Regulatory Consulting at Crowell & Moring (Gov Contracts + AI)

Overview

Crowell & Moring occupies a distinctive niche in the AI-policy landscape: it pairs a leading government-contracts practice with active AI regulatory work, putting it at the point where federal procurement policy and emerging AI rules intersect. The firm publishes closely followed client alerts tracking how federal and state regulators are actually moving against AI harms — an area where enforcement has advanced faster than general AI legislation. Its analysis of the TAKE IT DOWN Act is representative: passed with bipartisan support in late spring 2025, the law makes it a federal crime to knowingly publish non-consensual intimate imagery of minors or non-consenting adults, including ‘digital forgeries’ created through AI, and requires covered platforms to establish notice-and-removal processes by May 19, 2026, taking down offending content within 48 hours of a victim’s request, with FTC enforcement authority. Crowell identified it as the first federal law to limit AI use in ways harmful to individuals — a milestone for anyone tracking when AI policy became binding law rather than framework guidance. That combination of procurement depth and regulatory tracking makes the firm useful for understanding both how government buys AI and how it polices it.

AI-Focused Regulatory Work

Crowell’s contribution to the AI-policy conversation is precision about enforcement mechanics — the unglamorous details that determine whether a law changes behavior. Its work on federal and state regulators targeting AI chatbots and intimate imagery lays out exactly what the TAKE IT DOWN Act requires of covered platforms: a functioning notice-and-removal process standing by the May 2026 deadline, 48-hour takedown windows, and significant compliance burdens falling on any website, online service, or mobile application within scope. The firm situates this in history, noting that AI-generated non-consensual intimate imagery long predates the current wave — the very forum that popularized the term ‘deepfakes’ was distributing AI-manipulated imagery of public figures — and that a series of high-profile incidents, including in American schools, built the political coalition behind federal action. For a directory reader, this is where AI policy stops being a debate about frameworks and becomes a concrete compliance obligation with an FTC enforcer attached. Paired with Crowell’s government-contracts practice, the firm covers both halves of the public-sector AI question: how agencies procure and deploy AI systems under federal acquisition rules, and how regulators pursue AI-enabled harms once those systems are in the world. It is a narrower lane than the full-service firms, but a consequential one, and it sits directly on the procurement-plus-AI intersection that matters most for anyone working on government AI policy.

Notable AI Policy Work

• Published ‘Federal and State Regulators Target AI Chatbots and Intimate Imagery,’ analyzing the TAKE IT DOWN Act — identified as the first federal law limiting AI use in ways harmful to individuals.
• Detailed the Act’s compliance mechanics: covered platforms must build notice-and-removal processes by May 19, 2026 and remove offending imagery within 48 hours of a victim request, with FTC enforcement authority.
• Combines a leading government-contracts practice with AI regulatory advisory, covering how federal agencies procure and deploy AI under federal acquisition rules.
• Tracks state-level regulatory action against AI chatbots and AI-generated content alongside federal enforcement developments.
• Advises clients on emerging-technology compliance where procurement obligations and AI-specific regulation intersect.

Thought Leadership

1. Federal and State Regulators Target AI Chatbots and Intimate Imagery
   Analyzes the TAKE IT DOWN Act — the first federal law limiting harmful AI use — and the notice-and-removal compliance burden it places on covered platforms by May 2026.
2. Crowell & Moring — insights & client alerts
   The firm’s ongoing alerts at the intersection of government contracts, emerging technology, and AI regulation.

Clients

Serves federal contractors and technology companies at the intersection of government procurement and AI regulation, plus covered platforms navigating new federal content-removal obligations. Specific engagements are largely confidential.