Compliance Stuff

On April 3, 2025, the White House Office of Management and Budget (OMB) released two memoranda, M-25-21 and M-25-22, regarding federal agencies’ use and acquisition, respectively, of artificial intelligence (AI) systems. Among other strategies oriented towards the Trump administration’s priorities of driving AI innovation,  M-25-21  and  M-25-22  require “covered agencies”—“any executive department, military department, Government corporation, Government controlled corporation, or other establishment in the executive branch of the Government … or independent regulatory agency,” subject to specific exclusions as set forth in 44 U.S.C. § 3502(1)—to (1) publish, by September 30, 2025, an AI Strategy identifying and removing barriers to responsible AI use, and (2) issue, by December 29, 2025, detailed policies setting the terms for acceptable use and procurement of AI. Several federal agencies—including the  U.S. Department of Homeland Security  (DHS),  U....

The rules surrounding government agency use of artificial intelligence (“AI”) have changed. On April 3 rd , 2025, in accordance with  President Trump’s January 23 rd  Executive Order  regarding AI, the Office of Management and Budget (“OMB”) issued  M-25-21  and  M-25-22 , reshaping how federal agencies must use, inventory, and buy AI technologies. These sweeping memoranda rescind and substitute the Biden-era OMB memos  M-24-10  and  M-24-18 , ushering in a full regulatory buildout that prioritizes US-developed AI, mandates risk assessments for AI that may have significant impacts on Americans, and introduces new source-selection and intellectual property (“IP”) language into Requests for Proposals (“RFPs”). M-25-21: How Agencies Must Use AI OMB Memorandum M-25-21 requires agencies to bring structure and transparency to how they use AI— not just in future programs, but  with AI tools currently in use as well .  By July 2 nd , 2...