Federal AI blacklist targets foreign tech—but definitions are dangerously vague
S. 2177 — No Adversarial AI Act · Filed by Rick Scott (R-FL) · 1 cosponsor · Introduced Jun 25, 2025 · Referred to committee
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What it does
This bill requires the federal government to create and maintain a public list of artificial intelligence systems developed or produced by foreign adversaries (like China, Russia, Iran, North Korea). Federal agencies must review their AI use within 90 days and remove or exclude any AI from that list, unless they get a written exception approved by the Office of Management and Budget and Congress—which can be granted for research, testing, counterterrorism, or critical mission functions.
Why we flagged it
The bill's core function is to identify and exclude AI systems from foreign adversaries in federal procurement and use. It is a supply-chain security measure, not a broad AI regulation or innovation bill, despite the generic title.
What the text implies
- The 20% foreign ownership threshold for 'foreign adversary entity' status may inadvertently capture U.S. companies with significant foreign investment or multinational structures, creating compliance uncertainty.
- The exception process (research, testing, counterterrorism, mission-critical) is broad and agency-discretionary; agencies can justify almost any AI use by claiming one of these categories, potentially undermining the bill's intent.
The full analysis lists 4 implications of this text.
Who stands to gain
U.S. semiconductor and AI hardware manufacturers (AMD, HPE, CSCO, CTSH); U.S. software and AI service providers not on the foreign adversary list; Domestic cybersecurity and compliance consulting firms