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.