On October 21, 2025, the US Department of Commerce’s International Trade Administration (“ITA”) announced the implementation of the July 23, 2025 Executive Order (“EO”) Promoting the Export of the American AI Technology Stack (the “American AI Exports Program”). Following our earlier post addressing the White House’s AI Action Plan and the EO, this update focuses on the implementation of the EO and the ITA’s request for public feedback.
As a reminder, the EO directs the Secretary of Commerce, in consultation with the Secretary of State and the Director of the Office of Science and Technology Policy (OSTP), to establish the American AI Exports Program and call for proposals from industry-led consortia. As part of the launch of the AI Exports Program, the ITA has issued a Request for Information (“RFI”) with the goal of eliciting input from US and non-US technology companies, trade associations, potential buyers of US AI exports, and other interested parties.
The RFI is broken into nine sections, A–I (surely just a coincidence), and 28 questions, seeking information on, among other things:
- Whether the EO’s description of what the components of a “full-stack” AI technology package is clear or needs to be expanded;
- How each component of that stack should be evaluated when included in a proposal (i.e., what factors should be considered for each component);
- What challenges an industry consortium might face in developing a proposal that includes all the elements of a full-stack AI technology package;
- Who should participate in such consortia and how should they be formed and governed, in particular, to what degree should non-US entities and countries be able to be involved;
- Which countries or regions should US AI exports promotion target;
- Different business, operational, and ownership models that the US government should prioritize when selecting consortia proposals;
- What support mechanisms from the government would be most effective (e.g., direct loans, loan guarantees, equity investments, co-financing, political risk insurance, credit guarantees, technical assistance); and
- How to ensure that the promotional efforts comply with US export controls, outbound investment restrictions, and other national security regulations while also advancing US AI exports in order to decrease international dependence on AI technologies developed by so-called “countries of concern” (e.g., China).
The official publication date of the RFI in the Federal Register remains uncertain, given the ongoing government shutdown. Parties interested in submitting comments on the RFI will have 30 days to do so once the RFI is published.
The Department of Commerce also announced a new website, aiexports.gov, and plans to establish an integrated American AI export team, all to facilitate engagement between interested US companies and trusted foreign buyers. For now, the website directs interested parties to fill out the RFI.
We will continue to monitor and comment on policy, legal, and regulatory developments in the AI space and their impacts on export controls, national security, and sanctions matters.
