US Export Control 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.

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.

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.

@dang

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.

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.

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

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.

> The US is moving toward a system where government controls and throttles technology and picks winners

What else can it do? They don’t want to lose their lead, and whatever restrictions they’ve been putting on China et al. have let the exact desired outcomes so far. The idea is to try to slow down the beast that has very set goals (e.g. to become high tech manufacturing and innovation center), and try to play catch up (like on-shoring some manufacturing).

Personally, I’m skeptical that it will work, because by raw number of hands on deck, they have the advantage. And it’s fairly hard when your institutional knowledge of doing big things is a bit outdated. I would argue, a good bet in North America would be finding a financially engineered solution to get Asian companies bring their workers and knowledge to ramp us up. Kinda like the TSMC factory. Basically the same thing as China did in 2000s with western companies.

> The US is moving toward a system where government controls and throttles technology and picks winners.

Moving towards? The US has a pretty solid history of doing a great deal of this (and more) in the 20th century. But so did all of the world's powers... as they all continue to do today. It seems to be an inherent part of being a world power.

I agree this law won’t be effective in its intended purpose, and that China will develop models of their own that are sufficiently competitive (as we’ve already seen). However, I think seeking “peaceful collaboration” between the US (or Europe or many others) and China - either between governments or private firms - is a naive strategy that will simply lead to the US being replaced by a more dangerous superpower that does not respect the values of free and democratic societies.

I also think that to a great extent, we’re already at war. China has not respected intellectual property rights, conducted espionage against both companies and government agencies, repeatedly performed successful cyberattacks, helped Russia in the Ukraine conflict, severed telecommunications cables, and more. They’ve also built up the world’s largest navy, expanded their nuclear arsenal, and are working on projects to undermine the status of the US Dollar. All of this should have been met with a much stronger and forceful reaction, since clearly it does not fit into the notion of “peaceful collaboration”.

China’s unpeaceful actions aren’t limited to the West. China annexed much of its current territory illegally and through force (see Xinjiang and Tibet). When Hong Kong was handed back, it was under a treaty that China now says is not valid. China has been trying to steal territory from neighboring countries repeatedly, for example with Bhutan or India. They’ve also threatened to take over Taiwan many times now, and may do so soon. They’re about to build a dam that will prevent water from reaching Bangladesh and force them to become subjugated. The only peaceful and just outcome is for those territories to be freed from the control of China - which will require help from the West (sanctions, tariffs, blockades, and maybe even direct intervention).

Even within China, the CCP rules with an iron fist and violates virtually all principles of free societies and classically liberal values that we value in the West. I don’t see that changing. And if it doesn’t, how can they be trusted with more economic and military power? That’s why I don’t think we should seek peaceful collaboration with China. We just need smarter strategies than this hasty AI declaration.

I don't think you're wrong but Big Tech is bending the knee to Trump because he will be picking the winners.

Only in some diplomatic contexts.

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