This week’s episode covers a GSA proposed rule on AI and large language models, an Executive Order on post-quantum cryptography, a recent GAO decision about protest filing deadlines, and the latest in the FAR overhaul, and is hosted by Peter Eyre and Yuan Zhou. Crowell &amp; Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government contracts legal and regulatory developments that no government contracts lawyer or executive should be without.

Fastest 5 Minutes: AI, Post-Quantum Cryptography, and FAR Overhaul

Fastest 5 Minutes, The Podcast Government Contractors Can’t Do Without

# Full Transcript

**Podcast:** Fastest 5 Minutes, The Podcast Government Contractors Can’t Do Without

## Transcript

Welcome to the Fastest 5 Minutes presented by Crowell & Moring LLP. We are your co-hosts for this edition, Peter Eyre and Yuan Zhou, bringing you a bi-weekly summary of significant government contracts, legal and regulatory developments that no government contracts lawyer or executive should be without.

We've got a packed episode, quite a bit to cover today. So we're going to be covering a new GSA proposed rule on AI and large language models, an executive order on post-quantum cryptography, a recent GAO decision that's really a cautionary tale on bid protest filing deadlines, and we're also going to cover the latest on the FAR overhaul.

Let's start with the FAR overhaul. Here's really the key headline. The FAR overhaul is officially moving from class deviation phase into formal rulemaking. On June 23rd, the FAR Council proposed the first tranche of proposed rules, covering 17 parts of the FAR. Everything from part one on the system itself, to parts five and six on how to publicize actions and the competition requirements.

And then we've got updates on part 40 on information security and supply chain security. So really this moves the overhaul from class deviations, which we've seen, and that's been in process for about a year, into a formal notice and comment rulemaking phase. Industry and government will have about 30 days to submit and review comments, with the comment period formally closing in mid-July.

There is a lot to get through here. It's about, you know, a thousand pages of proposed rules. In general, it seems that the proposed rules really track the class deviations, but there are some relatively minor differences, and there are a few examples where the proposed rules were carried forward from other prior publications.

So for example, there was a prior proposed rule on safeguarding CUI that would have been incorporated in the FAR. That had been dormant for a little bit. We're now seeing it brought forward into this proposed rule. So it's a mix of a few different things, but certainly an important milestone in the RFO process. Yuan, let me turn it over to you to talk about this GSA AI rule.

Definitely an important update from GSA that has been getting a lot of industry attention. On June 17th, GSA published a revised proposed clause that's titled, Basic Safeguarding of Data Within Large Language Model AI Systems. So this is a substantially reworked version of an earlier draft GSAR clause that was released in March.

And the revised clause is more narrowly tailored, and there are several key headlines we'll talk through today. So first let's focus on scope. The revised clause only applies where government data will be processed by a large language model, so an LLM.

It carves out LLMs that are embedded in common commercial products like word processors, navigation tools, and situations where LLM functionality is m...

Fastest 5 Minutes: AI, Post-Quantum Cryptography, and FAR Overhaul

Transcript

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Fastest 5 Minutes: AI, Post-Quantum Cryptography, and FAR Overhaul

Transcript

Built for investment professionals

Every day you wait, your competitors are findingedge in conversations you're not hearing.

Every day you wait, your competitors are finding
edge in conversations you're not hearing.