Framework for Artificial Intelligence Diffusion

  "First, it assumes that scaling models automatically leads to something dangerous"

This is an appropriate restriction on what will likely be a core part of military technology in the coming decade (eg drone piloting).

Look, if Russia didn't invade Ukraine and China didn't keep saying they wanted to invade Taiwan, I wouldn't have any issues with sending them millions of Blackwell chips. But that's not the world we live in. Unfortunately, this is the foreign policy reality that exists outside of the tech bubble we live in. If China ever wants to drop their ambitions over Taiwan then the export restrictions should be dropped, but not a moment sooner.

> Even if future amendments try to address test-time compute, the proposed regulation seems premature. There are too many unknowns in future AI development to justify using a fixed compute-based threshold as a reliable indicator of potential risk.

I'm disinclined to let that be a barrier to regulation, especially of the export-control variety. It seems like letting the perfect be the enemy of the good: refusing to close the barn door you have, because you think you might have a better barn door in the future.

> Instead of focusing on compute thresholds or model sizes, policymakers should focus on regulating specific high-risk AI applications, similar to how the FDA regulates AI software as a medical device. This approach targets the actual use of AI systems rather than their development, which is more aligned with addressing real-world risks.

How to you envision that working, specifically? Especially when a lot of models are pretty general and not very application-specific?

> First, it assumes that scaling models automatically leads to something dangerous.

The impression I had is with reversed causation: that it can't be all that dangerous if it's smaller than this.

Assuming this alternative interpretation is correct, the idea may still be flawed, for the same reasons you say.

While your critiques most likely have some validity (and I am not positioned to judge their validity), you failed to offer a concrete policy alternative. The rules were undoubtedly made with substantial engagement from the industry and academic researchers, as there is too much at stake for them not to engage, and vigorously. Likely there were no perfect policy solutions, but decided to not let the perfect stop the good enough since timeliness matters as much or more than the policy specifics.

> these rules risk stifling innovation

These rules intentionally "stifle innovation" for foreigners - this is a feature, not a bug.

You wrote three separate comments for this course. Can you just combine them?

Traditional export control applied to advanced hardware is because the US doesn't want its adversaries to have access to things that erode the US military advantage. But most hardware is only controlled at the high-end of the market. Once a technology is commodotized, the low-end stuff is usually widely proliferated. Night vision goggles are an example, only the latest generation technology is controlled, and low-end stuff can be bought online and shipped worldwide.

Applying this to your thoughts about AI, is that as the efficiency of training gets better, the ability to train models is commodotized, and those models would not be considered to be advantageous and would not need to be controlled. So maybe setting the export control based on the number of operations is a good idea- it naturally allows efficiently trained models to be exported since they wouldn't be hard to train in other countries anyway.

As computing power scales maybe the 10^26 limit will need to be revised, but setting the limit based on the scale of the training is a good idea since it is actually measurable. You couldn't realistically set the limit based on the capability of the model since benchmarks seem become irrelevant every few months due to contamination.

The practical problem I see is that unless US AI labs have perfect security (against both cyber attacks and physical espionage), which they don’t, there is no way to prevent foreign intelligence agencies from just stealing the weights whenever they want.

>The most salient thing in the document is that it put export controls on releasing the weights of models trained with 10^26 operations.

Does this affect open source? If so, it'll be absolutely disastrous for the US in the longer term, as eventually China will be able to train open weights models with more than that many operations, and everyone using open weights models will switch to Chinese models because they're not artificially gimped like the US-aligned ones. China already has the best open weights models currently available, and regulation like this will just further their advantage.

Could be nice with some artificial pressure to use more efficient algorithms though. The current game of just throwing in more data centers and power plants may be kind of convenient for those who can afford it, but it's also intellectually embarrassing.

this is like saying that regulating automatic weapons is misguided because someone might invent a gun that is equally dangerous without being automatic

We can't let perfect be the enemy of good, regulations can be updated. Capping FLOPs is a decent starter reg.

And don't forget the amazing workaround Zimmerman of PGP fame came up with - the source code in printed form was protected 1A speech, so it was published, distributed, and then scanned and OCR'd outside the US - https://en.wikipedia.org/wiki/Pretty_Good_Privacy#Criminal_i...

It hampered the security of a lot of things. That wasn't misguided -- that was the point.

China, Russia, and Iran used Internet Explorer too.

I see the return of cold war computing model, where many countries had their own computer platforms and programming languages.

Which apparently might be a good outcome to FOSS operating systems, with national distributions like Kylin.

As European I vote for SuSE.

Someone still sees Eastern Europe as a provider of cheap brainpower. This is insulting.

This smells about as well informed as the genius move that forced Ukrainian owner, Max Polyakov, to divest from Firefly Aerospace. A US government position that was widely derided by space industry watchers, and has now been reversed.

This might be a product of the USA being a gerontocracy.

includes (among others) a bunch of countries that would normally be seen as close US allies - e.g. some NATO countries (most of Central/Eastern Europe).

Yeah, this is really a bit insulting.

Obviously to prevent proliferation of dual-use technologies to potentially adversarial actors. The same intent behind restricting high-fidelity infrared camera and phased radar equipment.

Maybe they intend for it to speed up/start implementation of federal agencies and regulations. The intent is to exert control over an emerging market while it’s still comprised of cooperative participants. Regulators want to define the regulatory frameworks rather than relying on self-policing before it’s “too late.”

Let’s see if this survives the next administration. Normally I’d be skeptical, but Musk has openly advocated about the “dangers” of AI and will likely embrace attempts to regulate it, especially since he’s in a position to benefit from the regulatory capture. In fact he’s doubly well-placed to take advantage of it. Regardless of his politics, xAI is a market leader and would already be naturally predisposed to participate in regulatory capture. But now he also enjoys unprecedented influence over policymaking (Mar a Lago) and regulatory reform (DOGE). It’s hard to see how he wouldn’t capitalize on that position.

Not the same situation at all. PGP would run on any computer you happened to have around. The source code was small enough to fit in a book. The people who already had the code wanted to release it. Lots of people could have rewritten it relatively quickly.

The ML stuff they're worried about takes a giant data center to train and an unusually beefy computer even to run. The weights are enormous and the training data even more enormous. Most of the people who have the models, especially the leading ones, treat them as trade secrets and also try to claim copyright in them. You can only recreate them if you have millions to spend and the aforementioned big data center.

Only in some diplomatic contexts.

https://www.cia.gov/the-world-factbook/countries/taiwan/