National Security Presidential Memorandum/NSPM-11

 

On 5 June 2026 President Trump issued a Presidential Memorandum--National Security Presidential Memorandum/NSPM-11, rescinding the Biden Presidency's National Security Memorandum-25 and associated guidance. It was accompanied by an explanatory Fact Sheet: President Donald J. Trump Signs Historic Directive on AI in the National Security Enterprise. This adds another layer to the emerging strategies and principles for implementing the new national security framework within which AI development in markets is to be undertaken (See my discussion in Brief Reflections on the Cognitive Semiotics of President Trump's Executive Order; Promoting Advanced Artificial Intelligence Innovation and Security (2 June 2026). And, ironically it recalls key arguments in Leopold Aschenbrenner's 2024 reflection, "Situational Awareness" (see, e.g., Satyricon, or Tragedy at Play--Artificial Intelligence and the New World Order: Leopold Aschenbrenner, "Situational Awareness").

As understood by its authors, the National Security Presidential Memorandum/NSPM-11 is meant to attain the following objectives:

The Memorandum directs the national security enterprise to accelerate AI adoption to meet surging demand, adapt the best commercial and open-source technologies for mission use, assure that fielded systems are robust, steerable, controllable, and preserve clear lines of accountability under the Constitutional chain of command.

The Memorandum strengthens national security capabilities, directing the rapid onboarding of the most advanced AI models from multiple vendors, driving the buildout of next-generation, high-security computing facilities to run future AI systems at scale, and bolstering the talent pipeline, including by establishing an AI National Security Strategic Reserve of top non-governmental experts.

The Memorandum directs the Secretary of War to issue an updated directive on autonomy in weapon systems and requires annual review of key guidance across the national security enterprise to keep pace with the rapidly advancing AI frontier. 

The Memorandum directs departments and agencies to ensure that no entity, commercial or otherwise, can disable, degrade, or modify an AI system that American warfighters depend on without prior approval. It also offers new partnerships with willing private-sector companies to secure America’s cutting-edge AI against global threats. 

The Memorandum rescinds and replaces the Biden Administration’s NSM-25, an outdated document that burdened American AI adoption with ideological mandates and fostered dangerous single-vendor dependencies that left our warfighters exposed. (Fact Sheet: President Donald J. Trump Signs Historic Directive on AI in the National Security Enterprise)

 President Biden's NSM-25, which is reproduced below,  was closely aligned with President Biden's own Executive Order rationalizing AI within its national security context, Executive Order 14110—Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence. That document, in turn, was closely incorporated the critical objectives of the Biden Administration with respect to safe, secure and ethical AI the development and deployment of which would be grounded in a labor and civil rights and equity based framework.  Indeed, the Trump and Biden Administration emphasized different priorities reflected in the approach to implementation. The Biden Administration's NSM 25 emphasized among other things the need to balance civil rights against national security, in ways that could be respectful of markets. :

(h) In this effort, the United States Government must also protect human rights, civil rights, civil liberties, privacy, and safety, and lay the groundwork for a stable and responsible international AI governance landscape. Throughout its history, the United States has been a global leader in shaping the design, development, and use of new technologies not only to advance national security, but also to protect and promote democratic values. The United States Government must develop safeguards for its use of AI tools, and take an active role in steering global AI norms and institutions. The AI frontier is moving quickly, and the United States Government must stay attuned to ongoing technical developments without losing focus on its guiding principles.

 The Trump Administration kept much of the old structure, its architecture hard hired into the neural network of the American system--markets driven ("national security enterprise shall adapt commercial or open-source AI technologies, leveraging the most cutting-edge capabilities available from diverse suppliers across the private sector, large and small, while ensuring that AI technologies chosen are optimized for their intended use" National Security Presidential Memorandum/NSPM-11, §2(b)), refashioning the terms of the Biden Administration (safe, secure, and ethical markets that is competitive in the way that the Biden Administration understood that term)--to align with his America First principles in which economic policy and national security are fused, mediated by markets driven innovation (elaborated in The Conceptual Architecture of America First—Ideological Transactionalism and the Case of Cuba). In this version, the  specifies objectives that are sector specific.

AI will be among the most transformative technologies for national security in American history. Used appropriately, it can help protect troops on the battlefield, enable precise operations that minimize harm to civilians, and ensure the United States maintains technological overmatch against every adversary.

The national security enterprise will never develop or deploy AI to censor free speech, embed ideological bias, or conduct unlawful surveillance against the American people. Civil liberties and Constitutional protections are non-negotiable.

The Memorandum makes accountability a central pillar of AI adoption, reinforcing a chain of command that runs from the American people through their elected President to the warfighter. Commanders, directors, and agency heads remain accountable for ensuring these obligations are met at every level. (Fact Sheet: President Donald J. Trump Signs Historic Directive on AI in the National Security Enterprise)

Section 2 sets oput the normative framework and objectives. Section 3 is the operative provision. Section 3(a)directs the "Secretary of War [to] issue an update to DOD Directive 3000.09 on Autonomy in Weapon Systems, to be reviewed annually to account for the rapidly evolving capabilities of AI systems, to ensure the deliberate adoption of AI systems that respect the chain of command and operational authorities." Section 3(b) directs contract termination for default or for convenience contracts with companies that have repeatedly demonstrated a pattern of conduct that is inconsistent with policies laid out in section 2 of this memorandum. Section 3( c) directs the development of an appropriate policy for governance of AI use in national security systems, including implementation and reporting requirements, consistent with .AI governance requirements for non-national security systems, such as that in OMB guidance OMB memorandum M-25-21. Section 4 then targets national security capabilities through intense interactions (really the interpenetration) of the national security and AI sectors, one private and markets centered, the other public and grounded in a very broad understanding both of national defense and of the character of threat.  

 

 

Now Available Vol 39(5) Vol. 38(5) International Journal for the Semiotics of Law/ Revue internationale de Sémiotique juridique (IJSL)--"Exploring Tensions in Law and Legal Semiotics"

 

 

I am delighted to announce that Volume 39(5) of the International Journal for the Semiotics of Law is now available online.  It is a special issue, the theme of which is "Exploring Tensions in Law and Legal Semiotics" guest edited by Wei Yu, Kieran Tranter, and René Cornish. This Special Issue brings together a diverse range of contributions examining the tensions, complexities, and interconnections that shape law, legal language, and legal semiotics in contemporary societies.

The editors have this to say in the opening chapter (Tensions in Law: Contestation and Interconnection):

 The inherent tensions of law lie in the competing understanding towards the legal concepts and principles. However, the understanding of the representation of the legal content, namely legal texts, can be different from judge to judge and from lawyer to lawyer. Opposing opinions get negotiated and settled under the legal framework. For example, in the judicial decisions of the common law legal system, judges who have different interpretations of legislation express their dissenting opinions in legal judgments. Such complex interpretations add another layer of tension for the legal disputes. And the representation of legal content itself can be different from the legal ideals in mind as well, as discussed above.

 Many of the articles are open access.  Titles, authors  and links are provided below.  

 

Marxist Theory as a Productive Force of Social Revolution (社会革命); Considering 秦宣 邱安琪, 在守正创新中推动马克思主义理论学科高质量发展 [Promoting the High-Quality Development of the Discipline of Marxist Theory Through Upholding Integrity and Innovation]

 

Pix credit here (Science is the force of production, 1979)

  Qin Xuan, Director of the Institute of Xi Jinping Thought on Socialism with Chinese Characteristics for a New Era at Renmin University of China, and Qiu Anqi, Lecturer at the School of Marxism at Renmin University of China have published a most interesting essay. Entitled 在守正创新中推动马克思主义理论学科高质量发展 [Promoting the High-Quality Development of the Discipline of Marxist Theory Through Upholding Integrity and Innovation], the essay was originally published in 光明日报 [Guanming Daily] (21 May 2026) .  

Everything is under construction in China. That is as it ought to be. And it ought to be as a function of the fundamental political line of Chinese Marxist Leninism--a fundamental political line built into the driving force of socialist modernization as the core premise of the political economic model and of the task around which Chinese Marxism and Chinese Leninism is both constructed and developed as China proceeds along the socialist path toward the establishment of a communist society under the leadership and guidance of the Communist Party.  In that respect, both Marxism and Leninism might be understood each as one of the productive forces of the nation; and since the 3rd Plenum of the 20th CPC Congress, all productive forces are understood to be further developed within the framework of high quality production that favors innovation. That had been the thrust of remarks made at a conference held at Renmin University in September 2026: "A Question on Chinese Modernization and the Vanguard Party” [“关于中国现代化和先锋党的问题”] (focusing on the constitution of socialist modernization and its relationship to the new important concept of new quality development of productive forces. With that as a framework, the remarks focused on a consideration of  the ramifications of this form of development theory for governance.")

That brings me to the question for which I hope this group of eminent scholars and officials may help me consider correctly. The question: Is the Communist Party itself the manager or supplier of national productive forces or is the Communist Party also a superior productive force? The question thus focuses on the extent and manner to which the Party must itself apply the principles of socialist modernization, especially as they have been thoroughly explained by the General Secretary, to its own organization and to the contribution of its own productive forces to China’s forward movement along the Socialist path.

Under the leadership of the General Secretary and at the core of the 3rd Plenum’s consideration of developing socialist modernization theory, it has become clear that the need to meet the challenge of the current general contradiction requires the focusing of all of the nation’s productive forces. Those productive forces, in turn, serve as the engine of socialist modernization itself by embracing the entirety of the productive capacities of the social, cultural, economic and political spheres. It is also aligned with China’s international relations.

It is now well understood that these necessary evolutionary changes also required a change in conception— from productive to New quality productive forces. The emphasis is on innovation, being in accord with the times, bring the past forward and moving into the future. Nonetheless new quality production applies comprehensively, suggesting the path forward for the current realization of socialist modernization. It is in this respect that the issue of the way in which the principles of socialist modernization, and especially of its concepts of new quality production apply to the work of the Party and its organs. "A Question on Chinese Modernization and the Vanguard Party” 

 It is to that question--one built around a conceptual problem of "the relationship between being a productive force and directing or supplying productive forces for the nation,[and a supposition that both] might be considered a central element in evolving Chinese Marxist-Leninist theory!" (Ibid.)--to which much of the essay, 在守正创新中推动马克思主义理论学科高质量发展 , is devoted. 

The object is to consider the construction--the modernization--of a Chinese Marxist system, attended to and directed through principles of Chinese Leninism. The necessity of Marxist theoretical production is made clear from its characterization as the the core Leninist element, the leading force driving and guiding the fields of philosophy and the social sciences.  " Discipline construction serves as the foundational undertaking for conducting basic research, applied research, and frontier exploration. The discipline of Marxist theory stands as the leading discipline within China's system of philosophy and social sciences with Chinese characteristics. " [学科建设是开展基础研究、应用研究、前沿探索的基础工程。马克思主义理论学科是中国特色哲学社会科学学科体系中的领航学科。] (在守正创新中推动马克思主义理论学科高质量发展). Philosophy and the social sciences are elements of knowledge production the acceleration of the development of which is dependent on the leading role of Marxist theory. Philosophy and the social sciences, then, become extensions of, they express in practical terms philosophy and the social sciences in its most productive and efficient forms--as productive forces the highest and best use of which is as contributors to forward movement along the Socialist Path. In that critical objective, the development of Marxist theory with Chinese characteristic serves as the guiding element.  " Over the past decade, the construction of the discipline of Marxist theory has achieved substantial progress, and its leading role within the system of philosophy and social sciences with Chinese characteristics has become increasingly prominent. " [十年来，马克思主义理论学科建设取得长足发展，在中国特色哲学社会科学学科体系中的引领作用日益凸显。]  (在守正创新中推动马克思主义理论学科高质量发展). 

Qin and Qiu then explore this high quality production of Marxist theory in two sections: (1) Substantial Progress Achieved in the Construction of the Discipline of Marxist Theory [马克思主义理论学科建设取得长足发展]; (2) Opportunities and Challenges Facing the Development of the Marxist Theory Discipline [多策并举推进马克思主义理论学科高质量发展]； 爱你的（3) Take Multiple Measures to Promote high-Quality Development of Marxist Theoretical Discipline [多策并举推进马克思主义理论学科高质量发展].

With respect to the first, Qin and Qiu disaggregates  the role of Marxist theoretical development into two distinct spheres: serving national strategies and consolidating the guiding status of Marxism in the ideological sphere. "Upholding the commitment to serving national strategies, thereby powerfully consolidating the guiding status of Marxism in the ideological sphere. [坚持服务国家战略，有力巩固马克思主义在意识形态领域的指导地位。] (在守正创新中推动马克思主义理论学科高质量发展). 

First, scientific research has yielded even more fruitful results, providing academic support for driving the Party's theoretical innovation. A vast body of theoretical workers has focused their research on classic Marxist texts, fundamental Marxist theories, and the latest achievements in the Sinicization and modernization of Marxism; in doing so, they have produced a collection of high-caliber, exemplary works that have played a pivotal role in elevating the level of Marxist theoretical understanding throughout the entire Party and the theoretical community. Second, the research and interpretation of the Party's innovative theories have deepened significantly, providing a crucial guarantee for enhancing the effectiveness of theoretical study and publicity. The development of the Marxist theory discipline has consistently prioritized its vital role in rallying hearts and forging souls. [一是科学研究取得的成果更加丰硕，为推动党的理论创新提供学理支撑。广大理论工作者聚焦马克思主义经典文本、马克思主义基础理论、马克思主义中国化时代化最新成果进行研究，推出了一批有较高学术水平的精品力作，为提高全党和理论界的马克思主义理论水平发挥了重要作用。二是研究阐释党的创新理论更加深入，为提升理论学习宣传实效提供了重要保障。] (在守正创新中推动马克思主义理论学科高质量发展). 

 This, the author's argue, have facilitated the internalization of Marxism as the foundational premise of the Chinese cognitive cage. It also provides  intellectual support for Chinese modernization. Marxist theory with Chinese characteristics, then, can be understood as the theoretical structuring of socialist modernization with Chinese characteristics. Marxist theory is the conceptual framework within which it is possible to operationalize itself as Chinese (socialist) modernization, That modernization, under the guidance of the CPC (and the parallel guidance of Chinese Marxist theory) provides the Leninist  operational element.  Marxist theory, then focuses on Marxist (socialist) development as the primary task; the task of socialist Modernization and Marxism itself, then, is an expression of Leninist organization and application. " Over the past decade—driven by the deepening and expansion of disciplinary development—the field of Marxist theory has achieved substantial progress in terms of layout optimization, scale expansion, platform construction, and institutional standardization. " [十年来，伴随学科建设纵深推进，马克思主义理论学科在布局优化、规模拓展、平台建设、制度规范等方面取得长足进步。一是学科布局持续优化。] (Ibid.). Much of this is reflected in the institutionalization of the educational structures of theoretical Chinese style Marxism. "The attainment of these achievements has enabled the discipline of Marxist Theory to establish a comprehensive and efficiently functioning institutional framework, laying a solid foundation for it to fulfill its leading role within China’s system of philosophy and social sciences with Chinese characteristics." [四是思政课教学成效显著提升。通过精心设立实践教学基地，持续举办思政课骨干教师研修班，创新举办覆盖全国思政课教师的高校思政课集体备课会，切实提升了高校思政课教学的针对性和实效性。] (Ibid.). 

The projection of all of this theory and its practice is to be undertaken through Ideological and Political Theory Courses (IPTCs). "  Over the past decade, the discipline of Marxist Theory has consistently regarded the support of IPTC development as a core mission; consequently, it has made significant strides in terms of developmental philosophy, reform and innovation, pedagogical methods, and educational outcomes. "[十年来，马克思主义理论学科始终将支撑思政课建设作为学科发展的重要使命，在建设理念、改革创新、教学方法、教学成效等方面取得显著进展。]. (Ibid.). And thus Marxist development and deployment of the productive forces of Marxism itself through its Lemni9nist elee3mt--the constitution of a n institutional vanguard that is meant to apply Leninist theory (democratic centralism and the mass line) to the teaching and incorporating of Marxist productivity in shaping and directing philosophy and the social sciences. What that needs is a functionally differentiated sub-collective of dedicated talent. "Over the past decade, the discipline of Marxist Theory has made concerted efforts in both team building and talent cultivation, providing a solid foundation of human resources for its sustainable development." [十年来，马克思主义理论学科在队伍建设和人才培养上双向发力，为学科可持续发展提供了坚实人才保障。] (在守正创新中推动马克思主义理论学科高质量发展). And thus Leninist recursivity in the production of cadres that serve as the front line developers and teachers of Marxist theory that drives modernization--both of the productive forces of the nation and the education cadres as elements of the productive forces of education.

This produces opportunities and challenges.  That is the subject of the second section of the essay, Opportunities and Challenges Facing the Development of the Marxist Theory Discipline [多策并举推进马克思主义理论学科高质量发展]. This is divided into four sections. The first, touches on the strategic leadership opportunities arising from the expansion of the discipline's mission. This focuses on the construction of an independent knowledge systems for philosophy and social sciences with Chinese characteristics, that is for knowledge production that in all its elements is Marxist. That in turn suggests the quite conscious effort to construct a quite specific cognitive cage of Chinese Marxist theory which then is the basis for rationalizing the entirety of Chinese reality. "In particular, the call to "accelerate the construction of an independent knowledge system for philosophy and social sciences with Chinese characteristics" has further expanded the functional positioning and mission of the Marxist theory discipline, providing strategic impetus for the discipline to plan its future development from a higher vantage point and within a broader framework." [特别是“加快构建中国哲学社会科学自主知识体系”的提出，进一步拓展了马克思主义理论学科的功能定位和职责使命，为学科在更高站位、更大格局中谋划发展提供了战略牵引。]

The second explores opportunities for theoretical innovation arising from magnificent practical achievements. Practice serves as the foundation of theory. This focuses on the use of Marxist dialectics and especially in the form of the mass line element of Chinese Leninism. "The great practice of Chinese modernization in the new era—along with the full demonstration of the institutional strengths of China—has provided the discipline of Marxist theory with a wealth of empirical material and new points for theoretical growth; consequently, the conditions are now more mature than ever to "It has provided a wealth of empirical material and new points of theoretical growth for the discipline of Marxist theory, and the conditions for "summarizing Chinese experience through Chinese principles and elevating that experience into Chinese theory" have become increasingly mature." [为马克思主义理论学科提供了丰富的经验素材和新的理论生长点，“用中国道理总结好中国经验，把中国经验提升为中国理论”的条件更加成熟。]. (在守正创新中推动马克思主义理论学科高质量发展).

The third returns Marxism to the Communist international. It suggests the possibilities of developing Marxist theory with Chinese characteristics in a way that produces a foundation for a new international. "This presents a brand-new historical opportunity for the discipline of Marxist theory to go global, tell China's story well, and enhance its international academic influence." [这为马克思主义理论学科走出国门、讲好中国故事、提升国际学术影响力提供了全新历史机遇。]. (在守正创新中推动马克思主义理论学科高质量发展).

The fourth touches on innovation and development opportunities brought about by digital technology empowerment. "The rapid development of digital technology has provided strong technical support for the digital compilation of classic documents, paradigm innovation in academic research, intelligent transformation of ideological and political teaching models, and precise access to theoretical dissemination, and has opened up a new space for the high-quality development of Marxist theoretical disciplines." [数字技术的飞速发展，为经典文献的数字化整理、学术研究的范式创新、思政课教学模式的智能化变革、理论传播的精准化触达等提供了强大技术支撑，为马克思主义理论学科高质量发展打开了全新空间。] (在守正创新中推动马克思主义理论学科高质量发展).

Then to the challenges. The first includes quality problems ("In individual places and universities, there is a tendency to emphasize form over content and performance over problems in subject construction"); the second touches on uneven quality of instruction among universities ("The problem of uneven subject development between the eastern and central and western parts of the country and between key universities and general universities is more prominent"); the third touches on the risks of reliance on subsidies and support from outside localities; the fourth touches on rigidity  in research and teaching that impedes innovation ("the homogeneity phenomenon in the subject research of Marxist theory is relatively serious, and the ability to use academics to talk about politics and conduct theoretical innovation based on practical innovation needs to be improved"); and the fifth touches on the need to transform Marxist theory and education through  the use of digital technologies ("The deep integration of digital technology and ideological and political teaching has not yet been effectively carried out"); 

The essay ends with the consideration of the application of Leninist measures to the further and scientific development of the structures within which  advances in innovative Marxist theory that is useful may be realized. These include the core praxis of Chinese Leninism--independent knowledge systems, democratic centralism, the mass line, collective knowledge production, the political as a productive force, working upwards from practice and downwards from theory, and Marxist internationalism.

But above all of that is a fundamental theory that Marxist theory is recursive, but that its iterative mimesis produces progress that is organic and inevitably leads forward along a Socialist path. 

"This is an era that needs theory and will be able to produce theory. This is an era that needs ideas and will be able to produce them. We cannot let down this era." To continue to promote the discipline construction of Marxist theory at a new historical starting point, we must objectively analyze the new situation facing discipline construction, persist in innovation, and follow the path of high-quality and connotative development. [“这是一个需要理论而且一定能够产生理论的时代，这是一个需要思想而且一定能够产生思想的时代。我们不能辜负了这个时代。”在新的历史起点上继续推进马克思主义理论学科建设，必须客观分析学科建设面临的新形势，坚持守正创新，走好高质量内涵式发展之路。] (在守正创新中推动马克思主义理论学科高质量发展).

The essay is remarkable, then, for advancing notions inherent in the 3rd Plenum on high quality productivity attached to the core premise of socialist modernization and attaching these in turn, to the characterization of the political work of the vanguard, including its work on the theoretical level, as a subject of high quality production essential to socialist modernization. One can quibble with its approach and analysis; but that is far less important than what appears to be at least one acknowledgement that everything, inclusion ideology and its institutional guardians, the vanguard of leading forces that is the CPC, are productive forces that must all contribute to and are part of the great national effort of socialist modernization with a purpose--to scientifically lead the masses in an accelerated way toward the goal of establishing a communist society. Ideology, and the vanguard itself, then, has two bodies. It is on the one hand the supplier of ideology, guidance and leadership through which socialist modernization can be properly undertaken along the socialist path. At the same time both are also the subjects of the same process of modernization and must lead by example--both theory and the institutions that guard and deploy them. It is to those ends that self- and social revolution becomes an instrument with a purpose--that purpose is to  produce a system of iterative recursivity in which the system must itself reflect the adjustments and transformations which it develops for the rest of the nation--making both object, signifier and interpreter simultaneously--and also a reminder that nothing is transformed without transforming itself (see, Social Revolution (社会革命) as Self-Revolution (自我革命) and the New Quality Production of CPC Modernization: 习近平 深入推进党的自我革命 [Xi Jinping, Deepen the Party's Self-Revolution] (Part of a speech at the Third Plenary Session of the 20th Central Commission for Discipline Inspection on January 8, 2024)).  This essay suggests its effects not just in the context of the construction of institutionalized education, but also in the construction and rationalization of the production of knowledge.  In that there is much resonance with the underlying thinking of post-modernity (See eg, Michel Foucault, The Order of Things: An Archeology of Human Sciences, Vintage Books 1994). 

The essay appears in full below in the original Chinese and in an English translation. 

 

Pix credit here (Long Live the Dictatorship of the Proletariat, 1971)

European China Law Studies Association (ECLS) Summer Academy 2026 Law and Technology in China

 

 

I am delighted to pass along information about the European China Law Studies Association Summer Academy 2026, which this year has as its theme Law and Technology in China.  The Summer Academy is scheduled for 1-4 September 2026 on the campus of the University of Turin (Italy). 

Here is the description from the Summer Academy brochure:

Few legal systems engage as actively with the governance of emerging technologies as China’s does. It is developing regulatory frameworks for artificial intelligence, biotechnology and algorithmic decision-making, all the while building a comprehensive smart court system and integrating technology into its modes of governance. Making sense of this requires more than policy literacy. It requires familiarity with the underlying legal architecture and the specific tensions that shape how rules are made, applied, and contested in a distinct legal culture.
The Department of Law at the University of Turin, in collaboration with the European China Law Studies Association (ECLS), is presenting the second edition of the ECLS Summer Academy on Chinese Law and Technology. Over four intensive days, internationally acclaimed specialists will guide participants through the constitutional foundations, data governance, criminal law, biotechnology and more. The goal is not to provide an overview, but to facilitate a structured encounter with a legal system whose decisions regarding the regulation of technology are becoming increasingly important well beyond China’s borders. Participants will leave with sharper analytical tools and a firmer grasp of a field that is reshaping legal practice and scholarship worldwide.
The Academy is open to doctoral researchers, advanced students, and legal professionals seeking rigorous, first-hand engagement with Chinese law. 

It has a great faculty including Bjorn Ahl, Marianne von Blomberg, Daniel Sprick, Ge Chen, Monika Prusinowska, Simona Novaretti, Knut Banjamin Pissler, Viola Negro, Guo Zhiyuan, and Anna Maria Rizzo.

Brochure follows below. 

 

Open for Comment: OMB Revisions to "Regulation for Federal Financial Assistance"

 

Pix credit here

On 29 May 2026 the OMB (Office of Management and Budget) proposed a set of revisions and updates to the Uniform Guidance (2 C.F.R. § 200),  the government-wide framework issued by the Office of Management and Budget (OMB) that establishes administrative requirements, cost principles, and audit requirements for all federal grants, cooperative agreements, and pass-through awards. 

The Office of Management and Budget (OMB) proposes to revise the Guidance for Federal Financial Assistance to improve government-wide policies and requirements related to the management of grants, cooperative agreements, and other forms of assistance. OMB is proposing revisions that would improve transparency, accountability, and oversight for Federal awards across the Federal Government. This includes ensuring that American tax dollars are not wasted or misused, activities performed under Federal awards are consistent with law and policy, and recipients are held accountable when they fail to meet relevant standards. The revisions also aim to ensure that basic American principles of equality and equal opportunity are upheld throughout all stages of the award making process and that unlawful discrimination is no longer permitted. Proposed changes also include providing further clarification on the regulatory status of the OMB requirements and on the process for future updates to the government-wide requirements. Finally, OMB also proposes changes to reduce recipient burden. The listed Federal grant-making agencies propose conforming changes to their respective adopting regulations, or, in the case of some agencies and other entities, establishing new adopting regulations or policies. The proposed changes reflect the administration's commitment to transparency, accountability, and proper oversight for the Federal grantmaking process. The proposed regulations seek to ensure that American tax dollars are ultimately used to serve the needs of the American public.

The proposed revisions are open for comments and reactions which may be delivered on or before 13 July 2026. Comments on this proposal must be submitted electronically before the comment closing date to www.regulations.gov. In submitting comments, please search for recent submissions by OMB to find docket OMB-2026-0034, which includes the full text of the proposed revisions and submit comments there. 

Institutional academia has not reacted well to the proposals, part of th Trump Administration's efforts to (1) remove the Biden Administration's regulatory efforts to embed their version of diversity, equity and inclusion measures within the grant awarding and administration process; and (2) reduce the aggregate grant payouts, especially to the extent that grant money subsidizes university or institutional operations. A useful summary of the changes and their effects on university fundraising and compliance responsibilities may be found at Key Issues within OMB Uniform Guidance Revision Proposal [Docket OMB-2026-0034], distributed by the Association of Public and Land Grant UIniversities. 

It ought to be no surprise that these proposed changes have been met with opposition from grant recipients and their institutional environments.  

Although research has bipartisan support in the US Congress, and trust in science is above 75% across the country, the Trump administration seems as determined as ever to mortally wound the nation’s scientific enterprise. After the scientific community persuaded Congress to restore most of the president’s draconian cuts to research funding last year, the White House Office of Management and Budget (OMB), under Russell Vought, has found new ways to circumvent the will of Congress and starve American science.* * * The sweeping new regulations proposed by OMB would subject every federal research funding decision to political review. Peer review has never been formally binding, but this proposal would dramatically expand the power of political appointees to override expert assessments of scientific merit. Agencies could end multiyear grants with no due process. They also could use the vague criteria of Trump’s “gold standard science” to identify institutions for preferential treatment. International collaboration with countries identified solely by the administration would be prohibited under the new rules, but more notably, all research that involves the expenditure of funds outside the US would require case-by-case approval.(Another Red Alert for American Science).

The authors of that opinion piece then raise a call to arms, one that is likely top be met with much sympathy among those adversely impacted: 

The scientific community needs to flood OMB with responses during the public comment period, open until 13 July. Universities and associations must speak out as a united front to mobilize Congress and be ready to file lawsuits once the regulations are finalized. I was sympathetic to members of the scientific establishment who played it carefully during last year’s budget negotiations. Getting the budget deal done was crucial. But that was then. The red light is now flashing. All hands, report to stations."! (Another Red Alert for American Science).

 Of course they are right to do so. Scientific grants programs, like every other action of the State, are an overtly political action, in the sense that they represent a political conclusion that State intervention  (in this case subsidies for private research in aid of national goals and aspirations) serves the interests of the State. That State interests--or in American parlance the public interests--serves the financial, status, business, or status interests of others, including academics, researchers, unioversoities and the like in this case, is good but of secondary interest, even if the state interest is, from time to time, served by sunbsidizing the private interests of those objects and processes that are the object if public polñiocy, in this case the fruits of research that serves State interests. For a long time, those converghing interests were mediated largely through self-regulation--academics presiding over grant decisiopns coordinated with state fiunctiponaries. And the universities got their cut, all nicely justified by whatever justificatory logicv appealed to all parties. But the Trump Admionistraiton serves as a reminder that alignment is neithjer permanent nor non-political. The State interests may shift--and that is a matter for elected officials to determine. That shifting may have significant effects on the financial planning of subsidized enterprises and thier employees, as well as on the busoiness model of knowledge production. Yet those are factors in a political consideraiotn, the discretion for which--within the boundaries of due process and the regulaitons under which such susidy programs are organized--lie with political functionarties and not with the beneficiaries of these programs.  

The political nature of these determinations, however do not leave those affected powerless. Politics is a sport that American liberal democracy spreads widely acropss the populaiton. Adverse impacts of political discretionary decisionmaking may always be the subject of a counter politics; ones that may require political counter-responses. The object is to advance one's own interests as against the political intrerests of opponents. And the principal way of doing that in early 21st century Amerioca is to argume virtually anything but politics while denegrationg the opposition as narrowly political. That is fair. In politics. To aid those fforts, of course, one now must play politics in the ocurts, while defending the courts as the last bastion of non-politicalaction.  That is also a quintessentially American politics. 

 And thus, for those interested, or affected. by the proposed revisions, you have a chance to make your voice heard, to the extent that this is possible, through 13 July.  After that, one goes back to that now well embedded poliutical strategy --litigation. 

 

Brief Reflections on the Cognitive Semiotics of President Trump's Executive Order; Promoting Advanced Artificial Intelligence Innovation and Security (2 June 2026)

 

Image prepared using Gemini

 How does one balance the imperatives of economic/social development with the critical element of national security? How does one attempt that balance within a political neural network which is driven by markets (the autonomous and free mimetic iterative actions of consumers and producers within a platform of exchange grounded in the expectations of that very iterative mimetics)? How does one balance the essential need for structural coupling within and among trade, politics, culture,  and social sub-systems-- how does one balance the essential element of cross-system irritation--with the need to protect the solidity and integrity of collectives producing and consuming irritation?

Those are the fundamental questions that now confront apex states as they attempt to re-imagine  themselves by putting together whatever remains of the building blocks the post-1945 project of global convergence  which they destroyed and from out of which they seek to elaborate virtual sub-systems masquerading as empire--empire the constitution and defense of which can be undertaken bloodlessly within the simulacra that is the virtual manifestation of the physical order from out of which all of this emerged in the last decade.  

Tragic in so many ways. . . 

But perhaps inevitable as well, in the ancient Greek sense of tragedy anyway --at least for those who understand the repeating sequential patterns of human collective neural networking. Today one witnesses the quite extraordinary marriage of Nietzsche and Abd al-Rahman ibn Khaldun.  The former reminding one of the constitutive realities that come from investing truth and fact with the values, bias and perceptions that produce human cognitive cages constructed from out of belief in the truth of things, and with it their reality; the later reminding one of the recursivity of human collectives, of their assabiyah (عصبيّة) from which one might realize lebenswelt (Husserl) or habitus (Bourdieu) or imaginaries (Sartre) as the lived simulacra of the human collective (in physical form) and its increasingly managerial force in the form of generative digitized realities of those physical manifestations of imagined collective solidarity. Humans project themselves into their simulated selves, into generative sentience made in their own image- - -and then recoil in the horror if it, even as they are tempted to invest even more of themselves in the project of virtual recreation and in the construction of the relationships between themselves physical and virtual, as each projects themselves against and within the other.  

Pix credit here (note that the output is "dog" because the neural pathways make that choice inevitable; other pathways might have concluded that the image was "food", or "not the property of the state" etc. (on its phenomenology here; on categoriuzation and its framing see Emporio celestial de conocimientos benévolos)

 

All of this by way of introduction to a most remarkable document that serves to evidence the way the United States approaches the problem of balance while staying true to the core driving premises (the bars of the cage of its own cognitive frameworks) producing through the application of the processes of its own collective political neural networks an inevitable approach to the balancing of innovation and national security within a markets driven reality aligned with a political system fundamentally distrustful of the State (despite what might be conceived, in retrospect, as the techno-bureaucratic state managed aberrations of the period 1919-2015, or winch might themselves be cast as the current aberrations from the techno-state evolution that ascended or supplanted the national structures of the American political neural networks after 1919). That remarkable document--and the process of its finalization, was President Trump's Executive Order: Promoting Advanced Artificial Intelligence Innovation and Security (2 June 2026). What makes it remarkable is not its terms, as such, but the way in which it exposed the conceptual framework within which such a document was inevitable within a broader framework that had, in the prior Administration of President Biden, produced a different result within the same conceptual cage: Executive Order 14110 of October 30, 2023, Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence. It is one in which national security (AI must be "safe and secure"; "addressing AI systems' most pressing security risks—including with respect to biotechnology, cybersecurity, critical infrastructure, and other national security dangers—while navigating AI's opacity and complexity") is balanced in a different way against other values (privacy, equity and civil rights, enhancing labor rights, etc.), but which also includes protection of market forces ("Federal Government will promote a fair, open, and competitive ecosystem and marketplace for AI and related technologies so that small developers and entrepreneurs can continue to drive innovation"). But see the Biden Administration's 2024 National Security Memorandum (NSM-25) which is discussed in a separate post.

As reported widely (I used the reporting in Politico). That reporting nicely highlighted the structural elements of decision making processes. These were grounded (quite unconsciously of course, because that is how being inside a cognitive cage works) in the protection of the core elements of American cognitive political structures--markets, distrust of the State, and the relentless drive that is innovation (as that in turn might be understand flexibly over time and among sectors of human collective production and consumption of whatever might be of interest from a regulatory perspective) balanced against the fundamental need to protect the markets and its political collective as the primary obligation of the State.  

The original version of what became Promoting Advanced Artificial Intelligence Innovation and Security  was to have been signed at a White House event on 21 May 2026. That event, and the signing of that version was postponed at the last minute.

Thursday’s abrupt postponement of President Donald Trump’s much-awaited executive order on artificial intelligence came after former AI czar David Sacks voiced industry concerns about the measure to Trump, according to a senior White House official and two people familiar with the matter. * * * The executive order, which the White House planned to release Thursday afternoon, would have set in motion a voluntary oversight system in which developers of advanced AI models could submit their products to a review by federal agencies before releasing them, POLITICO previously reported.* * * According to the White House official, Sacks had participated in a review of the EO this week, and White House officials believed he was generally happy with it and would support it. But Wednesday night, he began to raise concerns, including fears that the voluntary nature of the agreement may one day become mandatory, the senior White House official said. “Then, he called POTUS this morning unbeknownst to anybody, his own staff included, and derailed it,” the White House official said. The reversal also came after industry officials raised concerns about a proposed voluntary review process for cutting-edge “frontier” AI models, according to four people familiar with the matter, who were granted anonymity to discuss private discussions. (Politico).

The question, then, wasn't whether the draft Executive Order (dated May 2026) ought to outline an "America First" AI strategy (eg, discussed here) designed to accelerate technological growth by reducing regulatory burdens while aggressively hardening national security infrastructure against AI-driven threats, but how that balance was to be struck consistent with the interpretation of those values by those producing, managing and developing both products and the national security structures that protected their freedom in and as markets. within the value systems. The policy rejected mandatory federal licensing or preclearance, though the spectre of both remains very much in the air. The alternative--voluntary public-private partnerships, rapid deployment of defensive AI tools across government agencies, and targeted criminal enforcement against malicious actors--one grounded in the vitality of private sector standards and deep interpenetration between the market and the national security apparatus on an operational level, better reflected current consensus on the legitimacy of American regulatory approaches. To do that the Executive Order protects innovation in markets, but ties that innovation to the consequences of such innovation for and as critical elements of American national security.

As finalized, the Executive Order retained most of its original provisions. But it did shorten the period for examination from 90 to 30 days and included the Department of Commerce (Section 3) as a consulting partner.  

What result? Here is a short summary:

Section 1: Purpose and Core Policy: The EO starts by reaffirming the operational premise that principle American leadership in AI stems from private-sector talent and a deliberate avoidance of bureaucratic constraints. The administration contrasts its approach with the prior administration, stating that it has actively slashed regulatory hurdles to accelerate AI adoption across both government and industry. 

It is the policy of the United States to promote AI innovation and security by working collaboratively with the private sector to modernize government and private sector information systems and harden them against external threats; to protect American ingenuity and intellectual property from exploitation and theft by adversaries; and to cultivate America’s advanced AI-enabled capabilities.

The core policy balances two competing pillars: AI Innovation: Championing an "America First" technological framework that fosters private-sector investment and rapid deployment. National Security: Addressing external threats by modernizing public and private information systems, protecting intellectual property from foreign adversaries, and cultivating advanced defensive capabilities ("Advanced AI capabilities make our Nation stronger, but also introduce new national security considerations that require coordinated action across executive departments and agencies (agencies), and components.").

Section 2: Upgrading American Systems for Advanced AI: This section mandates immediate actions to upgrade cyber defenses across federal and civilian networks, leveraging advanced AI tools to counter incoming threats (Section 2(a). The specifics are set out in Sections 2(b)-(f). They oinclude:

(1) Within 30 days, specific actions are assigned to key agencies: National Security & War Systems: The Committee on National Security Systems and the Secretary of War must prioritize and expedite the cyber defense of their respective information networks.
(2) Civilian Government & Critical Infrastructure: Within 30 days the Department of Homeland Security (DHS), via the Cybersecurity and Infrastructure Security Agency (CISA) and in consultation with the Office of Management and Budget (OMB), must issue Binding Operational Directives. These directives will expedite civilian federal cyber defense, expand AI-driven defensive programs, and facilitate access to cybersecurity tools (including "covered frontier models") for local entities like rural hospitals, community banks, and local utilities.
(3) AI Cybersecurity Clearinghouse: The Department of the Treasury, the National Security Agency (NSA), and CISA will form a clearinghouse in voluntary collaboration with private industry. This entity will scan for, validate, patch, and remediate software vulnerabilities.
(4) Funding and Talent (30 & 60 Days): OMB must immediately evaluate federal grant programs to redirect available funds toward advanced AI vulnerability detection. Within 60 days, the Office of Personnel Management (OPM) must expand hiring and placement pathways for the U.S. Tech Force Information Cybersecurity Specialist program to bring technical talent into government.

Section 3: Secure Frontier Model Deployment: This is a section that sets out the public-private framework for AI development within the architecture of national security. Within 60 days, a multi-agency coalition led by Treasury, the NSA, CISA, the National Cyber Director, and the National Institute of Standards and Technology (NIST) must establish protocols for governing highly advanced AI models. 

Classified Benchmarking Process: Section 3(a) describes the creation of a classified process to evaluate the cyber capabilities of AI systems under NSA leadership,which is to determine the exact technical thresholds that designate a system as a "covered frontier model." These benchmarks will be shared with researchers and developers.

Voluntary Government-Industry Framework: The order designs a voluntary program allowing AI developers to: (1) "engage the Federal Government" to determine if their models meet the "covered frontier" designation; (2) provide the federal government with early access to these models for up to 30 days prior to a wider release (under strict confidentiality and intellectual property protections); (3) jointly select "trusted partners" to receive early access to the models to reinforce critical infrastructure defenses.

Anti-Regulation Guardrail: Section 3(c) provides that nothing in this section permits the creation of mandatory government licensing, permitting, or preclearance requirements for developing or distributing AI models.

Section 4: Protection Against Criminal Actors:  The Attorney General is directed to prioritize federal criminal enforcement against malicious actors leveraging AI. Specifically, the Department of Justice will target individuals utilizing AI to unlawfully access, breach, or damage public or private information technology systems, or deploying autonomous AI agents to steal data for criminal purposes.

Section 5: General Provisions: the Department of War will bear the costs of publishing the order.

Key Operational Matrix

The following table summarizes the explicit mandates, responsible agencies, and strict deadlines imposed by the draft order:

Timeline	Responsible Agency / Official	Mandated Action	Target Systems / Sectors
30 Days	Committee on National Security Systems	Prioritize and expedite cyber defense protocols.	National Security Systems
30 Days	Secretary of War	Expedite information system cyber defenses.	Department of War Systems
30 Days	DHS (CISA) / OMB / National Cyber Director	Release Binding Operational Directives; deploy AI defensive tools.	Civilian Federal Gov / Critical Infrastructure (Rural hospitals, community banks)
30 Days	Treasury / NSA / CISA	Establish a voluntary AI Cybersecurity Clearinghouse.	Software vulnerability scanning and patch distribution
30 Days	OMB / CISA / National Cyber Director	Identify and divert federal grant funds.	Advanced AI vulnerability detection development
60 Days	Office of Personnel Management (OPM)	Expand specialist hiring and placement pathways.	U.S. Tech Force Information Cybersecurity
60 Days	NSA / Treasury / CISA / NIST / National Cyber Director	1. Establish classified benchmarking metrics. 2. Build a voluntary 30-day early-access framework.	"Covered Frontier Models"
Ongoing	Attorney General / DOJ	Prioritize criminal prosecution of AI-driven cybercrimes.	Unauthorized computer access, malicious AI agents

None of this affects sanctions regimes, nor export restrictions regimes and must be understood as deeply embedded in the current government programs to manage exports with national security implications. What it does do is provide an additional structural pillar in the reconstitution of economic policy, and development, of key industrial sectors, as national security in line with the fundamentals of the Trump Administration's America First policy (see The Conceptual Architecture of America First—Ideological Transactionalism and the Case of Cuba). 

And none of this touches on the deep, intricate and informal networks of engagement between public and private in the context of frontier (and more "ordinary") tech based innovation.  The deep intertwining of the State apparatus and the market for products, innovation, expectation, and processes that the apparatus consumes (and protects) suggests that actions like this Executive Order are important, but also serve to shield those interconnections that sometimes make it hard to distinguish either a public or private sphere, or in this case the larger private producers and the State as consumer of innovation. In that respect the now long process of the interconnection between institutional actors in markets continues to develop (or evolve) in ways that suggest that the private-public divide will assume new and not yet visible characteristics in the future.

The primary source documents follow: (1) Promoting Advanced Artificial Intelligence Innovation and Security; (2) Fact Sheet: President Donald J. Trump Promotes Advanced Artificial Intelligence Innovation and Security; and the (3) the Draft Executive Order (May 2026), along with President Biden's 2023 Executive Order 14110 (30 October 30); Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence.