Featured Articles
Buying Blind: Corruption Risk and the Erosion of Oversight in Federal AI Procurement,” 55 Public Contract Law Journal 175 (2026). Read the article on SSRN
How the government acquires AI today determines the integrity vulnerabilities it will inherit tomorrow. Missing audit rights, weak testing requirements, and opaque supply chains are acquisition-phase choices that become significant corruption risks in federal procurement.
Military AI Policy by Contract: The Limits of Procurement as Governance, Lawfaremedia.org (March 2026)
Over the past year, the United States has moved toward an AI governance model that is flexible yet profoundly inadequate: regulation by contract.
The GSA’s Draft AI Clause Is Governance by Sledgehammer, Lawfaremedia.org (March 2026)
The General Services Administration’s draft AI clause gets the governance problem right—then blows right past it.
“What rights do AI companies have in government contracts?” NextGov/FCW (March 2026)
It depends on the acquisition pathway, the contract type, and the contract terms.
Twenty-Five Cent AI: The Hidden Costs of Promotional AI Deals: The Future of Reasoned Decision-Making in Federal AI Procurement,68 GC ¶ 49 (March 2026).
GSA’s AI OneGov program offers loss-leader pricing low enough to accelerate adoption, while obscuring lifecycle costs, operational dependency, and diminished negotiating leverage at renewal
Governance as a “Blocker”: How the Pentagon’s New AI Strategy Trades Oversight for Speed, 68 GC ¶ 31 (February 2026).
The Pentagon just told its workforce that AI oversight tools are “blockers” and created a board to eliminate them. The article examines the implications for procurement integrity, contractor risk, and the acquisition workforce.
Abdicated Judgment: The Future of Reasoned Decision-Making in Federal AI Procurement,(Symposium on AI & the APA), Yale J. on Reg.: Notice & Comment (February 2026).
Federal agencies’ growing use of AI in source selections risks “abdicated judgment” by substituting opaque AI tools for the independent decision-making that the FAR and bid protest doctrine require for defensible source selection decisions.
Read HERE.
Books
- Routledge Handbook of Public Procurement Corruption (Sope Williams & Jessica Tillipman eds., Routledge, 2024). Chapter: “United States”
- Reform of the UNCITRAL Model Law on Procurement: Procurement Regulation for the 21st Century, 2010-2011 (Jessica Tillipman and Susan Arrowsmith eds., Eagan, MN: West, 2010).
Journal Articles
(Full Text of Scholarship is Available at SSRN)
“Buying Blind: Corruption Risk and the Erosion of Oversight in Federal AI Procurement,” 55 Public Contract Law Journal 175 (forthcoming Winter 2026).
“Canada’s Integrity Regime: The Corporate Grim Reaper,” 53 The George Washington University International Law Review 475 (2022).
“The Compliance Mentoring Program: Improving Ethics and Compliance in Small Government Contractors,” 49 Public Contract Law Journal 217 (2020) (reprint in Ethical Dilemmas in the Global Defense Industry, Oxford University Press) (with Vijaya Surampudi).
“The Congressional War on Contractors,” 45 The George Washington University International Law Review 235 (2013).
“A House of Cards Falls: Why ‘Too Big to Debar’ Is All Slogan and Little Substance,” 80 Fordham Law Review Res Gestae, 49-58 (2012).
“The Breakdown of the United States Government Purchase Card Program and Proposals for Reform,” Public Procurement Law Review (2003).
Book Chapters
“The Capacity Imperative: Professionalizing Public Procurement,” in Title TBD (Routledge, forthcoming 2026).
“US Debarment: An Introduction,” in The Cambridge Handbook of Compliance 288 (Benjamin van Rooij & D. Daniel Sokol eds., Cambridge Univ. Press, 2021) (with John Pachter & Christopher Yukins).
Essays, Opinion, and Other Publications
(Full Text of Other Publications is Available at SSRN)
“The GSA’s Draft AI Clause Is Governance by Sledgehammer,” Lawfaremedia.org (March 2026).
“Military AI Policy by Contract: The Limits of Procurement as Governance,” Lawfaremedia.org (March 2026).
“Twenty-Five Cent AI: The Hidden Costs Of Promotional AI Deals,” Gov’t Contractor ( March 2026).
“What rights do AI companies have in government contracts?” NextGov/FCW (March 2026).
“Abdicated Judgment: The Future of Reasoned Decision-Making in Federal AI Procurement,” (Symposium on AI & the APA), Yale J. on Reg.: Notice & Comment (February 2026).
“Governance as a “Blocker”: How the Pentagon’s New AI Strategy Trades Oversight for Speed,” 68 Gov’t Contractor ¶ 31 (February 2026).
“Feature Comment: Institutional Amnesia and the Neglect of the Federal Acquisition Workforce,” 67 Gov’t Contractor ¶ 182 (July 2025) (with Steven Schooner).
“The Cost of a Lie: Kousisis Affirms Criminal Fraud Liability Without Economic Harm,” On the Docket, Geo. Wash. L. Rev. on the Docket (Oct. Term 2024) (June 10, 2025).
“How to Procure AI Systems that Respect Rights,” Issues Sci. & Tech. at 12 (2024).
“Feature Comment: Don’t Let Post-Employment Conflicts Derail Your Contract Award,” 66 Gov’t Contractor ¶ 39 (2024) (with Bryan Dewan).
“Opinion, Using AI Risk to Reduce Performance Risk in U.S. Procurement,” Regul. Rev. (June 29, 2022).
“Schutte & Polansky: Shifting the Landscape of False Claims Act Litigation & Compliance,” Geo. Wash. L. Rev. on the Docket (Oct. Term 2022) (August 18, 2023) (with Teddie Arnold).
“Organizational Conflicts of Interest: Cautionary Tales,” Cont. Mgmt., Aug. 2022, at 24 (2022).
Opinion, “Trump’s Latest Ethical Violation: Firing the State Department’s Inspector General,” USA Today (May 22, 2020).
Opinion, “Pruitt May Be Gone, But Trump Administration’s Ethical Void Remains,” The Hill, (July 9, 2018) (with Kathleen Clark).
“Gifts, Hospitality and Government Contractors,” 14-7 Briefing Papers 1 (June 2014) (Thomson Reuters).
“Government Lawyering,” 11-2 Briefing Papers 1 (Feb. 2011) (Thomson West) (with Robert Mahini).
“The Foreign Corrupt Practices Act & Government Contractors: Compliance Trends & Collateral Consequences,” 11-9 Briefing Papers 1 (Sept. 2011) (Thomson West).
“Venture Capital Investment & Small Business Affiliation Rules: Why an Exemption is Crucial to Economic Recovery Efforts,” The Clause, Vol. 21, Issue No. 1 (December 2010) (reprint in NCMA Contract Management Magazine, February 2011) (with Damien Specht).
“Foreign Corrupt Practices Act Fundamentals,” 08-10 Briefing Papers 1 (Sept. 2008) (Thomson West), reprinted in The New Landscape of Government Contracting: From the Ethics Rule to the Recovery Act, Thomson West (2010).
“FCPA Enforcement in a Sarbanes-Oxley World,” Law Journal Newsletters: The Corporate Counselor, Vol. 20, No. 3, August 2005 (with Joseph Covington & Thomas Newkirk).
“Recovery of Attorney’s Fees Incurred in Defense of False Claims Act Litigation: The Best Briefs from the McKenna & Cuneo Government Contracts Moot Court Competition,” Public Contract Law Journal, (Summer 2002).