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Spring 2025 Unified Agenda Outlines New AI Export Control Framework

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The Trump administration’s first Unified Agenda – the semi-annual report outlining regulatory plans for federal agencies – provides the first detailed look at its artificial intelligence (AI) export control priorities, particularly after the Commerce Department’s announced rescission on May 13, 2025, of the Biden-era AI Diffusion Rule.

Confirming this new direction, the Spring 2025 agenda proposes a replacement rule titled “Framework for Secure Sharing of Advanced AI Technology with Trusted U.S. Partners Worldwide.” Its stated goal is to secure core U.S. AI technology and advanced integrated circuits (ICs) while promoting innovation among trusted partners. According to the rule’s abstract, the administration views these controls as “critical for preventing or limiting the further development of weapons of mass destruction, advanced weapons systems, and high-tech surveillance applications that threaten U.S. national security.”

The framework is expected to formalize technology partnerships with key allies to ensure a unified approach. This “trusted partner” network will likely include nations with advanced technology sectors, such as Japan, the Netherlands, South Korea, and the United Kingdom, to harmonize export licensing and prevent the backfilling of restricted technologies to adversaries.

The proposal is officially in the Proposed Rule Stage, but the agenda’s target of August 2025 for a Notice of Proposed Rulemaking has already passed. This delay likely stems from the immense technical complexity of defining “advanced AI” and extensive inter-agency review between the Departments of Commerce, State, and Defense.

While developing this new AI framework, the administration is also finalizing other chip-related regulations. In a separate action, the Bureau of Industry and Security expects to issue a final rule next month implementing additional due diligence procedures for advanced computing ICs. This action will finalize two interim rules from 2024 to help key supply chain partners – notably semiconductor foundries and Outsourced Semiconductor Assembly and Test (OSATs) companies – with “Know-Your-Customer” due diligence, requiring exporters to more rigorously verify that their products are not being illegally diverted or transshipped through third countries to restricted end-users. This parallel action indicates a multi-faceted approach, with the administration simultaneously crafting a long-term strategy while completing more immediate, compliance-focused rules.

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