White House Unveils Comprehensive AI Strategy: “Winning the Race: America’s AI Action Plan”

Following the release of the Executive Order Removing Barriers to American Leadership in AI in January 2025, the White House announced a comprehensive new policy initiative on July 23, 2025 titled Winning the Race: America's AI Action Plan ("AI Action Plan"). This initiative outlines the Trump Administration's vision for securing US leadership and dominance in artificial intelligence and delivering its benefits to businesses and consumers.

The AI Action Plan is built on three core pillars: (I) Accelerating AI Innovation; (II) Building American AI Infrastructure; and (III) Leading in International AI Diplomacy and Security. In addition to its structural pillars, the AI Action Plan is guided by three foundational principles:

• Empowering American Workers – The AI Action Plan emphasizes the role of U.S. workers in the nation's AI strategy, with the stated aim of ensuring they are positioned to benefit from the opportunities created by the AI technological revolution.
• Ensuring Ideological Neutrality – As reflected in the "Preventing Woke AI in the Federal Government" executive order, the Trump Administration intends to update the federal procurement guidelines to ensure that only "unbiased" large language models considered free from "ideological dogmas such as DEI" and other "partisan or ideological judgments" are eligible for government use.
• Protection Against Misuse – The federal government should take measures to prevent advanced technologies from being misused or stolen by malicious actors and monitor emerging and unforeseen risks from AI.

This client alert provides an overview of the AI Action Plan's policy goals and highlights key takeaways for businesses.

Pillar I: Accelerate AI Innovation

The first pillar of the AI Action Plan lays out a roadmap aimed at securing US leadership in artificial intelligence by fostering an environment where private-sector innovation thrives. Accordingly, the federal government is tasked with removing regulatory barriers and actively incentivizing AI development and adoption. According to the AI Action Plan, "AI is far too important to smother in bureaucracy at this early stage, whether at the state or federal level." This deregulatory approach was previewed earlier during congressional debate over the House Budget Bill, in which a previously proposed (but ultimately unsuccessful) provision would have preempted state enforcement of AI-related laws for ten years. While that measure failed, the AI Action Plan directs federal agencies to consider state AI regulatory frameworks when allocating AI-related discretionary federal funding and to assess whether restrictive state policies hinder innovation in the AI space.

More specifically, the AI Action Plan assigns key responsibilities to several federal agencies. The Office of Management and Budget ("OMB") is encouraged to evaluate state laws in funding decisions; however, it is unclear how much impact this recommendation will have or what it will look like in practice. The Federal Communications Commission ("FCC") is tasked with evaluating whether state AI laws interfere with its authority under the Communications Act of 1934. Moreover, it directs the Federal Trade Commission ("FTC") to review and, where appropriate, seek to modify or set aside investigations, orders, consent decrees and injunctions from prior administrations that may unduly burden AI innovation.

Other key policy objectives and recommendations under this pillar include:

• Incorporate First Amendment Protections Into AI Development – The AI Action Plan states that AI systems must be designed with freedom of speech and expression as foundational principles, and government policy should not undermine that objective. To this end, the AI Action Plan recommends that the National Institute of Standards and Technology ("NIST") revise its AI Risk Management Framework by removing references to misinformation, DEI and climate change.
• Promote Open-Source and Open-Weight AI – The AI Action Plan seeks to promote the growth of open-source AI by encouraging a supportive environment, including expanding access to large-scale computing power for startups and academic researchers, and partnering with leading tech companies to broaden access to models, data and software tools.
• Facilitate AI Adoption & Build an AI Evaluations Ecosystem – The AI Action Plan seeks to accelerate AI adoption across sectors by establishing regulatory sandboxes to test and deploy new AI tools. It also calls for domain-specific efforts (e.g., in healthcare, energy and agriculture) led by NIST to develop national standards and productivity benchmarks for AI systems.
• Support Workforce Development for AI-Related Transitions – The AI Action Plan includes workforce development measures aimed at supporting US workers impacted by AI, such as directing education and training funds toward AI-related skill-building, establishing a research hub to study AI's impact on the labor market and establishing rapid retraining for workers displaced by AI.
• Advance Next-Generation Manufacturing Technologies – The AI Action Plan encourages investment in "next-generation" manufacturing, such as autonomous drones, self-driving cars and robotics. It also encourages the development of public-private partnerships to address supply chain challenges in US robotics and drone manufacturing.
• Invest in AI-Enabled Scientific Research – The AI Action Plan calls for federal investment in automated cloud-enabled laboratories across various research fields. It recommends policy actions to incentivize researchers to publicly release "high-quality datasets" by considering the impact of scientific and engineering datasets from researchers' prior funded efforts when reviewing funding proposals for new projects. The AI Action Plan also recommends the implementation of policies that would require federally funded researchers to disclose non-proprietary, non-sensitive data used in AI-driven research and experimentation. The AI Action Plan also envisions building world-class datasets by establishing minimum data quality standards for AI model training.

Pillar II: Build American AI Infrastructure

The second pillar focuses on strengthening the physical and human infrastructure necessary to support AI development, adoption and deployment while safeguarding against foreign adversary threats. It calls for streamlined permitting processes for data centers, semiconductor manufacturing facilities and energy infrastructure—for instance, through establishing a new categorical exclusion under the National Environmental Policy Act ("NEPA") to cover data center-related actions, expediting environmental permits under several regulations such as the Clean Air Act and Clean Water Act, and using federal lands for data center construction. The AI Action Plan also recommends implementing strict security guardrails to prevent foreign adversaries from infiltrating critical infrastructure. For example, it recommends that the domestic AI computing stack be built on American products and that supporting energy and telecommunications infrastructure remain free from foreign information and communications technology and services.

Key further policy objectives and recommendations under this pillar include:

Develop a Grid to Match the Pace of AI Innovation – The Trump Administration seeks to optimize existing grid resources as much as possible, and to incorporate frontier energy sources such as enhanced geothermal, nuclear fission and fusion.

Restore American Semiconductor Manufacturing – The AI Action Plan aims to remove extraneous policy requirements for CHIPS Act-funded semiconductor manufacturing projects and directs the Department of Commerce and other relevant federal agencies to streamline regulations that slow semiconductor manufacturing efforts.

Build High-Security Data Centers for Military and Intelligence Community Usage – The AI Action Plan discusses the creation of new technical standards for high-security AI data centers.

Train a Skilled Workforce for AI Infrastructure – The AI Action Plan calls for building partnerships with state and local governments and stakeholders to support the creation of industry-driven training programs.

Bolster Critical Infrastructure Cybersecurity – The AI Action Plan proposes establishing an AI Information Sharing and Analysis Center to facilitate threat intelligence sharing across critical infrastructure sectors, directing the Department of Homeland Security to issue guidance to the private sector on remediating and responding to AI-specific vulnerabilities and threats, and promoting secure-by-design AI technologies and applications.

Pillar III: Lead in International AI Diplomacy and Security

The third pillar outlines a strategy to expand the global use of US-developed AI systems, computing hardware, and technical standards through international collaboration. It emphasizes leveraging US participation in diplomatic and standards-setting forums to promote approaches to AI governance that support innovation and investment in US interests. Central to this strategy is the goal of exporting the full AI technology stack, including hardware, models, software, applications and standards, to countries willing to join a proposed "AI Alliance."

The AI Action Plan also calls for coordination with allies to harmonize export control measures (particularly with respect to semiconductor manufacturing subsystems) and to enhance technology protection efforts. Finally, the AI Action Plan highlights the importance of maintaining the capability to assess national security risks associated with advanced AI models and of integrating those assessments into broader technology and security policies.

Key Takeaways

The AI Action Plan aims to place innovation at the core of the US AI policy, in contrast to the more risk-focused approaches adopted by the European Union's AI Act and certain state-level initiatives such as the Colorado AI Act. Businesses may be able to benefit from various proposed incentives, such as regulatory sandboxes and endorsement for open-source and open-weight AI models, but the practical impact in states with existing or emerging AI regulatory frameworks remains uncertain. The AI Action Plan's emphasis on international collaboration and export strategies, such as the proposed "AI Alliance," could also create opportunities for US companies to expand into new markets. On the other hand, businesses may also need to reevaluate their supply chains, partnership structures and compliance programs to avoid inadvertently granting adversaries or entities of concern access to controlled AI technologies. AI companies engaging in government contracting, or whose products may otherwise be evaluated under the forthcoming guidelines on ideological neutrality, should also closely monitor for developments in this area.

Importantly, companies will still be required to comply with state-level AI laws as federal policy to implement the AI Action Plan develops. The way in which federal initiatives will interact with existing state requirements remains uncertain and could vary significantly depending on legislative, regulatory and judicial developments. This uncertainty may persist for some time, particularly in states that have already enacted or proposed comprehensive AI regulatory frameworks. Businesses operating across multiple jurisdictions may therefore experience a period in which both federal and state regimes apply in parallel, with potential overlaps or inconsistencies in scope and enforcement.

Burak Haylamaz (White & Case, Staff Attorney, Los Angeles) contributed to the development of this publication.

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