The U.S. Department of Commerce has announced the launching of the American AI Exports Program. This initiative is part of a larger effort by President Donald Trump to advance the United State’s leadership in advanced technologies. The program will include hardware, software, applications, models, and full stack AI export. Full Stack AI refers to a comprehensive approach of building applications that utilize artificial intelligence across all layers of development.
Department of Commerce Export Promotion for AI
The Department of Commerce has launched a Request for Information (RFI) site to invite public comments from the artificial intelligence and the science and technology sectors. Feedback and proposals received from the RFI will be evaluated by the Secretary of State, the Secretary of War, the Secretary of Energy, and the Director of the Office of Science and Technology Policy.
The interagency Economic Diplomacy Action Group will support qualified full stack AI package exports upon final approval. The Department of Commerce will continue to provide updates as implementation progresses. Commerce will also launch a new website to facilitate communication between potential foreign buyers and American AI technology providers. Additionally, Commerce will partner its leverage with the Department of State to support this advance of America’s global leadership internationally.
Export Import Bank Involvement
The Export Import Bank of the United States (EXIM) is making use of its financing tools to finance exports of transformational technology sectors. This effort will help companies developing AI to compete in global markets. The agency is encouraging U.S. AI companies to explore opportunities for financing their development of American AI Export.
Export Controls on Advanced Technologies
Organizations engaged in the export of advanced technologies including AI should be mindful that stringent export regulations are still in place for this sector. AI integrated circuits and associated articles, commodities, services and technical data are controlled under the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR).
Parties that engage in transactions without prior authorization from the Directorate of Defense Trade Controls or the Bureau of Industry and Security are subject to possible criminal and civil penalties if violations occur. These transactions include the export, reexport, or in-country transfers of regulated commodities. It is important, therefore, to conduct classifications, denied parties screening, and to ensure appropriate end-use in the case of dual use items.
The BIS has released Industry Guidance to Prevent Diversion of Advanced Computing Circuits. This document contains a revised set of red flags that organizations should use to screen potential transactions.
CVG Strategy Export Compliance Management Programs
Organizations involved with export must adhere to regulations regardless of export regulations effectiveness. Remaining informed and having an effective export compliance program is essential for avoiding criminal and civil penalties.
Export Compliance Management Programs establish clearly defined policies and procedures for all departments within an organization. They ensure that registration, item classifications, license applications, denied part screening, and security measures are taken that will prevent violation. They also ensure that training, auditing, and record keeping are maintained according to requirements.
CVG Strategy can help you understand revisions to the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR), and help you establish a coherent and effective export compliance program. We can perform export control classifications, perform audits, assist in filings for export licenses and educate your team. Regardless of whether your business falls under EAR or ITAR, CVG Strategy has the expertise to help.