The Federal Acquisition Regulation (FAR), the bedrock of Federal procurement, is undergoing an unprecedented (some would say Revolutionary) overhaul. The Sheppard Mullin Government Contracts Team has created an online resource to help the Federal procurement community stay informed of the proposed changes.
Continue Reading Sheppard Mullin’s Government Contracts Team Launches Revolutionary FAR Overhaul Tracker
On June 6, 2025, the Trump Administration released a new Executive Order (“EO”) on cybersecurity, Sustaining Select Efforts to Strengthen the Nation’s Cybersecurity and Amending Executive Order 13694 and Executive Order 14144.[1] The Executive Order itself will not impose new obligations on agencies; instead, it strikes, amends, and updates certain provisions in prior Executive Orders from the Obama and Biden Administrations that have not been rescinded.
Continue Reading Trump’s New Cybersecurity Executive Order: What Contractors Need to Know
In a significant shift in international policy, the United States, European Union, and United Kingdom have each taken steps to ease sanctions on Syria, aiming to support the country’s reconstruction and political transition following the fall of the Assad regime.
Continue Reading Syria-ous Changes for Middle East Business? The United States, UK, and Europe Relax Sanctions on Syria
On May 28, 2025, a three-judge panel of the U.S. Court of International Trade (CIT) unanimously struck down the extensive tariffs imposed by President Trump under the International Emergency Economic Powers Act (IEEPA). The CIT held that the imposition of the tariffs exceeded the authority granted to the President by Congress under IEEPA. The Court issued a permanent injunction blocking the administration from enforcing the IEEPA tariffs, and ordered the administration to issue the necessary administrative orders within 10 days to end them. In response, the government appealed the case to the U.S. Court of Appeals for the Federal Circuit.
Continue Reading Federal Court Strikes Down IEEPA Tariffs
Years ago, when I was a baby lawyer living in a group house in DC, we had a toaster—my toaster. I had owned the toaster since college and it was showing its age. Eventually, you had to hold down the thing[1] to keep the bread lowered in the slots and toasting. But the appliance still heated bread and produced toast. One morning, I became so frustrated with that toaster and the thing-holding-down effort that I threw the toaster out, fully intending to get a new toaster.
The following day, my housemate, we’ll call him Mike,[2] raised an important
Continue Reading Throwing Away the Toaster: Where AI Controls Are Now and May be Heading
Some importers are finding, to their surprise, that the Trump Administration’s 25% tariffs on aluminum and steel create an exemption from the 125% tariffs on Chinese goods.
Continue Reading Not What You Think: Some Trump Tariffs Exempt Your Goods from Other Trump Tariffs
On April 3, 2025, OMB released two new memorandums on artificial intelligence (“AI”) as directed by Executive Order 14179, Removing Barriers to American Leadership in Artificial Intelligence. (As a reminder, President Trump issued Executive Order (EO) 14179 on January 23, 2025 after rescinding President Biden’s AI Executive Order (EO 14110)).
Continue Reading All American AI: New OMB Memos Set Priorities for Federal AI Use and Acquisition
Last month, the federal government announced a major overhaul of the Federal Risk and Authorization Management Program (“FedRAMP”) called “FedRAMP 20x” (we discussed the initiative here). FedRAMP 20x is moving forward fast – with new authorizations, community engagement efforts, standards documents, and the Phase One pilot program. (More information about the Phase One pilot program is available here.)
Continue Reading FedRAMP 20x – Update on Significant Change Process and Assessment Scope Standards
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.
Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III
The implementation of new 25% Section 232 duties on steel, aluminum, and certain derivatives, effective March 12, 2025, which are in addition to any special rate of duty otherwise applicable, are affecting importers globally. Here is a breakdown of what these new tariffs entail:
Continue Reading Overview of Section 232 Tariffs on Steel and Aluminum: What Importers Need to Know
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.
Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.
Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I
On April 16, 2025, the Department of Commerce announced that it initiated an investigation on April 1, 2025, under Section 232 of the Trade Expansion Act, into imports of semiconductors, semiconductor manufacturing equipment (SME), and related products to evaluate how those imports may impact national security.
Continue Reading Who is Stacking the Chips: U.S. Commerce Department Launches Section 232 Investigation into Semiconductor Imports
In the context of the tariffs imposed by the Trump Administration on imported goods, a prevalent misconception has arisen that foreign suppliers automatically bear the cost of these tariffs. The reality, however, is more complex. The actual payment of tariffs is significantly influenced by the specific contractual agreements between U.S. buyers and their foreign suppliers.
Continue Reading Understanding the Allocation of Tariff Payments
The first 100 days of President Trump’s second term have been action-packed with the President issuing 43 Executive Orders within hours of his inauguration – and an additional 46 that soon followed. Two Executive Orders in particular – Executive Order 14151, “Ending Radical and Wasteful Government DEI Programs and Preferences,” and Executive Order 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity,” – have received significant attention. These Orders mark a significant shift from prior administrations, and aim to redefine the role of DEI not only within the Federal Government, but also within the private sector. What follows is a brief
Continue Reading The Trump Administration’s Diversity, Equity, and Inclusion (DEI) Executive Orders: A Brief Primer
In Part 1 of our blog series, we outlined the Trump Administration’s new Executive Orders (“EOs”) on Diversity, Equity, Inclusion (“DEI”) and Diversity, Equity, Inclusion, and Accessibility (“DEIA”) programs, and the current legal status of those EOs. In this second part, we provide several observations on what actions federal contractors and grant recipients might want to consider taking in response to these EOs to ensure compliance and mitigate risks.
Continue Reading What Should Contractors and Grant Recipients do in Response to the DEI Executive Orders?