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Commerce Department Solicits Feedback on AI Exports Program

By Holly Fechner, Matthew Shapanka & Samuel Klein on October 28, 2025
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The Commerce Department today published a Request for Information (RFI) inviting the public to submit comments on U.S. artificial intelligence exports.  The RFI asks stakeholders to weigh in on aspects of the Department’s new “American AI Exports Program,” an initiative intended to “promot[e] the export of full-stack American AI technology packages.”

The RFI follows from President Trump’s Executive Order 14320, Promoting the Export of the American AI Technology Stack—one of three such orders implementing the Administration’s “AI Action Plan,” published in July—which directed the Department of Commerce, consulting with the Secretary of State and the Director of the Office of Science and Technology Policy, to establish and implement the program.  According to the Executive Order, the Program will ultimately seek proposals from “industry-led consortia” for export packages that integrate, among other capabilities, “AI-optimized computer hardware,”  “AI models and systems,” and “AI applications for specific use cases.”

Commenters are encouraged to respond to any or all of the Department’s questions regarding, among other things, criteria for evaluating proposals and details about the relevant components of the AI tech stack; priority regions for AI exports; the structure of the consortia; federal support mechanisms; and international standards-setting.

Stakeholders may submit comments by November 28, 2025.

Photo of Holly Fechner Holly Fechner

Holly Fechner has two decades of legal, legislative and public policy experience in the public and private sectors.  Ms. Fechner has a broad-based practice handling legislative and regulatory matters for clients in areas including healthcare, tax, intellectual property, education, and employee benefits.  Drawing…

Holly Fechner has two decades of legal, legislative and public policy experience in the public and private sectors.  Ms. Fechner has a broad-based practice handling legislative and regulatory matters for clients in areas including healthcare, tax, intellectual property, education, and employee benefits.  Drawing on her extensive congressional and private sector experience, Ms. Fechner offers clients comprehensive advocacy services, including strategic advice, substantive legal and regulatory expertise, and policy and message development.  She has a proven track record in assisting clients fulfill their government affairs goals.

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Matthew Shapanka

Matthew Shapanka draws on more than 15 years of experience – including on Capitol Hill, at Covington, and in state government – to advise and counsel clients across a range of industries on significant legislative, regulatory, and enforcement matters. He develops and executes…

Matthew Shapanka draws on more than 15 years of experience – including on Capitol Hill, at Covington, and in state government – to advise and counsel clients across a range of industries on significant legislative, regulatory, and enforcement matters. He develops and executes complex, multifaceted public policy initiatives for clients seeking actions by Congress, state legislatures, and federal and state government agencies, many with significant legal and political opportunities and risks.

Matt rejoined Covington after serving as Chief Counsel for the U.S. Senate Committee on Rules and Administration, where he advised Chairwoman Amy Klobuchar (D-MN) on all legal, policy, and oversight matters within the Committee’s jurisdiction, including federal election law and campaign finance, and oversight of the Federal Election Commission, legislative branch agencies, security and maintenance of the U.S. Capitol Complex, and Senate rules and regulations.

Most significantly, Matt led the Rules Committee staff work on the Electoral Count Reform and Presidential Transition Improvement Act – landmark bipartisan legislation to update the antiquated process of certifying and counting electoral votes in presidential elections that President Biden signed into law in 2022.

As Chief Counsel, Matt was a lead attorney on the joint bipartisan investigation (with the Homeland Security and Governmental Affairs Committee) into the security planning and response to the January 6, 2021 attack on the Capitol. In that role, he oversaw the collection review of documents, led interviews and depositions of key government officials, advised the Chairwoman and Committee members on two high-profile joint hearings, and drafted substantial portions of the Committees’ staff report on the attack. He also led oversight of the Capitol Police, Architect of the Capitol, Senate Sergeant at Arms, and executive branch agencies involved in implementing the Committees’ recommendations, including additional legislation and hearings.

Both in Congress and at the firm, Matt has prepared many corporate and nonprofit executives, academics, government officials, and presidential nominees for testimony at legislative, oversight, or nomination hearings before congressional committees, as well as witnesses appearing at congressional depositions and transcribed interviews. He is also an experienced legislative drafter who has composed dozens of bills introduced in Congress and state legislatures, including several that have been enacted into law across multiple policy areas.

In addition to his policy work, Matt advises and represents clients on the full range of political law compliance and enforcement matters involving federal election, campaign finance, lobbying, and government ethics laws, the Securities and Exchange Commission’s “Pay-to-Play” rule, as well as the election and political laws of states and municipalities across the country.

Before law school, Matt worked as a research analyst in the Massachusetts Recovery & Reinvestment Office, where he worked on all aspects of state-level policy, communications, and compliance for federal stimulus funding awarded to Massachusetts under the American Recovery & Reinvestment Act of 2009. He has also worked for federal, state, and local political candidates in Massachusetts and New Hampshire.

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Samuel Klein

Samuel Klein helps clients realize their policy objectives, manage reputational risks, and navigate the regulatory environment governing political engagement.

As a member of Covington’s Election and Political Law practice, Sam assists clients facing Congressional investigations and offers guidance on ethics laws; with the…

Samuel Klein helps clients realize their policy objectives, manage reputational risks, and navigate the regulatory environment governing political engagement.

As a member of Covington’s Election and Political Law practice, Sam assists clients facing Congressional investigations and offers guidance on ethics laws; with the firm’s Public Policy group, Sam supports strategic advocacy across a breadth of policy domains at the federal, state, and local levels.

Sam spent one year as a law clerk at the Federal Election Commission. His prior experience includes serving as an intern to two senior members of Congress and helping clients communicate nuanced policy concepts to lawmakers and stakeholders as a public-affairs consultant.

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  • Posted in:
    International
  • Blog:
    Global Policy Watch
  • Organization:
    Covington & Burling LLP
  • Article: View Original Source
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