Comment by Onni Aarne

The Action Plan includes valuable measures to get BIS better information about where and how smuggling is happening, through collaboration with the intelligence community, and location verification. Location verification for AI chips in particular is an idea that IAPS has championed - my colleague Asher and I wrote the first full report on the idea last year. Understandably, the Action Plan only calls for "exploration" of the idea, but exploration could already mean e.g. working with Nvidia to prove out the idea on their chips in high-risk countries, and let Jensen Huang prove that chip smuggling is not happening. The bipartisan bicameral Chip Security Act shows potential Congressional interest in the idea of location verification as well. However, Congress will also need to approve the President's request for increased BIS funding, so that BIS will have the enforcement resources to act on that information.