With artificial intelligence becoming increasingly tied to national security issues, the U.S. Department of Commerce is establishing the American AI Exports Program as directed by Executive Order 14320, “Promoting the Export of the American AI Technology Stack.” The Program is key to America’s AI Action Plan, which was issued alongside E.O. 14320 and was developed to accelerate American AI innovation, build American AI infrastructure, and advance U.S. global leadership in AI through strategic exports.
The American AI Exports Program involves exporting the full AI stack — hardware, software, models, applications, and standards — to allies and partners in order to promote the global adoption of U.S. AI systems and standards.
Certain aspects of the Program are already in progress. Commerce created a new website, AIexports.gov, to connect U.S. companies with foreign partners. Commerce also outlined plans to utilize its commercial service, in conjunction with the State Department’s foreign service officers, to build support for this Program globally.
To determine how to best structure the American AI Exports Program, Commerce issued a Request for Information (RFI) in late October seeking comments from U.S. and global technology companies to better understand the needs of the industry and how to best achieve the Program’s intended policy outcomes. Responses to the RFI will inform Commerce’s request for proposals from industry-led consortia to deliver comprehensive, U.S.-origin AI systems designed to be exported as complete, end-to-end solutions to selected countries and regions. The Secretary of Commerce, in consultation with the Secretary of State, Defense, Energy, and the Director of the Office of Science and Technology Policy, will then select proposals to be designated as priority AI export packages, which will be supported through priority access to federal financing and other tools.
The RFI requests the following information from industry participants to help establish the parameters of the Program:
- How to define an AI stack and evaluate its components;
- Who should participate in the industry-led consortia;
- How these consortia should be formed and governed;
- How much foreign involvement should be allowed in the Program;
- Specific target countries or regional blocs identified for export engagement and appropriate ways to support the global deployment of American AI technologies;
- How the entities that will build, own, and operate data centers should be structured;
- Which U.S. federal support mechanisms would be most useful for the consortia;
- Other factors that should be considered to maximize the benefits of the Program for U.S. national security; and
- How proposals should be evaluated by Commerce and the other agencies.
Commerce also requests comments on any additional aspects of the proposal process or the Program at large.
The deadline to provide comments is December 13, 2025. Comments may be submitted through Regulations.gov (Docket Number ITA-ITA-2025-0070) or through the newly created American AI exports website.
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Cassidy Levy Kent’s attorneys, compliance professionals, economists, and licensed customs brokers assist clients navigating export controls and sanctions issues. We expect further developments in this space and will continue to provide updates. Please contact us with any questions.