Joshua Gruenspecht

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Key Takeaways

  • The Executive Order, Promoting Advanced Artificial Intelligence Innovation and Security (Order), directs the creation of a framework for developers of advanced frontier models to engage with the federal government for a voluntary pre-release review of the models.
  • The Order also directs the Treasury Department, together with the National Security Agency (NSA) and Cybersecurity and Infrastructure Security Agency (CISA), to establish a clearinghouse to coordinate cyber vulnerability scanning, discovery, and patch distribution, in collaboration with private sector artificial intelligence (AI) and critical infrastructure companies.
  • CISA must issue Binding Operational Directives (BODs) and other guidance to expedite cyber defense of civilian federal systems and expand use of AI-enabled defensive tools.
  • The Order directs the Attorney General to prioritize prosecution of AI- and AI agent- facilitated computer crimes, identity theft offenses, and wire fraud schemes.
  • Developers considering engagement with the federal government for model pre-release review will need to assess the scope of pre-release access and the safeguards available during the early access window.
  • Companies seeking to become trusted partners should engage carefully with the U.S. government; those trusted partners may receive early access to covered frontier models, but also may be asked to disclose sensitive information and agree to continuing collaboration with the government.
Continue Reading Trump Administration Issues Executive Order on Advanced AI Innovation and Security

On July 23, 2025, the White House announced its long-awaited comprehensive AI Action Plan titled “Winning the AI Race: America’s AI Action Plan” (the Plan). The Plan is aimed at positioning the U.S. as the global leader in AI and is a follow up to President Donald Trump’s January 23, 2025, Executive Order on “Removing Barriers to American Leadership in Artificial Intelligence,” which revoked the Biden Administration’s prior AI Executive Order (Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence). The AI Action Plan contains more than 90 policy actions related to three key pillars: 1) Accelerating AI Innovation, 2) Building American AI Infrastructure, and 3) Leading in International AI Diplomacy and Security. This alert touches on all three pillars with a focus on the first, which outlines the Trump Administration’s strategic vision and policy recommendations to drive innovation in the American AI sector.

Continue Reading White House Releases America’s AI Action Plan

The recent omnibus foreign relations package signed by President Biden on April 24, 2024, includes the Protecting Americans’ Data from Foreign Adversaries Act of 2024 (the Act), a set of sweeping privacy provisions prohibiting data brokers from sharing sensitive personal information with a broad range of entities that may have ties to Russia, China, Iran, and North Korea. The Federal Trade Commission (FTC) will enforce these prohibitions and have the ability to seek civil penalties for violations. The provision takes effect 60 days after the date of enactment of the Act.

Continue Reading New Federal Data Broker Restrictions Signed into Law

On February 28, 2024, President Biden signed Executive Order 14117 (the Order) aimed at protecting Americans’ sensitive personal data and U.S. Government-related data from exploitation by “countries of concern.” This move constitutes a transformative overhaul in the U.S. approach to data regulation and creates the foundation for a comprehensive regulatory structure governing U.S. data.

Continue Reading New Executive Order Restricts Certain Cross-Border Transactions Involving Sensitive Personal Data of U.S. Citizens