This article is the third installment in our series on the White House’s AI Action Plan and America’s Evolving AI Posture (the Plan). Read the introduction to our series here. In Part Two of the series, we addressed the Plan’s national security and export control dimensions. In Part Three, we briefly look at a US initiative to advance the export of full stack US AI.

On October 28, 2025, the US Department of Commerce (DOC) issued a Request for Information (RFI)^[1] seeking public comments on a forthcoming Request for Proposals (RFP) that will launch the American AI Exports Program. The RFI advances the Trump administration’s AI Action Plan and Export Executive Order by seeking industry and public input to inform the American AI Exports Program.^[2] In our previous article we describe how this initiative seeks to promote and protect the US AI technology stack abroad.^[3]

The RFI invites feedback on key design elements for the upcoming RFP, through which industry-led consortia will compete to develop and deliver “full stack” AI export packages. These packages are expected to combine US-origin hardware, data infrastructure, models, cybersecurity layers, and applied AI applications for export to trusted foreign partners.

Who should comment?

DOC appears to be seeking public input on how to best advance the strategic objectives defined in the AI Action Plan and Export Executive Order. The RFI states that comments are welcome from all interested parties. US companies that may wish to participate in consortia under the program, such as semiconductor manufacturers, cloud providers, and data-infrastructure firms, may want to consider providing industry perspective. Other stakeholders, including potential foreign buyers, trusted foreign partners in full stack solutions, trade associations, and civil-society groups, either individually or as part of a consortium response, may also provide valuable perspective as DOC seeks to develop a program responsive to the complex dynamics of the global AI marketplace and US strategic objectives.

Why comment?

Input from this RFI will guide how DOC designs and implements the American AI Exports Program, shaping the foundation for how the US promotes, protects, and supports AI technologies abroad. It is an opportunity to help shape the new “rules of the game” for the US full stack AI export initiative. For companies across the AI ecosystem, the RFI offers an opportunity to influence how US innovations are deployed globally while balancing commercial growth, US national security, and responsible technology use. The RFI also is a forum for companies to help define the support mechanisms that will make AI export partnerships practical and competitive, from financing and regulation to operational collaboration.

What should my company say?

The RFI poses 28 questions requesting input regarding:

• The definition and scope of the AI technology stack
• Formation and governance of consortia
• Whether and how non-US partners should be engaged, and what criteria should be applied to “trusted partners”
• Business and operational models
• Federal support mechanisms, such as financing tools
• Input regarding national security equities, such as export controls, cybersecurity, and adversary exploitation
• Parameters for proposal evaluation

Respondents may answer any or all questions.

Productive topics for input may include commenters’ perspective on how their role in consortia or other aspects of full stack AI exports can help to promote the purposes of the anticipated AI Export Program.

When are comments due?

November 28, 2025.

I want to buy US AI technology through this program. How do I apply?

The RFI does not open applications or sales channels for foreign buyers. It only invites public input to help DOC design the forthcoming RFP that will set the rules for industry-led consortia. Foreign buyers interested in acquiring US AI technology should monitor the program’s development and consider engaging with potential US consortia partners or submitting comments to share perspectives on market needs.

When will the RFP open?

DOC has not set a firm date but based on the RFI timeline and typical federal review cycles, the RFP is expected to open in early 2026.

Can foreign companies participate in a consortium?

Possibly. The RFI seeks input on how foreign participation might be structured, including participation under a “trusted partner” model or through a country’s designated national champion.

How can companies prepare now?

Companies that want to join a consortium should identify potential partners, map their offerings across the AI stack, and plan for integrating security and compliance to address national security equities.

Foreign buyers may want to consider connecting with potential US consortia partners and submitting comments jointly or independently.

How A&M Can Help

The A&M National Security, Trade, and Technology (NSTT)  team helps clients navigate the dynamic AI technology security and export controls landscape by integrating “full stack” technical, policy, and security efforts to achieve success. We have a proven track record helping global clients implement trusted, operationally successful, “secure-by-design” high-performance computing (HPC) systems pursuant to US government-issued export authorizations. Our services integrate (among others):

• AI and critical technology export controls compliance assessments, investigations, and risk mitigation program design, enhancement, and implementation
• Logical access and use controls for advanced AI models and HPC systems
• Diligence reviews and screening for prohibited end uses, end users (particularly affiliation with US-embargoed countries or Restricted Party List (RPL) persons and broader Know Your Customer/Know Your Supplier diligence and integrity controls
• AI-specific security operations and continuous monitoring, including model access anomaly detection, training data integrity verification, adversarial attack prevention, model exfiltration monitoring, compute resource hijacking detection, and specialized threat hunting for ML/AI infrastructure with real-time alerting and incident response capabilities
• Robust information security controls and architecture, including verified compliance with security standards such as National Institute of Standards and Technology (NIST), the Cybersecurity Maturity Model Certification (CMMC), and FedRAMP
• Physical security safeguards, such as tamper-evident casings, end-to-end custody tracking protocols, low-impact visibility controls, and facility access controls
• Insider threat, social engineering, and malicious agent risk mitigation
• Project design, integration, and management, use case and technology analysis, capability gap assessment, infrastructure and equipment design, cross-functional expertise integration, budgetary and procurement planning and execution, stakeholder communications and coordination, and risk management services

We help clients remain forward-leaning on global growth while mitigating key risks, expanding responsibly and safeguarding their technology and trusted alignment with US policy objectives.

[1] “American AI Exports Program,” Federal Register, October 28, 2025.

[2] “Promoting the Export of the American AI Technology Stack,” Federal Register, July 23, 2025.

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