The Software & Information Industry Association (SIIA) expresses concerns regarding H.R. 8315, the ENFORCE Act, which aims to regulate the export of certain AI systems. While acknowledging the bill’s intent to safeguard national security interests, SIIA argues against implementing an Export Administration Regulations (EAR) licensing regime for AI models. They believe such controls would hinder U.S. firms’ competitiveness in AI, potentially empowering foreign counterparts. SIIA contends that AI’s dynamic nature makes it unsuitable for traditional licensing approaches and suggests leveraging the Executive Order 14110 process instead. They advocate for robust review mechanisms through the U.S. AI Safety Institute and urge against treating AI models like dual-use encryption software due to their distinct characteristics. SIIA encourages Congress to explore alternative strategies and offers collaboration with the Committee moving forward.