To Whom It May Concern:

In response to the Board’s May 23, 2024, Federal Register notice “PCLOB Public Forum Examining the Role of Artificial Intelligence in Counterterrorism and Request for Public Comment,” I offer the following comments, suggestions, and questions. I note that these are my views offered in my capacity as a Senior Fellow at the Cato Institute and do not necessarily represent the views of the Institute, its management, or its board of directors.

In responding to the Board’s request for comments, I’ve keyed my responses to several of the specific questions the Board itself raised in its Federal Register notice.

1. How is the federal government using AI in current efforts to combat terrorism and protect national security?

In the four years since then-President Trump issued Executive Order 13690 on AI use in the federal government, it’s become clear that the current federal approach to setting across-the-board AI standards government-wide has failed. A December 2023 Government Accountability Office (GAO) report revealed as much Indeed, six months before Trump issued that EO, his ODNI issued IC-wide guidance regarding AI standards and ethical conduct. To the best of the author’s knowledge, no specifics regarding exactly how the IC is employing AI in the counterterrorism (CT) context–whether targeting individuals or groups overseas or domestically–has been made public.