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Framework for Artificial Intelligence Diffusion
- chriskanan 2y agoThe most salient thing in the document is that it put export controls on releasing the weights of models trained with 10^26 operations. While there may be some errors in my math, I think that corresponds to training a model with over 70,000 H100s for a month. I personally think the regulation is misguided, as it assumes we won't identify better algorithms/architectures. There is no reason to assume that the level of compute leads to these problems. Moreover, given the emphasis on test-time compute nowadays and that it seems like a lot of companies have hit a wall with performance gains with trying to scale LLMs at train-time, I especially think this regulation isn't especially meaningful.
- HeatrayEnjoyer 2y agoWe can't let perfect be the enemy of good, regulations can be updated. Capping FLOPs is a decent starter reg.
- reaperman 2y agoCounterpoint would be the $7.25 minimum wage. It can be updated, but politicians aren't good at doing that. In both cases (FLOPS and minimum wage), at least a lower bound for inflation should be included: Something like: 10^26 FLOPS * 1.5^n where n is the number of years since the regulation was published.
- Cyph0n 2y agoI don’t see an issue here, because our legislators probably care more about FLOPS than humans.
- tivert 2y ago> Something like: 10^26 FLOPS * 1.5^n where n is the number of years since the regulation was published. Why would you want to automatically increase the cap algorithmically like that? The purpose of a regulation like this is totally different than the minimum wage. If the point is to keep and adversary behind, you want them to stay as far behind as you can manage for as long as possible. So if you increase the cap, you want only increase it when it won't help the adversary (because they have alternatives, for instance).
- deleted 2y ago[deleted]
- parsimo2010 2y agoTraditional export control applied to advanced hardware is because the US doesn't want its adversaries to have access to things that erode the US military advantage. But most hardware is only controlled at the high-end of the market. Once a technology is commodotized, the low-end stuff is usually widely proliferated. Night vision goggles are an example, only the latest generation technology is controlled, and low-end stuff can be bought online and shipped worldwide. Applying this to your thoughts about AI, is that as the efficiency of training gets better, the ability to train models is commodotized, and those models would not be considered to be advantageous and would not need to be controlled. So maybe setting the export control based on the number of operations is a good idea- it naturally allows efficiently trained models to be exported since they wouldn't be hard to train in other countries anyway. As computing power scales maybe the 10^26 limit will need to be revised, but setting the limit based on the scale of the training is a good idea since it is actually measurable. You couldn't realistically set the limit based on the capability of the model since benchmarks seem become irrelevant every few months due to contamination.
- ein0p 2y agoI wonder what makes people believe that the US currently enjoys any kind of a meaningful "military advantage" over e.g. China? After failing to defeat the Taliban and running from the Houthis especially. This seems like a very dangerous belief to have. China has 4x the population and outproduces us 10:1 in widgets (2:1 in dollars). Considering just e.g. steel, China produces about 1 billion metric tons of it per year. We produce 80 million tons. Concrete? 2.4B tons vs 96M tons. 70+% of the world's electronics. Their shipbuilding industry is 230x more productive (not a typo). Etc, etc. The short term profits US businesses have been enjoying over the past 25 years came at a staggering long term cost. The sanctions won't even slow down the Chinese MIC, and in the long run they will cause them to develop their own high end silicon sector (obviating the need for our own worldwide). They're already at 7nm, at a low yield. That is more than sufficient for their MIC, including the AI chips used there, currently and in the foreseeable future.
- parsimo2010 2y agoa) just because the government has policies that doesn’t mean they are 100% effective b) export controls aren’t expected to completely prevent a country from gaining access to a technology, just make it take longer and require more resources to achieve You may also be misunderstanding how much money China will spend to develop their semiconductor industry. Sure, they will eventually catch up to the West, but the money they spend along the way won’t be spent on fighter jet, missiles, and ships. It’s still preferable (from the US perspective) to having no export controls and China being able to import semiconductor designs, manufacturing hardware, and AI models trained using US resources. At least this way China is a few months behind and will have to spend a few billion Yuan to achieve it.
- etiam 2y agoCould be nice with some artificial pressure to use more efficient algorithms though. The current game of just throwing in more data centers and power plants may be kind of convenient for those who can afford it, but it's also intellectually embarrassing.
- thorum 2y agoThe practical problem I see is that unless US AI labs have perfect security (against both cyber attacks and physical espionage), which they don’t, there is no way to prevent foreign intelligence agencies from just stealing the weights whenever they want.
- iugtmkbdfil834 2y agoThis. We put toasters on the internet and are no longer surprised, when services we use send us breach notices at regular intervals. The only thing this regulation would do, as written, is add an interesting choke point for compliance regulators to obsess over.
- kube-system 2y agoOf course. They're mitigations, not preventions. Few defenses are truly preventative. The point is to make it difficult. They know bad actors will try to circumvent it. This isn't lost on the authors. It is explicitly recognized in the document: > The risk is even greater with AI model weights, which, once exfiltrated by malicious actors, can be copied and sent anywhere in the world instantaneously.
- thorum 2y ago> The point is to make it difficult. Does it, though?
- permo-w 2y agothis is like saying that regulating automatic weapons is misguided because someone might invent a gun that is equally dangerous without being automatic
- iugtmkbdfil834 2y agoThis appears to be a very shallow take and lazy argument that does not capture even basic nuance of the issue at hand. For the sake of expanding it a little and hopefully moving it in the right direction, I will point out that BIS framework discusses use of advanced models as dual use goods ( ie. not automatically automatic weapons ). edit(removed exasparated sigh; it does not add anything )
- logicchains 2y ago>The most salient thing in the document is that it put export controls on releasing the weights of models trained with 10^26 operations. Does this affect open source? If so, it'll be absolutely disastrous for the US in the longer term, as eventually China will be able to train open weights models with more than that many operations, and everyone using open weights models will switch to Chinese models because they're not artificially gimped like the US-aligned ones. China already has the best open weights models currently available, and regulation like this will just further their advantage.
- gyre 2y ago"consistent with its general practice, BIS will not require a license for the export of the model weights of open-weight models"
- resters 2y agoStrong opposition to this regulation seems to be one of the main things that led a16z, Oracle, etc. to go all in for Donald Trump. It's interesting that Meta too fought the regulation by its unprecedented open sourcing of model weights. Regardless of who is currently in the lead, China has its own GPUs and a lot of very smart people figuring out algorithmic and model design optimizations, so China will likely be in the lead more obviously within 1-2 years, both in hardware and model design. This law is likely not going to be effective in its intended purpose, and it will prevent peaceful collaboration between US and Chinese firms, the kind that helps prevent war. The US is moving toward a system where government controls and throttles technology and picks winners. We should all fight to stop this.
- 9283409232 2y agoI don't think you're wrong but Big Tech is bending the knee to Trump because he will be picking the winners.
- tokioyoyo 2y ago> The US is moving toward a system where government controls and throttles technology and picks winners What else can it do? They don’t want to lose their lead, and whatever restrictions they’ve been putting on China et al. have let the exact desired outcomes so far. The idea is to try to slow down the beast that has very set goals (e.g. to become high tech manufacturing and innovation center), and try to play catch up (like on-shoring some manufacturing). Personally, I’m skeptical that it will work, because by raw number of hands on deck, they have the advantage. And it’s fairly hard when your institutional knowledge of doing big things is a bit outdated. I would argue, a good bet in North America would be finding a financially engineered solution to get Asian companies bring their workers and knowledge to ramp us up. Kinda like the TSMC factory. Basically the same thing as China did in 2000s with western companies.
- logicchains 2y ago> They don’t want to lose their lead, and whatever restrictions they’ve been putting on China et al. have let the exact desired outcomes so far. They absolutely have not. The best open weights LLM is Chinese (and it's competitive with the leading US closed source ones), and around 10x cheaper both to train and to serve than its western competitors. This innovation in efficiency was largely brought about by US sanctions limiting GPU availability.
- neilv 2y agoThis `regulations.gov` is leaking info on who accesses what, to Google (via `www.google-analytics.com` tracker). There should be a federal regulation about that.
- datadrivenangel 2y agoIt's for the government's google analytics account, which is open data: https://analytics.usa.gov/general-services-administration https://analytics.usa.gov/general-services-administration
- dooglius 2y agoParent is unhappy with the fact the data is being tracked and analyzed at all, not about the closed or open nature of the analytics.
- neilv 2y agoI'm unhappy that: (1) Google is getting this information; (2) because Google is involved, who reads what is attributable to individuals; (3) citizens don't realize this.
- intunderflow 2y agoWe're sorry, an error has occurred A general error occurred while processing your request.
- geuis 2y agoThis smells a lot like the misguided crypto export laws in the 90s that hampered browser security for years.
- philjohn 2y agoAnd don't forget the amazing workaround Zimmerman of PGP fame came up with - the source code in printed form was protected 1A speech, so it was published, distributed, and then scanned and OCR'd outside the US - https://en.wikipedia.org/wiki/Pretty_Good_Privacy#Criminal_investigation https://en.wikipedia.org/wiki/Pretty_Good_Privacy#Criminal_i...
- mmaunder 2y agoAnd don’t forget Thawte which ended up selling strong SSL outside the US, cornering the international market thanks to US restrictions, and getting bought by Verisign for $600M.
- z2 2y agoI for one would love to see model weights published in hardcover book form.
- dkga 2y agoWhat a throwback to the time when some edgy folks would share printed codes in Pascal… I even remember seeing a hard copy of a binary in hex which was best not to execute.
- cheald 2y agoIt might be somewhat prohibitive to print the model weights for any sufficiently large model, though.
- galangalalgol 2y agoUsing 2d barcodes you can fit ~20MB per page. Front and back you could probably fit a model that violated the rule on less than a thousand pages. Edit: maybe 10k pages
- mlfreeman 2y agoWhat do the regulators writing this intend for this to slow down/stop? I can't seem to find any information about that anywhere.
- chatmasta 2y agoMaybe they intend for it to speed up/start implementation of federal agencies and regulations. The intent is to exert control over an emerging market while it’s still comprised of cooperative participants. Regulators want to define the regulatory frameworks rather than relying on self-policing before it’s “too late.” Let’s see if this survives the next administration. Normally I’d be skeptical, but Musk has openly advocated about the “dangers” of AI and will likely embrace attempts to regulate it, especially since he’s in a position to benefit from the regulatory capture. In fact he’s doubly well-placed to take advantage of it. Regardless of his politics, xAI is a market leader and would already be naturally predisposed to participate in regulatory capture. But now he also enjoys unprecedented influence over policymaking (Mar a Lago) and regulatory reform (DOGE). It’s hard to see how he wouldn’t capitalize on that position.
- chronic4930018 2y ago> Regardless of his politics, xAI is a market leader Lol what? The only people who think this are Elon fanboys. I guess you think Tesla is the self-driving market leader, too. Okay.
- chatmasta 2y agoI don’t even use it. But in terms of funding, it’s in the top 5, according to Crunchbase data [0]. [0] https://news.crunchbase.com/ai/startup-billion-dollar-fundraisers-openai-anthropic/ https://news.crunchbase.com/ai/startup-billion-dollar-fundra...
- miohtama 2y agoIt's also quite decent, giving a lot of free request so I have switched from Claude.
- chriskanan 2y agoI have no idea if comments actually have any impact, but here is the comment I left on the document: I am Christopher Kanan, a professor and AI researcher at the University of Rochester with over 20 years of experience in artificial intelligence and deep learning. Previously, I led AI research and development at Paige, a medical AI company, where I worked on FDA-regulated AI systems for medical imaging. Based on this experience, I would like to provide feedback on the proposed export control regulations regarding compute thresholds for AI training, particularly models requiring 10^26 computational operations. The current regulation seems misguided for several reasons. First, it assumes that scaling models automatically leads to something dangerous. This is a flawed assumption, as simply increasing model size and compute does not necessarily result in harmful capabilities. Second, the 10^26 operations threshold appears to be based on what may be required to train future large language models using today’s methods. However, future advances in algorithms and architectures could significantly reduce the computational demands for training such models. It is unlikely that AI progress will remain tied to inefficient transformer-based models trained on massive datasets. Lastly, many companies trying to scale large language models beyond systems like GPT-4 have hit diminishing returns, shifting their focus to test-time compute. This involves using more compute to "think" about responses during inference rather than in model training, and the regulation does not address this trend at all. Even if future amendments try to address test-time compute, the proposed regulation seems premature. There are too many unknowns in future AI development to justify using a fixed compute-based threshold as a reliable indicator of potential risk. Instead of focusing on compute thresholds or model sizes, policymakers should focus on regulating specific high-risk AI applications, similar to how the FDA regulates AI software as a medical device. This approach targets the actual use of AI systems rather than their development, which is more aligned with addressing real-world risks. Without careful refinement, these rules risk stifling innovation, especially for small companies and academic researchers, while leaving important developments unregulated. I urge policymakers to engage with industry and academic experts to refocus regulations on specific applications rather than broadly targeting compute usage. AI regulation must evolve with the field to remain effective and balanced. --- Of course, I have no skin in the game since I barely have any compute available to me as an academic, but the proposed rules on compute just don't make any sense to me.
- 2y ago
- chriskanan 2y agoI'm not sure why the link no longer works, but this one works. The link should be updated to this one: https://www.federalregister.gov/documents/2025/01/15/2025-00636/framework-for-artificial-intelligence-diffusion https://www.federalregister.gov/documents/2025/01/15/2025-00...
- cube2222 2y agoIt’s worth noting that this splits countries into three levels - first without restrictions, second with medium restrictions, third with harsh restrictions. And the second level, for some reason, includes (among others) a bunch of countries that would normally be seen as close US allies - e.g. some NATO countries (most of Central/Eastern Europe).
- inglor_cz 2y agoincludes (among others) a bunch of countries that would normally be seen as close US allies - e.g. some NATO countries (most of Central/Eastern Europe). Yeah, this is really a bit insulting.
- tivert 2y ago>> And the second level, for some reason, includes (among others) a bunch of countries that would normally be seen as close US allies - e.g. some NATO countries (most of Central/Eastern Europe). > Yeah, this is really a bit insulting. So you're insulted some country of other wasn't included in: > First, this rule creates an exception in new § 740.27 for all transactions involving certain types of end users in certain low-risk destinations. Specifically, these are destinations in which: (1) the government has implemented measures to prevent diversion of advanced technologies, and (2) there is an ecosystem that will enable and encourage firms to use advanced AI models to advance the common national security and foreign policy interests of the United States and its allies and partners. ? IMHO, it's silly to get insulted over something like that. Your feelings are not a priority for an export control law. Taiwan, even though it's a US ally, is only allowed limited access to certain sensitive US technology it deploys (IIRC, something about Patriot Missile seeker heads, for instance), because their military is full of PRC spies (e.g. https://www.smh.com.au/technology/chinese-spies-target-taiwans-usmade-defenses-20120322-1vkps.html https://www.smh.com.au/technology/chinese-spies-target-taiwa...), so if they had access the system would likely be compromised. It's as simple as that.
- surfingdino 2y agoSomeone still sees Eastern Europe as a provider of cheap brainpower. This is insulting.
- PostOnce 2y agoLooks down to me. https://archive.is/F78tf https://archive.is/F78tf
- wslh 2y agoThis feels like déjà vu from the crypto wars (1990s). If that experience helps, it is impossible to repress knowledge without violence, and it motivates more people to hack the system. Good times ahead "PGP released its source code as a book to get around US export law" <https://news.ycombinator.com/item?id=7885238 https://news.ycombinator.com/item?id=7885238>
- Hizonner 2y agoNot the same situation at all. PGP would run on any computer you happened to have around. The source code was small enough to fit in a book. The people who already had the code wanted to release it. Lots of people could have rewritten it relatively quickly. The ML stuff they're worried about takes a giant data center to train and an unusually beefy computer even to run. The weights are enormous and the training data even more enormous. Most of the people who have the models, especially the leading ones, treat them as trade secrets and also try to claim copyright in them. You can only recreate them if you have millions to spend and the aforementioned big data center.
- wslh 2y ago> The ML stuff they're worried about takes a giant data center to train and an unusually beefy computer even to run. Now, consider this: the Palm [1] couldn’t even create an RSA [2] public/private key pair in “user time” The pace of technological advancement is astonishing, and new techniques continually emerge to overcome current limitations. For example, in 1980, Intel was selling mathematical coprocessors [3] that were cutting-edge at the time but would be laughable today. It’s reasonable to expect that the field of machine learning will follow a similar trajectory, making what seems computationally impractical now far more accessible in the future. [1] https://en.wikipedia.org/wiki/Palm_(PDA) https://en.wikipedia.org/wiki/Palm_(PDA) [2] https://en.wikipedia.org/wiki/RSA_(cryptosystem) https://en.wikipedia.org/wiki/RSA_(cryptosystem) [3] https://es.wikipedia.org/wiki/Intel_8087 https://es.wikipedia.org/wiki/Intel_8087
- clhodapp 2y agoOne interesting geopolitical fact about this document that's not being discussed much is the way it includes Taiwan in lists of "countries". Usually, the US government tries not to do that.
- kube-system 2y agoOnly in some diplomatic contexts. https://www.cia.gov/the-world-factbook/countries/taiwan/ https://www.cia.gov/the-world-factbook/countries/taiwan/
- veggieroll 2y agoThe compute limit is dead on arrival, because models are becoming more capable with less training anyways. (See DeepSeek, Phi-4)
- pjmlp 2y agoIt is going to be like it was in the 1990s with PGP and such all over again.
- deleted 2y ago[deleted]
- ChrisArchitect 2y agoRelated: WH Executive Order Affecting Chips and AI Models https://news.ycombinator.com/item?id=42683251 https://news.ycombinator.com/item?id=42683251
- United857 2y agoIt seems some EU countries are unrestricted but others are. How is this compatible with the EU single market/customs union?
- djoldman 2y agoMore information here: https://www.federalregister.gov/documents/2025/01/15/2025-00636/framework-for-artificial-intelligence-diffusion https://www.federalregister.gov/documents/2025/01/15/2025-00...
- miovoid 2y agoPerhaps this regulation will be a major force for next gen symbolic AI systems.
- saberience 2y agoWhat’s the point in this? Isn’t Trump going to just cancel this immediately on Monday? I don’t see how we can assume it will be enacted at all.
- casebash 2y agoMost of the comments here only make sense under a model where AI isn't going to become extremely powerful AI in the near term. If you think upcoming models aren't going to be very powerful, then you'll probably endorse business-as-usual policies such as rejecting any policy that isn't perfect or insisting on a high bar of evidence before regulating. On the other hand, if you have a world model where AI is going to provide malicious actors with extremely powerful and dangerous technologies within the next few years, then instead of being radical, proposal like this start appearing extremely timid.
- 1vuio0pswjnm7 2y agoUnblocked: https://web.archive.org/web/20250117042813if_/https://www.federalregister.gov/documents/2025/01/15/2025-00636/framework-for-artificial-intelligence-diffusion https://web.archive.org/web/20250117042813if_/https://www.fe...
- lincpa 2y ago[dead]