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Executive Order Creates Voluntary Regulatory Regime of Frontier AI Models

By Matthew Ferraro, Kate Growley & Rajeev Raghavan on June 3, 2026
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The president’s Executive Order, “Promoting Advanced Artificial Intelligence Innovation and Security,” directs federal agencies to develop a voluntary process through which AI developers may submit frontier models for government review 30 days prior to public release. It also establishes a suite of complementary measures, including an AI cybersecurity clearinghouse, expanded federal hiring for cybersecurity roles, and a directive to the U.S. Department of Justice to prioritize prosecution of AI-enabled criminal activity. Click here to continue reading the full version of this alert.

Tags: AI
Photo of Matthew Ferraro Matthew Ferraro

Matthew F. Ferraro is a partner in Crowell & Moring’s Privacy and Cybersecurity Group, where he helps clients address complex regulatory matters at the intersection of advanced technology, national security, and crisis management. He advises leading organizations on high-impact matters related to artificial

…

Matthew F. Ferraro is a partner in Crowell & Moring’s Privacy and Cybersecurity Group, where he helps clients address complex regulatory matters at the intersection of advanced technology, national security, and crisis management. He advises leading organizations on high-impact matters related to artificial intelligence (AI) and other emerging technologies, cyberattacks, domestic and international privacy compliance, internal investigations, foreign direct investment reviews, and high-stakes crises.

Before joining the firm, Matthew served as the Senior Counselor for Cybersecurity and Emerging Technology to the Secretary of Homeland Security. As a principal advisor to the Secretary and a member of the U.S. Department of Homeland Security’s leadership team, he served at the heart of U.S. government policymaking around AI and cybersecurity. He assisted in the development and drafting of key AI, cyber, and technology policies and regulations; advised on the deployment of AI to fulfill the department’s missions; and counseled on cyber-incident responses and investigations. Matthew also helped establish and served as the Executive Director of the Artificial Intelligence Safety and Security Board, a flagship public-private advisory committee focused on AI’s use in critical infrastructure and chaired by the Secretary and composed of industry, nonprofit, and government luminaries.

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Photo of Kate Growley Kate Growley

Businesses around the globe rely on Kate M. Growley to navigate their most challenging digital issues, particularly those involving cybersecurity, artificial intelligence, digital infrastructure, and their intersection with national security. Clients seek her guidance on proactive compliance, incident response, internal and government-facing investigations…

Businesses around the globe rely on Kate M. Growley to navigate their most challenging digital issues, particularly those involving cybersecurity, artificial intelligence, digital infrastructure, and their intersection with national security. Clients seek her guidance on proactive compliance, incident response, internal and government-facing investigations, and policy engagement. With a unique combination of legal, policy, and consulting experience, Kate excels in translating complex technical topics into advice that is practical and informed by risk and business needs.

Kate has extensive experience working with members of the U.S. government contracting community, especially those within the Defense Industrial Base. She has partnered with contractors from every major sector, including technology, manufacturing, health care, and professional services. Kate is an IAPP AI Governance Professional (AIGP) and a Certified Information Privacy Professional for both the U.S. private and government sectors (CIPP/G and CIPP/US). She is also a Registered Practitioner with the U.S. Cybersecurity Maturity Model Certification (CMMC) Cyber Accreditation Body (AB).

Having lived in Greater China for several years, Kate also brings an uncommon understanding of digital and national security requirements from across the Asia Pacific region. She has notable experience with the regulatory environments of Australia, Singapore, Japan, and Greater China—including the growing regulation of data flows between the latter and the United States.

Kate is a partner in the firm’s Washington, D.C., office, as well as a senior director in the firm’s consultancy Crowell Global Advisors, to which she was seconded for several years. She is a founding member of the firm’s Privacy & Cybersecurity Group and part of the firm’s AI Steering Committee. She has been internationally recognized by Chambers and named a “Rising Star” by both Law360 and the American Bar Association (ABA). She has held numerous leadership positions in the ABA’s Public Contract Law and Science & Technology Sections and has been inducted as a lifetime fellow in the American Bar Foundation.

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Photo of Rajeev Raghavan Rajeev Raghavan

Rajeev Raghavan is a former special counsel to the Director of the Federal Bureau of Investigation (FBI) and federal prosecutor who guides clients through high-stakes cybersecurity and privacy incidents, government investigations and enforcement actions, sensitive national security matters, and litigation.

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  • Posted in:
    Technology and AI
  • Blog:
    State AG Blog
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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