Sidley: New U.S. Export Controls on AI

The new export control regulations represent a significant shift in U.S. technology policy, introducing unprecedented controls on AI model weights and advanced computing infrastructure. By implementing complex licensing requirements and geographic restrictions, the regulations aim to prevent adversarial nations from accessing cutting-edge AI and computing technologies. The methodology involves a multi-pronged approach: expanding geographic coverage of existing controls, creating strategic exceptions for U.S. allies, implementing total processing power (TPP) quotas, and directly restricting exports of high-compute AI model weights. While these measures demonstrate a sophisticated attempt to manage technological diffusion, they also introduce substantial compliance burdens for technology companies and raise questions about implementation and enforcement of the nuanced quota systems.