No CCP Consultants Act

Prohibits the Department of State from working with contractors who have previously consulted for or fail to disclose conflicts of interest relating to foreign entities that pose national security or foreign policy concerns, including any Chinese state-owned entity or entity under the ownership and control of the PRC or CCP that is engaged in national security industries, such as producing AI-related products and services.

  • Authority: United States Congress
  • Parent authority: Federal government
  • Jurisdiction: United States
  • Collections: U.S. federal laws
  • Most recent activity: Defunct
  • Most recent activity date: 2025-01-03

Risk subdomain coverage

Minimal coverage — Brief mention but no specific mitigations, recommendations or governance measures relating to the risk subdomain are described.

  • Disinformation, surveillance, and influence at scale
  • Cyberattacks, weapon development or use
  • Competitive dynamics

All other risk subdomains had no coverage in this document.

Risk Coverage Summary

This document primarily addresses national security risks related to foreign influence and conflicts of interest in government contracting. It has minimal direct coverage of AI-specific risks, with only brief mention of AI as one of several national security industries. The primary focus is on preventing foreign entities from gaining influence through consulting relationships with the Department of State.

Sector coverage

Good coverage — Comprehensive governance measures or mitigations with clear procedures relating to the sector are explicitly described.

  • Professional & Technical Services
  • National Security

Minimal coverage — Brief mention but no specific mitigations, recommendations or governance measures relating to the sector are described.

  • Agriculture, Mining, Construction & Manufacturing
  • Information
  • Scientific Research & Development Services

All other sectors had no coverage in this document.

Sectors Summary

This document primarily governs Professional and Technical Services (consulting services to the Department of State) and indirectly references multiple national security industries including Information (AI products/services), Scientific Research and Development Services, Manufacturing (semiconductors, biotechnology), and Mining (critical minerals). The governance applies to contractors and consultancies that work with the Department of State.

Legislative Status

Hard Law

Legislative Status Summary

This is a binding legislative act from the United States Congress with mandatory language, explicit enforcement mechanisms including contract termination and debarment, and penalties for non-compliance.

Actors

Proposer

  • Entity Types: AI_Governance_Actor
  • Summary: The document is a Congressional bill as indicated by the opening text 'Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled'. Congress is the proposing authority for this legislation.

Target

  • Entity Types: AI_Developer
  • Summary: The Act targets 'covered consultancies' which are companies that provide consulting services and have relationships with covered entities. The definition of national security industries explicitly includes 'producing products or services that use artificial intelligence', making AI developers who consult for foreign entities a primary target.

Enforcer

  • Entity Types: AI_Governance_Actor
  • Summary: The Secretary of State is designated as the primary enforcement authority with power to terminate contracts, initiate debarment proceedings, approve certifications, and issue procurement policies. Multiple other federal agencies are involved in a consultative capacity for guidance development.

Monitor

  • Entity Types: AI_Governance_Actor
  • Summary: The Secretary of State monitors compliance through disclosure requirements and certification processes. The Office of Foreign Assets Control maintains the NS-CMIC-List, and the Department of Commerce maintains various export control lists that are referenced for monitoring covered entities.

AI Lifecycle Stages

Lifecycle stages covered by the documents, as defined in the OECD Framework for the Classification of AI Systems

No lifecycle stages identified.

AI Lifecycle Summary

The document does not directly govern AI lifecycle stages. It focuses on procurement and contracting restrictions for the Department of State, preventing contracts with consultancies that have relationships with foreign entities in national security industries, including AI. AI is mentioned only as one of several national security industries subject to these restrictions.

Technical Scope

Terms relating to technical scope that are mentioned or implicitly referenced in the document

No technical scope terms identified.

Technical Scope Summary

The document mentions AI only in the context of defining national security industries. It refers to 'producing products or services that use artificial intelligence' as one category of national security industry but does not define AI models, AI systems, or any specific AI technical concepts. There is no mention of frontier AI, general purpose AI, foundation models, generative AI, predictive AI, open-weight models, or compute thresholds.

https://www.congress.gov/bill/118th-congress/house-bill/6146
https://agora.eto.tech/instrument/322
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Document data from AGORA, CSET Emerging Technology Observatory.