Securing America's compute advantage: Anthropic’s position on the diffusion rule

In response to the Department of Commerce's "Framework for Artificial Intelligence Diffusion" interim final rule, Anthropic has submitted detailed analysis and recommendations for maintaining and strengthening export controls on advanced semiconductors. At the heart of our recommendations is a clear message: maintaining America's compute advantage through export controls is essential for national security and economic prosperity as powerful new AI systems are developed in the coming years.

The "Diffusion Rule," published in January 2025, establishes export controls on advanced AI chips and model weights worldwide. The Diffusion Framework also creates a three-tier system based on national security risk. Tier 1 includes close allies with few restrictions, Tier 2 includes most other countries with some limits, and Tier 3 includes adversarial nations with strict controls.

The first Trump Administration correctly diagnosed that AI will be central to strategic competition with China, and that the United States can and should use export controls to maintain and strengthen its AI leadership. While the U.S. still maintains a lead in AI development, Chinese AI labs like DeepSeek have made significant progress, using chips obtained before export controls went into effect, and underscore the importance of strong export controls on advanced chips.

2. Reduce the no-license compute threshold for Tier 2 countries . Currently, countries in Tier 2 can buy the equivalent of 1,700 NVIDIA H100 advanced chips without needing government permission—roughly $40 million worth of technology. This creates a potential loophole for smuggling, as people can make multiple purchases just under this limit to avoid scrutiny. We recommend lowering this threshold so that more transactions would require review, making it harder for smugglers to exploit this gap.

Compute Advantage is Critical: Advanced AI systems require massive computing power to train and operate. The U.S. currently leads in advanced semiconductor technology, and export controls capitalize on the trend of computing power doubling every two years, so while U.S. chip technology continues advancing, China’s progress is slowed. This growing efficiency gap means that by 2027, countries using older chips could face AI training costs that are ten times higher than those with cutting-edge American technology.

DeepSeek Shows Controls Work: Chinese AI companies like DeepSeek openly acknowledge that chip restrictions are their primary constraint, requiring them to use 2-4x more power to achieve similar results to U.S. companies. DeepSeek also likely used frontier chips for training their systems, and export controls will force them into less efficient Chinese chips.

Cement America’s Infrastructure Lead: Without strong controls, AI infrastructure development for frontier-scale training could shift overseas (similar to solar panels and batteries), threatening U.S. strategic advantage. The U.S. share of global semiconductor production has fallen from 40% in 1990 to just 12% today, with 90% of the world's leading-edge semiconductors now made outside the U.S. This offshoring represents a strategic vulnerability, and we must not make the mistake again with AI. The Diffusion Framework addresses this risk through domestic compute requirements and foreign compute caps, ensuring the coming AI infrastructure buildout happens in America by American firms. Current supply constraints, combined with the framework's global export regime, create clear incentives for other nations: accessing large-scale cutting-edge compute requires investing in U.S. AI infrastructure and complying with American export controls.