Promoting the Stack: Trump’s AI Export Incentive Program Explained
Overview of the Executive Order
Alongside its AI Action Plan, the Trump administration published an executive order (EO) for Promoting the Export of the American AI Technology Stack. The Action Plan describes the goal of the EO as follows: “Establish and operationalize a program within DOC aimed at gathering proposals from industry consortia for full-stack AI export packages. Once consortia are selected by DOC, the Economic Diplomacy Action Group, the U.S. Trade and Development Agency, the Export-Import Bank, the U.S. International Development Finance Corporation, and the Department of State (DOS) should coordinate with DOC to facilitate deals that meet U.S.-approved security requirements and standards.”
Essentially, the EO gives the Department of Commerce 90 days to establish the American AI Exports Program, through which participating industry-led consortia can gain access to:
Financing from the Export–Import Bank of the United States (EXIM) and the United States International Development Finance Corporation (DFC)
Additional diplomatic support, and
Other “incentives and support mechanisms” requested by the applicant.
In return the consortia must:
Export a full-stack solution, from hardware and data pipelines through AI models all the way down to intended applications for specific use cases.
Take actions, proposed by the consortium, to ensure the security of the models and systems they export.
Report to what extent the hardware is manufactured in the US, and who will build, own, and operate the infrastructure.
For example, a consortium might look like a US model developer, such as OpenAI, working with a US cloud provider, such as Microsoft, and a chip company such as Nvidia, to build a data centre in a particular country to sell access to models for a particular set of applications. This is somewhat unusual, as an effort like this would typically not have a pre-specified list of applications, given the general-purpose and rapidly evolving nature of the technology. It is somewhat unclear whether the consortium could allow the capacity to be used for other use cases than those specified in the proposal.
The EO appears to be an attempt to generalize the approach taken to the May 2025 deals to export chips to the UAE and Saudi Arabia. However, in those cases deals were necessary because the US had imposed a license requirement for exporting the relevant chips to those countries. It is somewhat difficult to say what the impact of this program will be in cases where companies can simply export without any participation in the program.
What kind of support might consortia receive in practice?
Financing
The Export–Import Bank of the United States (EXIM) has a total statutory authority to have $135 billion loans outstanding at any given time, and has $34.1 billion outstanding, giving them over $100 billion capacity that they could dedicate to AI projects. The United States International Development Finance Corporation (DFC) has a statutory authority of $60 billion, with only $11 billion of that currently available. Even if entirely dedicated to AI projects, these funds would not represent a large increase in the total amount of financing available to US companies, but partial EXIM financing could still be used to incentivize exporters to take somewhat different actions than otherwise. And Congress could, of course, authorize additional lending.
Prospective consortia can also request unspecified “federal incentives”, which may ultimately have a greater financial impact than direct financing.
Diplomatic support
Many countries have various regulatory obstacles, regarding e.g. data privacy or foreign investment, that may pose difficulties for these export deals. The State Department could provide direct diplomatic support to attempt to clear these obstacles. Government-to-government negotiations could also help address political risk in export deals.
Other support
Prospective consortia can request Federal “support mechanisms”. The most obvious such support mechanism would be expedited export licenses, in cases where such licenses would be required.
Why full-stack?
It is interesting that the administration is specifically incentivizing exports of integrated full-stack solutions. This is arguably in some tension with the Plan’s other rhetoric about getting allies to build on the US tech stack: If you provide a full-stack solution from hardware to applications, there’s not much left to build on.
At a CSIS event, OSTP Director Kratsios explained that the decision to cultivate full-stack solutions specifically was motivated by the observation that foreign governments, particularly in the Global South, often struggle to navigate the diverse offerings of the US tech industry, while Chinese companies sell easy-to-understand, turnkey packages. According to Kratsios, “we as America need to make it easy for lots of folks to understand what’s available and how they can actually deploy this technology in their country.”
Of course, one may ask why the US tech industry needs sales help from the government. Reading between the lines, the concern may be that US tech companies will otherwise underinvest in providing solutions to less developed economies, because there is less revenue to be gained there. The U.S. government on the other hand sees it as a foreign policy interest that the U.S. has a strong presence in these markets, which may have outsized geopolitical importance despite their smaller financial size.
Exporting a full-stack solution may also have some advantages when exporting to “swing states” in the Global South. In particular, a full-stack helps encourage countries buying US hardware to commit to also run US models and applications on that hardware, rather than turning to China for models and applications.
It is difficult to say at this point how excited industry will be about this approach. It is currently somewhat uncommon for dedicated infrastructure to be built for specific applications, which the EO seems to demand. It is not clear if the incentives provided by the EO will be able to compete with the advantages afforded by a more flexible approach.
How will the American AI Exports Program interact with export controls?
The program in some ways can be seen as an alternative to Biden’s “diffusion framework” export controls, but focused entirely on export promotion. Indeed, the EO makes hardly any reference to export controls.
However, the program may end up being most appealing to consortia looking to export to countries that are subject to license requirements: Expedited export licensing is one of the most valuable forms of support that the program could offer, and diplomatic support may also be particularly valuable in these contexts.
An integrated full-stack approach may be most beneficial in the context of higher-risk jurisdictions: If American hardware is only being used to run American models for pre-specified applications, there is radically less risk that the chips will be diverted, or used in ways that are contrary to American values or security interests. The (unspecified) security requirements of the program would also be most relevant in such high-risk contexts.
Ultimately, this program may evolve into the Trump administration’s streamlined, industry-friendly answer to the universal validated end user concept introduced in Biden’s diffusion framework.
What to look for in implementation?
The actual call for proposals that Commerce will need to produce may include additional detail and clarity on the rubric that will be used to assess proposals, including:
Details on what applicants’ security measures should actually look like.
Details on the expected structure of the consortia, and how “applications” should be defined for an intrinsically general-purpose technology.
Specific expectations for infrastructure ownership arrangements.
Specific requirements for what share of the system components should be manufactured in the US.
If the Trump administration chooses to connect the program to the US export control regime, Commerce could also ask companies to at least provide documentation of what measures they intend to take to prevent diversion of the exported chips, and what measures will be taken to ensure that the services will not be used to advance e.g. adversary military modernization efforts.