Apple could be impacted by proposed US export ban on AI, Computer Vision, iPhone processor technology

A document highlighted by former presidential technology and national security advisor R. David Edelman on Twitter reveals the Department of Commerce's Bureau of Industry and Security has requested comments about monitoring the sales of certain technologies to countries outside the United States.

The Bureau of Industry and Security controls the export of "dual use and less sensitive military items" via Export Administration Regulations (EAR), specifically through the Commerce Control List (CCL). The CCL advises of whether specific items need to be handled in specific ways in order to leave the country, such as by acquiring licenses before being exportable to specific locations, and is usually meant to prevent potentially harmful products or technologies from being acquired or misused by bad actors.

The list covers a large number of areas ranging from aerospace and propulsion systems to more sensitive areas, such as chemicals, toxins, microorganisms, or nuclear materials. The list also includes sections for electronics, computers, telecommunications, and information security, with each section covering a wide variety of sensitive areas of concern to national security.

According to the filing, the Bureau notes that there are certain types of "emerging technologies" that are yet to have been included in the CCL, which have yet to be evaluated for their "national security impacts." The filing is a request for public comment on "criteria for identifying emerging technologies that are essential to U.S. national security," due to the potential of being used as conventional weapons, weapons of mass destruction, terrorist applications, intelligence collection, or "could provide the United States with a qualitative military or intelligence advantage."

The list of areas the Bureau wishes comment on is long, and contains quite a few publicly-known technology types. For Artificial Intelligence, this includes neural network and deep learning technologies, computer vision, speech and audio processing, natural language processing, planning, AI cloud technologies, AI chipsets, and the potential for audio and video manipulation technologies.

The AI section covers a number of products and services Apple both offer to consumers, and those it is actively working on. For example, the natural language processing and AI technologies relate to Siri, along with Apple's other machine learning work, while computer vision would cover Face ID and vision systems used in Apple's self-driving vehicle-oriented "Project Titan."

Other general areas raised include the fields of biotechnology, positioning and navigation, quantum information and sensing technology, 3D printing, robotics including drones, brain-computer interfaces, advanced materials, advanced surveillance, and microprocessor technology.

The filing is a request for comments, rather than proposals for restrictions to the named technologies. It is also not unexpected for the government to have an interest in how each technology is used in other countries, as it has a vested interest to prevent U.S. Technology from being used by terrorists in an enemy state against the United States itself.

The wide-ranging nature of the requests is likely to impact the vast majority of big tech companies, Apple included, and is almost certainly going to draw commentary from those working in each field. In the case of Apple, restrictions on AI technology could hypothetically prevent the company from selling iPhones in specific markets completely, or force it to produce a version with features cut to comply with licensing rules.

The deadline for comments is on a highly-aggressive timetable during a holiday season where the federal government is normally pretty quiet. The deadline of December 19, 2018 gives only a one-month window for responses from the public before the Bureau starts pressing the matter further.

According to the filing, comments can be submitted through the Federal eRulemaking Portal using identification number "BIS 2018-0024", as well as via the mail.