Overview
On October 21, 2025, the US Department of Commerce's International Trade Administration (ITA) announced the launch of the American AI Exports Program ("the Program"), as directed by President Trump's July 23, 2025 Executive Order 14320 (the EO), Promoting the Export of the American AI Technology Stack. The EO, which set a 90-day deadline for establishing the Program, is intended to support the development and deployment of United States full-stack artificial intelligence (AI) export packages. As described in the EO, a full-stack package includes hardware (e.g., chips, servers, and accelerators); software (e.g., AI models and security/cybersecurity systems); technology, including data pipelines and labeling systems; and services (e.g., data center storage, cloud, and networking services).
The Program, which was first announced in President Trump's AI Action Plan, fits within the administration's broader approach to AI and, in particular, a desire to see other countries use AI systems built on US technology with US values and US security controls. The Action Plan notes that the Program will help prevent other countries from "turn[ing] to our rivals."
RFI
The Program’s implementation is beginning with a Request for Information (RFI) which seeks input from US and international technology companies to inform the final structure and content of the Program. The RFI presents questions on a number of topics, including:
- The components of the full-stack package (as listed above), including whether the components should be expanded upon and how to evaluate each component in a proposal;
- The industry-led consortia mandated by the EO, including formation, membership, and governance;
- Ways to support the global deployment of American AI technologies;
- Business and operational models, including which models should be prioritized for inclusion in the approved consortia;
- Federal support mechanisms pursuant to the Program, including which mechanisms would be most useful to approved consortia;
- National security regulation compliance mechanisms, including factors that should be taken into account to ensure activities under the Program comply with US export controls and other national security laws; and
- How to evaluate proposals for inclusion under the Program, including factors to be used for evaluation.
Comments are due by November 28, 2025.
Proposals
Following closure of the RFI comment period, the Department of Commerce will issue a call for proposals from industry-led consortia to establish full-stack AI export packages. These proposals will be evaluated by the Secretary of Commerce in consultation with the Secretary of State, the Secretary of War, the Secretary of Energy, and the Director of the Office of Science and Technology Policy. Proposals approved through the Program will receive federal support, including through the interagency Economic Diplomacy Action Group for qualified export opportunities.
AI Exports Website
In conjunction with the Program, the Department of Commerce will launch a new website, AIexports.gov, and establish an integrated American AI export team. The new website will bolster the international presence of the Program by facilitating connections between US companies and "trusted foreign buyers."
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For more information, please contact a member of Steptoe's Artificial Intelligence Practice or Export Controls Practice.
