The Software & Information Industry Association (SIIA) has submitted comments in response to the Bureau of Industry and Security’s (BIS) request for comment on interim final rule AC/S IFR. SIIA appreciates BIS’s goals of protecting U.S. national security while maintaining a calibrated approach to avoid undermining U.S. technology leadership and commercial trade.
SIIA raises concerns about the potential duplication of regulations and the impact on the global standing of U.S. Infrastructure-as-a-Service (IaaS) providers. It emphasizes the importance of consistent and realistic requirements for IaaS providers, citing potential conflicts with existing regulations and executive orders.
We highlights the role of IaaS providers in national security objectives related to artificial intelligence (AI) and recommends that any controls on IaaS providers consider existing regulations. SIIA suggests that enforcement should be targeted, with a comprehensive list of entities subject to controls to maintain the U.S. IaaS industry’s leadership position.
Regarding deemed exports and reexports of advanced computing and semiconductor (AC/S), SIIA argues against imposing licensing requirements, emphasizing the importance of attracting foreign talent for AI development. It suggests that additional licensure requirements may hinder innovation, disrupt ongoing activities, and drive top talent to countries without similar restrictions.
We addresses concerns about the definition of “headquartered companies” and recommends a clear definition to avoid ambiguity and facilitate compliance. It suggests limiting the definition to majority ownership by a company headquartered in a designated nation and providing guidance on the treatment of ownership by holding companies.
