On January 13, 2025, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") issued an interim final rule that significantly expands export controls around artificial intelligence ("AI") and advanced computing chips.
On January 13, 2025, the U.S. Department of Commerce's
Bureau of Industry and Security ("BIS") issued an interim final rule that significantly expands
export controls around artificial intelligence ("AI") and
advanced computing chips. Entitled "Framework for Artificial
Intelligence Diffusion," these new rules restrict the export,
reexport, or in-country transfer of sophisticated AI models by
requiring a license to export the most advanced closed-weight AI
models. Model weights, numerical values that represent the strength
of the connections between variables in an AI model, will now be
controlled by U.S. export controls even where those model weights
are for an AI model that was: (1) trained entirely outside the
United States, (2) by non-U.S. personnel, and (3) using cloud
computing centers outside the U.S. Indeed, these new rules govern
the export of any AI model trained above
a certain level of computational operations using advanced
integrated chips subject to U.S.
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