The U.S. has been actively developing export control policies for advanced AI technologies, particularly to prevent adversaries like China from accessing cutting-edge capabilities. In January 2025, the Biden administration's Bureau of Industry and Security (BIS) issued the "Framework for Artificial Intelligence Diffusion," which created new export controls on advanced AI chips and on the model weights of the most advanced closed-source AI models (Federal Register, Council on Foreign Relations). The rule created a new export control classification (ECCN 4E091) for "frontier" AI model weights—specifically, closed-weight AI models trained using more than 10²⁶ computational operations, requiring licenses to export these model weights outside of the U.S. (Sidley Austin). The rule sorted countries into three tiers: 18 close U.S. allies were largely exempt, China and Russia faced presumptive denial, and all other countries fell into a middle tier with country-specific quotas (Nextgov).

• Frontier AI model weights: The export, reexport, or transfer of model weights for advanced AI models (e.g., models above a certain computational threshold, most advanced models, or similar frontier-defining criteria)
• Computing resources for frontier AI training: Chips, computing clusters, or infrastructure specifically designated for training frontier AI models, beyond generic chip controls that don't explicitly reference AI model development
• Cloud access for frontier AI development: Cloud-based access specifically for developing or training frontier AI models

To qualify, controls must:

• Specifically identify AI models, model weights, or AI model training as controlled items or activities in the regulation text
• Be aimed at models at or near the technological frontier, not all AI systems generally
• Apply broadly and not be limited to a single country or entity (global controls with country-specific exceptions will qualify)

• Official announcements from the U.S. Department of Commerce or Bureau of Industry and Security
• Publication of new rules in the Federal Register
• Updates to the Export Administration Regulations (EAR)
• Executive Orders that directly impose (not merely study or recommend) export restrictions

• The rule must be legally enforceable, not merely non-binding guidance, policy frameworks, or recommendations
• If a rule is published with an effective date on or before 31 July 2026 but enforcement is delayed beyond that date, it still counts as "implemented"
• "New or expanded" means controls issued during the forecast period; simply maintaining unchanged controls that were fully in effect before 4 November 2025 does not count
• State-level or international controls do not count