Introducing Our Series on the AI Action Plan and America’s Evolving AI Posture
On July 23, 2025, the White House unveiled America’s AI Action Plan, marking a significant policy turn toward unleashing U.S. innovation, advancing domestic AI infrastructure, including data centers and chip manufacturing, and using export controls and trade tools to strengthen AI leadership abroad. The Action Plan (the Plan), along with a trio of executive orders promoting exports of the U.S. AI technology stack, streamlining permitting for AI-related U.S. domestic infrastructure and restricting “woke AI” in federal systems, reflects the operationalization of the Trump administration’s broader “America First” investment and trade strategy. Through these actions, the U.S. administration seeks to pursue several significant objectives: advance AI innovation and domestic infrastructure through deregulation; feed global demand for AI with the U.S. technology stack; shape global AI standards based on U.S. technology and administration preferences; and deny exploitation of U.S. AI technology and systems by foreign adversaries through robust export controls and appropriate security measures.
In many ways, the administration’s moves deregulate AI development while tightening rules around the export of that technology. The Plan directs agencies to dismantle prior AI compliance frameworks, revise the National Institute of Standards and Technology (NIST) AI Risk Management Framework (RMF), and withdraw Biden-era AI-related executive orders. This dual-track strategy blends export restrictions and intelligence-enabled enforcement with domestic efforts to remove perceived innovation barriers, especially in semiconductors, cloud infrastructure, and high-performance computing (HPC). The Plan simultaneously emphasizes open-source and open-weight model development, location-verified chips, expanded “Know Your Compute” protocols, robust use of Foreign Direct Product Rules (FDPRs) to assert U.S. enforcement authority worldwide, coordination of standards, security, and export controls among allies, and a fast-track program for export of “full stack” U.S. technology AI systems that integrate appropriate security and export controls.
In this series, Alvarez & Marsal brings together experts from its Investigations and Compliance, AI and Analytics, and National Security, Trade, and Technology practices to examine the implications of this evolving framework. From enforcement risk mitigation to data-center design and security integration and international licensing, the A&M team has helped clients operationalize governance across some of the world’s most complex AI and HPC deployments. Our approach is practical, trust-based, adaptive, and already in place at major generative AI platforms, hyperscaler infrastructure, and multi-billion-dollar smart zone deployments.
The first piece in the series, authored by Cameron Radis and Steve Spiegelhalter, focuses on the strategic shift in U.S. AI governance and what it means for legal and compliance leaders. Our upcoming pieces will delve into national security enforcement, export control and security integration, engagement with the fast-track export program, and how U.S. policy is reshaping global AI deployment. As the policy environment shifts, one constant remains: Companies will need multidisciplinary, real-world strategies to meet evolving obligations and manage risk at the speed of innovation.
