export restrictions on high performance AI chips.The comment period for this proposed rule expired on October 11, 2024 and only 50 comments were submitted. Thus, we should expect BIS to issue a final rule in the coming months.Although BIS expects that this Proposed Rule would only impact a small number of “well-resourced technology companies,” the failure to comply carries the risk of civil and criminal penalties. The Proposed Rule and AI Executive EO demonstrate the U.S. Government’s recognition of the significant safety and national security risks posed by advanced AI models. The Proposed Rule intends to ensure the safe and reliable development of AI systems while also counteracting dangerous capabilities and the implementation of adequate safeguards to prevent the theft or misuse of dual-use foundation models by foreign adversaries.See BIS Proposed Rule, “Establishment of Reporting Requirements for the Development of Advanced Artificial Intelligence Models and Computing Clusters,” 89 Fed. Reg. 73612 (Sep. 11, 2024).See Executive Order 14110, Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence | The White House.See Proposed Rule at 89 Fed. Reg. 73617. The Proposed Rule defines “model weights” as “the numerical parameters used in the layers of a neural network.”