal investigations for multiple clients concerning data breaches, including counseling such clients on remediation and reporting obligations.</li><li>Conducted internal investigation regarding major defense contractor’s accounting and business systems practices, including representing client’s interests with the Defense Contract Audit Agency and advising client executives regarding proposed changes and remedial actions.</li><li>Conducted internal investigation concerning allegations of fraudulent billing, including submission of mandatory and supplemental disclosures to agency inspectors general.</li><li>Conducted internal investigation for major defense contractor responding to subpoena from federal agency seeking commercial cost data, including successfully negotiating the scope of the subpoena.</li><li>Conducted internal investigation regarding major defense contractor’s compliance with export control laws and regulations.</li><li>Conducted internal investigation for major defense contractor regarding contract performance issues.</li><li>Conducted internal investigation for major defense contractor concerning Procurement Integrity Act compliance.</li><li>Conducted Foreign Corrupt Practices Act investigation for multinational corporation.</li></ul><h5>Compliance</h5><ul><li>Conducted multiple multi-national government contracts compliance review and associated risk assessment for a Global Fortune 500 company, including recommending process improvements and policy changes.</li><li>Conducted multinational compliance review regarding conflicts of interest and anti-kickback policies.</li><li>Counseled major government contractor regarding cybersecurity disclosure obligations.</li><li>Counseled clients regarding compliance with applicable Pay-to-Play, Lobbying, and Revolving Door restrictions.</li></ul>

Sandeep Nandivada

Partner

Justin Haan is a partner in the firm’s Technology Transactions Group in the San Francisco office, advising leading technology industry pioneers to help them navigate their most critical IP and technology needs.Justin’s practice focuses on transactions and counseling involving intellectual property and technology, including licensing arrangements, technology transfers, and joint development activities. Justin structures, drafts, and negotiates a wide range of commercial agreements, including software and content licenses, service agreements, reseller arrangements, and collaboration, manufacturing, supply and distribution agreements. He advises clients on the development, procurement and commercialization of cutting-edge technologies, including artificial intelligence, machine learning, augmented/virtual reality, semiconductors, cloud computing services, autonomous vehicles, and unmanned aircraft systems. Justin also counsels clients on open source software, complex patent-related transactions, and the intellectual property aspects of M&A transactions. Justin’s experience includes advising OpenAI, Arm, Autodesk, Meta, Salesforce, SoftBank, Unity, and others on the IP aspects of complex projects involving cutting-edge technologies and fast-evolving areas of law. Justin serves on the firm’s AI industry committee, where he helps to lead and collaborate with attorneys across multiple practices on the rapid advances of generative AI. Justin is also a sought–after speaker and thought leader on artificial intelligence and has spoken at SXSW on the subject of multimodal AI.Before joining the firm, Justin was an intellectual property associate in the New York office of another global law firm.Justin received his J.D., with a certificate in law and technology, from the University of California, Berkeley School of Law, where he won the Prosser Prize in intellectual property in the entertainment industries and was an articles editor for the Berkeley Technology Law Journal. He received his A.B. from Harvard University.

Justin Haan

Government Strategies

Government Contracts + Public Procurement