On July 23, 2025, the White House released “Winning the Race: America’s AI Action Plan,” encompassing more than 90 federal policy actions and outlining the administration’s comprehensive and aggressive approach to securing US “dominance in artificial intelligence.” The plan is a significant departure from the previous administration’s safety-first, risk-based regulatory posture in favor of a deregulated and industry-partnered environment. The plan is structured around three main pillars: innovation, infrastructure, and international diplomacy and security.
The artificial intelligence action plan is largely not self-executing and some aspects may require congressional action, including appropriations to fund some of the measures.
The first pillar emphasizes a comprehensive commitment to fostering a regulatory and economic ecosystem that unleashes private sector–led AI innovation and removes perceived “red tape” and “onerous regulation.” The administration highlights that it has rescinded previous executive orders it perceived as imposing burdensome regulation on AI development and has directed the Office of Science and Technology Policy and Office of Management and Budget to identify and repeal any other federal regulations that they believe “hinder AI innovation.”
While the plan does not and likely could not directly restrict state regulation of AI, it recommends that the federal government “consider a state’s AI regulatory climate” when weighing how to distribute federal funding, with funding potentially withheld from states that maintain AI regulatory regimes the administration deems overly “restrictive.”
The action plan also mandates that AI systems, especially those acquired by the federal government, be “objective and free from top-down ideological bias” and instructs the National Institute of Standards and Technology (NIST) to revise its AI Risk Management Framework to remove references to “misinformation,” “Diversity, Equity, and Inclusion,” and “climate change.”
The plan also encourages the development of open-source and open-weight AI models—models that are made freely available by developers for anyone in the world to download and modify—with the government stressing their importance for innovation, academic research, and geostrategic leadership. Further actions outlined in the plan include the establishment of regulatory “sandboxes” and “Centers of Excellence” around the country to accelerate AI deployment in critical sectors such as healthcare, energy, and agriculture.
The plan also aims to “empower American workers,” calling for rapid AI skill development, creation of an AI Workforce Research Hub, and retraining programs for those displaced by AI-driven changes.
Federal government investments are also earmarked for next-generation manufacturing technologies, automated cloud-enabled labs, and the creation of “world-class” privacy-protected scientific datasets. Strategic funding will also be directed to theoretical, computational, and experimental AI research, particularly in interpretability, control, and robustness. To ensure system safety and trust, NIST and others are tasked with publishing guidelines for AI evaluation and establishing testbeds for real-world piloting.
The plan also formalizes interagency coordination for AI adoption in government and defense, including talent exchange and procurement reform, and emphasizes the protection of intellectual property and cyber-resilience.
Finally, the plan addresses the legal challenges of synthetic media (deepfakes) by developing forensic standards and guidance for courts and law enforcement.
Recognizing that US “AI dominance” requires substantial physical and digital infrastructure, the second pillar focuses on streamlining the permitting processes for data centers, semiconductor plants, and energy facilities while maintaining security “guardrails” against adversarial technology.
The plan sets forth a multiphase strategy to stabilize, optimize, and expand the US electric grid, prioritizing reliable, dispatchable power sources and advanced grid management technologies. This coincides with the president’s executive order directing federal agencies to streamline and expedite the permitting process for data center projects to support national goals of digital infrastructure, AI advancement, and energy efficiency.
The administration also tasks the CHIPS Program Office with revitalizing domestic semiconductor manufacturing and integrating AI tools throughout the production processes. New technical standards will be developed for high-security data centers, especially those handling sensitive military and intelligence workloads. Workforce initiatives target “high-priority occupations essential to the buildout of AI infrastructure,” emphasizing apprenticeships and partnerships with educational institutions.
To address new cyber risks, the administration instructs the US Department of Homeland Security to establish an AI Information Sharing and Analysis Center and issue guidance on AI-specific vulnerabilities. The plan orders the US Department of Defense and intelligence agencies to refine frameworks for AI assurance, resilience, and incident response, with NIST integrating AI into incident response playbooks.
The third pillar emphasizes expansion of US leadership in global AI governance and security, highlighting the export of the “full AI technology stack”—hardware, models, software, applications, and standards—to allies and partners, with the US Department of Commerce coordinating efforts to ensure compliance with American security standards.
The plan explicitly seeks to “counter Chinese influence” by leveraging US positions in international bodies to promote innovation-friendly AI governance and resist adversarial standard-setting. This pillar is supported by the White House’s executive order issued the same day directing the Secretary of Commerce to establish an American AI Exports Program within 90 days to solicit industry-led proposals for full-stack US AI export packages for targeted foreign partners and mobilize federal financing tools to support selected exports.
The plan explains that enforcement of AI compute export controls will be intensified, including location verification and international cooperation. New controls will target semiconductor manufacturing subsystems to “plug loopholes” and prevent adversaries from exploiting gaps. The United States will also encourage allies to adopt complementary protection measures and use diplomatic and economic tools to align global safeguards.
The administration also directs federal agencies to partner with AI developers to assess national security risks in frontier models with a focus on chemical, biological, radiological, nuclear, and cyber vulnerabilities. The plan further mandates robust biosecurity protocols, including nucleic acid sequence screening and the creation of secure data-sharing mechanisms to prevent AI misuse in synthetic biology.
The administration’s pivot toward deregulation, infrastructure expansion, and strategic global positioning presents both opportunities and compliance complexities for companies and in-house legal departments.
Companies operating in AI, data infrastructure, and critical sectors should closely monitor the implementation details of this action plan and, if it materializes as suggested, anticipate both increased federal support and heightened scrutiny, particularly regarding export controls and compliance with new federal procurement “neutrality” and “objectivity” standards.
Counsel for companies involved in AI development should evaluate legal implications of sandbox participation, including IP ownership, liability, data security, and privacy, and consider negotiating participation terms in MOUs or interagency agreements.
For companies in the infrastructure and energy space, the plan’s focus on expediting approval of data centers and other facilities with limited regulation has the potential to trigger fast-tracked energy procurement and grid modernization while also raising potential for environmental, land use, and permitting disputes. Counsel should prepare to update environmental impact assessments and ensure regulatory compliance.
For clients operating across jurisdictions, in-house counsel should monitor alignment between evolving state-level AI regulations and federal eligibility criteria. This may include adapting government contracts and RFP responses and preparing bias audits or neutrality certifications to preserve access to federal grants and contracts.
More generally, in-house counsel should also consider the following actions:
As federal priorities evolve, proactive legal guidance will be essential for navigating uncertainty, mitigating risk, and positioning clients for success in an increasingly AI-driven regulatory landscape.
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