December 16, 2025

Recommendations for Promoting American AI Abroad

Comments on the American AI Exports Program

Strategic Context and Program Objectives

The American AI Exports Program is an ambitious and essential proposal to expand the reach of American AI technologies in foreign markets. The United States has long channeled its energy and resources to advancing the frontier of AI, while promoting international diffusion has thus far received less sustained attention. But China, our primary strategic adversary, has not stood still: Chinese firms Alibaba and Huawei now market “AI in a box” packages that claim to bundle Huawei chips, Alibaba Cloud services, and pre-trained models—turnkey solutions tailored for less technically sophisticated markets. Chinese tech giants are also rolling out models in local languages: Chinese open-weight models now outperform U.S. alternatives across a wide variety of languages, including less widely spoken ones.

If China succeeds in widely promoting its AI stack, it will reap significant security, intelligence, and economic benefits. The adoption of Chinese AI technology around the world would open new vectors for espionage, influence, and coercion from Beijing. It would also erode U.S. firms’ market share in foreign markets, where companies like Google and Microsoft derive roughly half of their revenue, while locking U.S. start-ups out of new markets and hobbling their capacity to scale.1.

The United States has formidable advantages, but this lead may not last forever on every dimension. Export controls on AI semiconductors and their manufacturing equipment, introduced by President Trump in 2018, have given the United States a significant advantage. Today China remains chip-constrained and its leading models continue to lag their American peers. U.S. and allied export controls have not only slowed China’s domestic AI development, but also limited China’s ability to export its AI stack abroad, as China’s limited productive capacity has been reserved for meeting domestic demand. Yet if the United States relaxes export controls in a manner that allows the sale of Nvidia H200–and similar chips and related equipment–on a significant scale, this would have the effect of both accelerating China’s own AI capabilities and making it easier for China to begin exporting more of its advanced chips abroad, undercutting U.S. competitors.

The U.S. government and companies must capitalize on this narrow window to embed American AI systems globally while it remains open. With surging demand for AI technologies and countries making foundational technology choices now, the coming years will be decisive in determining whether the United States maintains its global technological leadership. The AI Exports Program can help ensure that the future of global AI development is built atop American platforms, standards, and innovation ecosystems.

While the Program holds tremendous promise, delivering on that potential will not be easy. Global trust in the United States is challenged and U.S. government capacity is strained. These constraints make it even more important to design the Program for early credibility and long-term sustainability.

We believe the Program will be successful to the extent that it:

  • Encourages third country markets to build their AI ecosystems on U.S. infrastructure and standards, helping to lock in an enduring advantage for AI exporters from the United States and allies relative to their competitors from China;
  • Maintains strong controls on Chinese access to advanced semiconductors and semiconductor manufacturing equipment to constrain China’s ability to export full-stack AI offerings and compete in third country markets;
  • Supports competitive, innovative, affordable AI projects that provide practical solutions tailored to importing partner countries’ objectives and constraints;
  • Incentivizes a broad range of U.S. AI firms to participate in the Program, showcasing the breadth of U.S. private sector AI capabilities and providing widespread benefits to the broader U.S. AI market;
  • Uses public funding judiciously to catalyze U.S. AI exports that the private market would not otherwise have delivered and that are strategically important to U.S. national security; and
  • Promotes responsible AI diffusion built on effective national security standards.

We propose the following recommendations to guide the development of the AI Exports Program:

  1. Adopt a flexible, modular approach in defining U.S. firm eligibility for the Program.
  2. Offer an affirmative message to all potential foreign markets while concentrating scarce resources on priority “swing markets,” countries in which the private sector may underinvest relative to their strategic interest and medium-term economic potential.
  3. Provide a range of benefits, both financial and otherwise, to incentivize U.S. companies to participate, tailored to what will be most helpful for launching successful projects in specific export destinations.
  4. Encourage companies and foreign governments to focus on AI applications that produce real, long-term value to ensure partnerships deliver mutual benefit.
  5. Prioritize layers of the AI stack that build ongoing partnership and combat Chinese influence.
  6. Encourage participating firms to adopt interoperable standards to allow upgrading and avoid lock-in on specific vendors.
  7. Engage with countries’ AI sovereignty concerns to better assuage fears of dependencies on U.S. firms and technology.
  8. Require U.S. company participants to adhere to national security safeguards based on commonsense principles and scaled to the company’s position in the AI stack.
  9. Allow select U.S. treaty allies and their companies to participate in the AI Exports Program on a reciprocal basis consistent with national security safeguards.

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  1. “Microsoft Corporation,” Bull Fincher, accessed September 11, 2025, https://bullfincher.io/companies/microsoft-corporation/revenue-by-geography; “Alphabet Global Revenue by Region (2024),” Voronoi, April 30, 2025, https://www.voronoiapp.com/markets/-Alphabet-Global-Revenue-by-Region-2024-4902.
  2. Alexandra Alper, Toby Sterling, Stephen Nellis, “Trump administration pressed Dutch hard to cancel China chip-equipment sale - sources”, Reuters, January 6, 2020, accessed December 1, 2025, https://www.reuters.com/article/world/uk/trump-administration-pressed-dutch-hard-to-cancel-china-chip-equipment-sale-so-idUSKBN1Z50H4
  3. Chris Miller, “Why China Can’t Export AI Chips”, American Enterprise Institute, December 2024, https://www.aei.org/foreign-and-defense-policy/why-china-cant-export-ai-chips

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