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FLI Response to Bureau of Industry and Security (BIS): Request for Comments on Implementation of Additional Export Controls

We welcome the request for technical solutions on this issue. FLI has recently been involved in multiple initiatives to create and improve technical solutions for the governance of AI hardware, including semiconductors.

In our primary comment, we offer arguments in favor of technical solutions for hardware governance, and introduce a new project from FLI which seeks to improve on-chip governance.

We also provide five general comments on the inclusion of civil society, states that facilitate WMD activities, chilling US-China cooperation, national security, and AI foundation model thresholds.

Author(s)
Hamza Chaudhry & Landon Klein
Date published
21 February, 2024
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