Trump Administration Unveils “AI Action Plan” & Executive Orders

Last week, the Trump administration unveiled its AI Action Plan, which is intended to serve as a roadmap for its artificial intelligence policy priorities. The president quickly followed that up with the following executive orders implementing various aspects of the plan:

– Promoting the Export of the American AI Technology Stack (July 23, 2025)
– Preventing Woke AI in the Federal Government (July 23, 2025)
– Accelerating Federal Permitting of Data Center Infrastructure (July 23, 2025)

This Nelson Mullins blog reviews the key provisions of each of these executive orders. This excerpt summarizes the key terms of the executive order on promoting the export of US AI technology:

A central principle of the AI Action plan is that America must establish its AI hardware and models “as the gold standard for AI worldwide and ensure our allies are building on American technology.” President Trump’s Executive Order titled “Promoting the Export of the American AI Technology Stack” echoes this goal, stating that the “United States must not only lead in developing general-purpose and frontier AI capabilities, but also ensure that American AI technologies, standards, and governance models are adopted worldwide to strengthen relationships with our allies and secure our continued technological dominance.”

The American AI Exports Program: To accomplish this goal, the order sets a 90-day deadline to establish and implement the “American AI Exports Program,” representing a strategic shift toward comprehensive technology packages rather than piecemeal exports. The “full-stack” AI approach encompasses:

AI-optimized computer hardware (e.g., chips, servers, accelerators);
Data center storage infrastructure, data pipelines, and labeling systems;
AI models and systems;
Cybersecurity measures; and
Sector-specific applications (e.g., AI applications for software engineering, education, healthcare, agriculture, or transportation).

Industry Call for Proposals: Continuing the practice of private sector involvement, the Department of Commerce will issue a public call for proposals from industry-led consortia for inclusion in the American AI Exports Program. Although the exact terms of the call for proposals may vary, the proposals must identify target countries or regional blocs for export engagement, describe business models for building and operating infrastructure, detail requested federal support, and ensure compliance with export controls and security requirements.

The selection process will involve multiple agencies–Commerce, State, Defense, Energy, and the Office of Science and Technology Policy–to select packages that align with both the both commercial and strategic interests.

Activating the Economic Diplomacy Action Group: This order also activates the Economic Diplomacy Action Group to coordinate federal financing tools in support of priority AI export packages, including “aligning technical, financial, and diplomatic resources to accelerate deployment of priority AI export packages under the Program.” This includes supporting direct loans and guarantees, investments, co-financing, political risk insurance, and Small Business Administration support, among other resources.

After providing similar summaries of the other two executive orders, the blog notes the implementation challenges businesses will face under these orders. In particular, it highlights the difficulties businesses will encounter in “interpreting largely undefined or conflicting requirements, potentially at the expense of compromising the overall integrity and viability of the AI models.”