Executive Summary

Alvarez & Marsal National Security, Trade, and Technology (A&M NSTT) recently submitted comments [1] to the U.S. Department of Commerce (DOC) in response to the Request for Information (RFI) [2] on the American AI Exports Program (Program) [3].

Read A&M NSTT’s full comments submission to the DOC here.

Together with the America First Investment Policy [4], the White House AI Action Plan [5], and the 2025 US National Security Strategy (NSS) [6], the American AI Exports Program reflects a durable shift in US policy:

• Economic security and technology leadership are national security priorities.
• Market access is increasingly conditioned on alignment, assurance, and enforcement.
• Speed and credibility, not multilateral consensus, define success.

A&M NSTT’s comments focus on execution: recommending practical, verified pathways for exporting full stack US AI that build trust, increase efficiency, reduce risk, and improve AI ROI for clients and partners. Our team has a proven track record of helping technology providers and consumers implement secure-by-design HPCs and data centers that achieve US and trusted partner objectives. 

AI Action Plan: Export the Full Stack

As discussed in our article on the ramifications of the US AI Action Plan [7], rather than exporting individual components, US policy now prioritizes exporting full-stack AI systems that encompass hardware, software, data pipelines, models, cybersecurity, and controls. The objective of the US AI Exports Program is to expand US AI leadership globally by embedding US technology and standards into deployments from the outset. The DOC’s RFI sought industry comments on what models of partnership would best achieve the program’s objectives. 

A&M NSTT’s comments recommend building executable and secure deployment models by embedding end-use governance, security-by-design, and independent verification directly into US AI system deployments.

• Full‑stack with security‑by‑design: We recommend NIST‑aligned, layered controls across physical, network, compute, storage, application, data pipeline, and monitoring—validated by an independent US third‑party security consultant with continuous monitoring and mandatory violation escalation. This turns compliance into a predictable accelerator while meeting the Program’s requirement for measures to secure AI models and systems.
• End‑user and end‑use governance: Know the user, their affiliation, and the workload. We propose strong identity and continuous affiliation screening; workload‑level usage controls (including prohibited‑topic enforcement); trained‑model protections (weights, API monitoring, usage accountability, compute thresholds); and location verification for advanced compute, with clear responsibility and reporting.
• Trusted pathways that scale: We recommend a Trusted Partner certification and a White‑Listed Technology and Solution Provider designation. Both rely on independently verified, US‑benchmarked controls to enable pre‑verified control inheritance, unified audit practices, and streamlined licensing—reducing deployment friction and cycle time without weakening enforcement. 

Emerging Policy Momentum: Interagency Alignment on AI Export Policy

Recent reporting indicates that senior US agencies are preparing to convene an interagency initiative focused on AI diffusion, export controls, and security standards, to begin in early 2026. Industry officials describe the effort as aimed at bringing greater order, consistency, and discipline to US AI export policy, advancing the American AI Export Program’s objective of promoting full-stack AI deployments. 

This anticipated alignment reflects concern that fragmented decision-making and inconsistent signals:

• Undermine exporter and ally confidence
• Create opportunities for regulatory arbitrage
• Increase the risk of strategic leakage to geopolitical competitors

In response, US policy is converging on a clear conclusion: Sustained AI leadership requires leadership in security, governance, and verification. The American AI Exports Program is designed not only to promote US AI abroad, but to ensure that exported systems remain under continuous, auditable control and establish US security standards as the global default.

What Do These Developments Mean for Clients and Partners?

US Technology and Infrastructure Providers

• Build export-ready stacks. Design data centers and AI platforms with end‑use governance and NIST‑aligned, security‑by‑design controls from Day 1 to make approvals predictable and reduce rework and delays. Instrument identity/affiliation screening, workload‑level controls (including end-use restrictions), trained‑model protections, and tamper‑evident logging to demonstrate continuous, auditable control of sensitive compute and models.
• Operate to a verified standard. Leverage trusted third-party control validation, continuous monitoring, and mandatory violation escalation to convert “trust” into faster licensing and lower operational risk across sites and jurisdictions.
• Prepare for programmatic oversight. Move from ad hoc licensing to repeatable governance with complete audit packets, location verification for advanced compute, and control inheritance across deployments to scale efficiently under the Program. 

Foreign Partners and Buyers

• Align early to trusted pathways. Adopt trusted partner‑style requirements—identity and access controls, isolation from countries of concern, continuous monitoring, and transparent reporting—to qualify for streamlined approvals and predictable treatment.
• Demonstrate end‑use accountability. Document who uses the stack, affiliations, approved workloads, and trained‑model controls; instrument anomaly detection and escalation to sustain confidence with US regulators and suppliers.
• De‑risk capital and timelines. Use White‑Listed/trusted providers and pre‑verified control templates to reduce integration risk, accelerate build schedules, and avoid duplicative reviews across jurisdictions.

Investors and Deal Teams

• Underwrite to governance, not promises. Treat AI exports as operating inside a national‑security perimeter; diligence technology lineage, model controls, location verification, and third‑party validation as core value and timing drivers.
• Price for compliance durability. Favor assets and operators that can inherit verified controls, show audit‑ready documentation, and leverage White‑List/trusted partner pathways—supporting faster revenue realization and lower enforcement risk.
• Anticipate programmatic oversight. Model ongoing monitoring, reporting obligations, and incident escalation as part of OpEx and covenant structures, improving certainty for boards and co‑investors. 

How A&M NSTT Can Help Clients and Partners Succeed

A&M NSTT is uniquely qualified by proven success helping clients and partners implement American AI-enabled HPCs and data centers with security, governance, and verification built in across the stack. We translate policy into integrated execution: architecting export‑ready full stacks, implementing end‑use governance and NIST‑aligned controls, verifying and optimizing controls, and providing evidence and perspective that accelerates approvals and operations. The result is trusted deployments that move faster, reduce regulatory and operational risk, and improve AI ROI across jurisdictions.

• Design export‑ready, full‑stack programs

  • Map use cases and requirements; architect vendor‑agnostic stacks; build security‑by‑design controls across physical, network, compute, storage, application, data pipelines, and monitoring layers aligned to NIST SP 800‑53/800‑171
  • Produce audit‑ready artifacts (SSP, runbooks, tamper‑evident logs, compliance dashboards) to support predictable approvals and ongoing assurance

• Establish end‑use governance and verified controls

  • Implement identity/affiliation screening, role‑based access, prohibited‑topic enforcement, model weight protection, API monitoring, and compute threshold controls; operationalize anomaly detection and escalation pathways
  • Serve as Third‑Party Security Consultant to verify controls, provide continuous monitoring/reporting, and support location verification and enhanced end‑use monitoring where required

• Form and operate effective consortia

  • Structure lead‑entity governance, decision protocols, and responsibility matrices; draft membership agreements; and enable control inheritance across multi‑vendor deployments, including participation by White‑Listed providers

• Navigate export controls and licensing

  • Support classification, licensing, license‑condition implementation, and liaison with BIS; integrate programmatic compliance into day‑to‑day operations to reduce friction and time‑to‑deployment

Bottom Line

The American AI Exports Program is not a standalone initiative. It is the operational convergence of the America First Investment Policy, the AI Action Plan, and the National Security Strategy. Organizations and investors that treat security, governance, and verification as core design features—not regulatory afterthoughts—will move faster, experience less friction, and achieve greater success in global AI markets. A&M NSTT is uniquely capable to help navigate for success.

[1]. Regulations.gov, Comment on FR Doc # 2025-19674 (A&M response to DOC RFI), December 13, 2025.

[2]. Department of Commerce, American AI Exports Program (Request for information), Federal Register 90 FR 48726, October 28, 2025.

[3]. The White House, “Promoting the Export of the American AI Technology Stack,” Executive Order, July 13, 2025.

[4]. The White House, America First Investment Policy, Memorandum, February 21, 2025.

[5]. The White House, Winning the Race: America’s AI Action Plan, July 2025.

[6]. The White House, National Security Strategy of the United States of America, Report, November 2025.

[7]. Randall Cook et al., “What the US AI Action Plan Means for Export Controls and US National Security,” Alvarez & Marsal, September 23, 2025.