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National Security Memorandum Aims to Accelerate Deployment of AI and Streamline Procurement Aligned to Administration Policies

By Alexandra Barbee-Garrett, Stephanie Crawford, Matthew Ferraro & Jacob Harrison on June 16, 2026
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On June 5, 2026, President Trump issued National Security Presidential Memorandum (NSPM) 11 (NSPM-11) to accelerate AI adoption by the U.S. military and intelligence agencies. It directs updated AI management, acquisition, and use policies and seeks to compel AI companies to comply with Trump administration policies.  It calls for expanded training and enhanced security in collaboration with the private sector and orders the “termination for default or for convenience” of government contracts with AI companies that wish to limit how the government uses their products. NSPM-11 could also herald a major change in autonomous warfighting policy by directing the update of the Pentagon’s primary directive on autonomous weapon systems.

Taken together with recent administration moves, including the issuance of an executive order on June 2, 2026, establishing a voluntary regulatory regime for cutting-edge AI models, NSPM-11 signals a continued effort to assert the administration’s far-reaching AI policy through executive action.

Link to Details of NSPM 11 Details of NSPM 11

Policy (Section 2). NSPM-11 sets out four pillars to accelerate the development and use of AI for national security purposes: adoption, adaptation, assurance, and accountability. 

  • Adoption: The national security enterprise must identify where AI can enhance effectiveness, remove barriers to adoption, and “maintain deep, proactive partnerships with industry” to ensure the government can quickly access cutting-edge models.
  • Adaptation: The national security enterprise must adapt commercial or open-source AI from many suppliers and share solutions (including non-commercial AI models) across the national security enterprise.
  • Assurance: The AI on which the national security enterprise relies must be “reliable, robust, steerable, and controllable,” and operate under law and policy. The national security enterprise must also use contract clauses to “ensure” that “no commercial entity or adversary possesses the capability to prevent use of, disable or degrade, or materially modify” an AI system and must test the systems for security and reliability, among others.
  • Accountability: NSPM 11 bars the national security enterprise from developing or using AI to “censor free speech, embed ideological bias, or conduct unauthorized or unlawful surveillance activities.” Military commanders and agency directors are accountable for keeping pace with regulations governing Americans’ privacy and civil liberties.

Updated Policies and Guidance (Section 3). NSPM-11 directs the secretary of war to update the Pentagon’s primary directive governing autonomous weapons systems, DoD Directive 3000.09, within 90 days and review it annually. It also directs the secretary of war, the director of national intelligence (DNI), and the heads of relevant agencies to direct “to the maximum extent permissible by law, termination for default or for convenience contracts with companies that have repeatedly demonstrated a pattern of conduct that is inconsistent with policies” enunciated in Section 2 of NISPM-11. The NSPM also directs the Committee on National Security Systems (CNSS) and the director of the Office of Management and Budget (OMB) to issue policy for governance of AI use in national security systems and rescinds National Security Memorandum-25, signed by former President Biden in October 2024.

Advancing National Security Capabilities (Section 4). NSPM-11 aims to accelerate the national security enterprise’s adoption of and access to AI resources, including by:

  • Directing the secretary of war and the Intelligence Community (IC) within 120 days to review and update procurement processes to ensure rapid onboarding of advanced AI models.
  • Directing White House officials within 90 days to develop a government-wide roadmap to ensure adequate access to advanced computing resources, including commissioning high-security AI computing facilities and establishing a dedicated AI test range for national security use cases. 

Additionally, NSPM-11 directs the Pentagon, the U.S. Department of Energy (DOE), and the IC to, within 120 days, develop partnerships with “willing” private-sector companies to help secure cutting-edge AI technologies, including by sharing threat intelligence, conducting joint red-team exercises, assisting with personnel vetting, supporting joint R&D, and enhancing the physical and cyber security of data centers.  While this effort—like the AI Cybersecurity Clearinghouse proposed in the executive order signed June 2—is voluntary, the administration intends to use these partnerships to facilitate R&D that the private sector “cannot undertake alone.”

Building Capacity for AI Adoption (Section 5). This section will likely impact AI procurement by the national security enterprise in several ways.

  • Within 120 days, the Pentagon, the director of the National Security Agency (NSA), and DNI must develop a joint AI risk management and assurance strategy to establish baseline AI security practices for national security use cases.
  • Also within 120 days, the Pentagon, the NSA Director, and DNI must develop standardized AI national security Test, Evaluation, Verification, and Validation (TEVV) methodologies, accounting for classification levels. These TEVV methodologies will be submitted to the White House for review prior to publication “where appropriate.”
  • NSPM-11 directs all federal agencies to prioritize R&D of technologies enabling AI “reliability,” “robustness,” “steerability,” and “controllability,” as defined in the NSPM.

Separately, Section 5 proposes the creation of an AI National Security Strategic Reserve, which will use private-sector AI talent to support federal efforts to address AI national security issues on an as-needed basis.  The mechanisms by which this strategic reserve will be created are not explained, raising questions about the terms under which private-sector personnel and proprietary knowledge may be accessed, and whether participation will become, formally or informally, an expectation of doing business with the Pentagon and the IC.

Tags: AI
Photo of Alexandra Barbee-Garrett Alexandra Barbee-Garrett

Alexandra Barbee-Garrett is a counsel in Crowell & Moring’s Washington, D.C. office, where she practices in the Government Contracts Group.

Alex helps companies navigate the complex requirements around doing business with the U.S. government, with a particular focus on government contracts and grants

…

Alexandra Barbee-Garrett is a counsel in Crowell & Moring’s Washington, D.C. office, where she practices in the Government Contracts Group.

Alex helps companies navigate the complex requirements around doing business with the U.S. government, with a particular focus on government contracts and grants compliance issues, government ethics, and lobbying laws. Her practice spans a broad range of counseling, investigatory, and litigation matters, including: compliance reviews and enhancing contractor compliance programs; representing clients in suspension and debarment proceedings; counseling on supply chain security and sourcing issues; voluntary and mandatory disclosures; internal investigations related to the False Claims Act, the Procurement Integrity Act, and other civil and criminal matters; and bid protest and claim litigation. Alex also helps clients understand developing legislative requirements in the supply chain and government contracting spaces.

Prior to joining Crowell & Moring, Alex was a law clerk to Judge Richard A. Hertling of the U.S. Court of Federal Claims. Before law school, Alex worked as a health care legislative assistant for Rep. Rick Larsen (WA) in the U.S. House of Representatives.

Read more about Alexandra Barbee-GarrettEmail
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Photo of Stephanie Crawford Stephanie Crawford

Stephanie Crawford is a trusted counselor to a broad range of industries facing reorganizations, transactions, national security issues, and questions of supply chain management. Stephanie provides related mergers and acquisitions, counseling, litigation, international arbitration, and investigations services to clients in the aerospace and

…

Stephanie Crawford is a trusted counselor to a broad range of industries facing reorganizations, transactions, national security issues, and questions of supply chain management. Stephanie provides related mergers and acquisitions, counseling, litigation, international arbitration, and investigations services to clients in the aerospace and defense, communications, energy, information technology, and consumer products sectors.

Stephanie has substantial experience with both buy-side and sell-side transactions. She has led government contracts diligence for numerous private equity entities and defense contractors. She assists clients with navigating post-closing government requirements, including unique license transfers and approvals; novation and change of name regulations; and Defense Counterintelligence and Security Agency communications and foreign ownership, control, and influence (FOCI) mitigation.

Stephanie counsels clients on supply chain, sourcing, and national security regulations and requirements. Such counseling includes compliance with the Defense Production Act, including priority orders, ratings and associated regulations; the Public Readiness and Emergency Preparedness Act; and National Industrial Security Program Operating Manual (NISPOM) regulations. She is also known for her ability to solve immediate and business-threatening System for Award Management (SAM) and Defense Logistics Agency (DLA) CAGE Code problems.

Stephanie defends government contractors facing potential tort litigation with a nexus to their government contracts and facing supply chain and national security-related investigations, litigation, and arbitrations.

Stephanie’s pro bono practice focuses on a broad range of veterans’ issues, including disability ratings and discharge upgrades

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Photo of Matthew Ferraro Matthew Ferraro

Matthew F. Ferraro is a partner in Crowell & Moring’s Privacy and Cybersecurity Group, where he helps clients address complex regulatory matters at the intersection of advanced technology, national security, and crisis management. He advises leading organizations on high-impact matters related to artificial

…

Matthew F. Ferraro is a partner in Crowell & Moring’s Privacy and Cybersecurity Group, where he helps clients address complex regulatory matters at the intersection of advanced technology, national security, and crisis management. He advises leading organizations on high-impact matters related to artificial intelligence (AI) and other emerging technologies, cyberattacks, domestic and international privacy compliance, internal investigations, foreign direct investment reviews, and high-stakes crises.

Before joining the firm, Matthew served as the Senior Counselor for Cybersecurity and Emerging Technology to the Secretary of Homeland Security. As a principal advisor to the Secretary and a member of the U.S. Department of Homeland Security’s leadership team, he served at the heart of U.S. government policymaking around AI and cybersecurity. He assisted in the development and drafting of key AI, cyber, and technology policies and regulations; advised on the deployment of AI to fulfill the department’s missions; and counseled on cyber-incident responses and investigations. Matthew also helped establish and served as the Executive Director of the Artificial Intelligence Safety and Security Board, a flagship public-private advisory committee focused on AI’s use in critical infrastructure and chaired by the Secretary and composed of industry, nonprofit, and government luminaries.

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Photo of Jacob Harrison Jacob Harrison

Jacob Harrison helps his clients navigate both domestic and international legal challenges.

Jake advises U.S. government contractors on internal investigations and state and federal regulatory compliance. His compliance practice focuses on counseling clients operating at the intersection of government contracts and cybersecurity, including

…

Jacob Harrison helps his clients navigate both domestic and international legal challenges.

Jake advises U.S. government contractors on internal investigations and state and federal regulatory compliance. His compliance practice focuses on counseling clients operating at the intersection of government contracts and cybersecurity, including for cybersecurity compliance reviews, risk assessments, and data breaches.

In his international practice, Jake represents foreign and domestic clients in Foreign Sovereign Immunities Act and Anti-Terrorism Act litigation. He also has experience advising clients involved in cross-border commercial arbitration proceedings.

During law school, Jake served as an associate editor of the Emory Law Journal and interned at the Supreme Court of Georgia and the Georgia House Democratic Caucus. Before attending law school, Jake worked in politics and state government.

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  • Posted in:
    Government and Public Policy, Technology and AI
  • Blog:
    Government Contracts Legal Forum
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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