Comment by Arnold & Porter

On September 11, 2024, the Department of Commerce (DOC), Bureau of Industry and Security (BIS) issued a proposed rule that would place an ongoing reporting requirement for entities developing, acquiring, or possessing advanced artificial intelligence (AI) models and computing clusters. If adopted, the proposed rule would require a covered U.S. person to submit quarterly notifications to BIS if the person has engaged in, or plans to engage in, either of the following “applicable activities” pertaining to certain advanced AI systems: Development of dual-use foundation AI models: conducting any AI model training run using more than 10^26 computational operations (e.g., integer or floating-point operations). Unverified source (2024)