A substantive expansion of reporting requirements and scope. v2 adds requirements for a classified annex to the annual report, mandates a description of public-private partnerships, and broadens the list of specific risks to consider. The bill also expands the list of officials to be consulted, particularly adding several financial regulatory bodies.
AI PLAN Act
- Sponsor
- Rep. Nunn, Zachary [R-IA-3]
- Committees
- Financial Services Committee (primary)
- Last action
- Jun 24, 2026
Bottom line
The AI PLAN Act mandates an annual interagency strategy and recommendations to combat AI-driven financial crimes by adversarial actors, aiming to protect U.S. financial markets, persons, businesses, and global supply chains.
What it actually does
This bill, the 'AI PLAN Act,' requires the Secretaries of the Treasury, Homeland Security, and Commerce to jointly develop and annually submit a strategy to Congress. This strategy must address the national and economic security risks posed by adversarial actors using artificial intelligence (AI) to commit financial crimes, including fraud and misinformation. The bill also mandates subsequent legislative recommendations and best practices for risk mitigation.
Proponents argue
Supporters argue that this bill is a crucial first step in addressing the rapidly evolving threat of AI-driven financial crimes, which pose significant risks to national and economic security. They contend that a coordinated interagency strategy, coupled with public-private partnerships and regular resource assessments, is essential to proactively defend against sophisticated adversarial actors. The bill's focus on specific threats like deepfakes and foreign election interference demonstrates a forward-thinking approach to safeguarding critical infrastructure and public trust.
Opponents contend
Critics might argue that while the intent is good, the bill primarily mandates reports and recommendations rather than immediate, concrete actions or regulatory frameworks. They may contend that the annual reporting cycle could be too slow to keep pace with the rapid advancements in AI technology and the evolving tactics of adversarial actors. Concerns could also be raised about the potential for bureaucratic inertia in coordinating numerous agencies, possibly leading to strategies that are broad but lack specific, enforceable measures.
The bill is concise and straightforward, making it accessible for a quick read and easy to understand its core requirements.
Section 2(b)(1)
Annual Interagency Strategy Report
This provision requires the Secretaries of the Treasury, Homeland Security, and Commerce to jointly submit an annual report to Congress. This report must outline a strategy to defend against economic and national security risks from adversarial actors using AI for financial crimes. It must include descriptions of interagency policies, public-private partnerships, and assessments of both readily available and needed resources (hardware, software, technologies, and personnel) to combat these threats.
Supporters argue
Supporters argue that this annual reporting requirement ensures continuous governmental focus and adaptation to the evolving threats posed by AI in financial crime. It fosters necessary interagency collaboration and provides Congress with critical insights into the nation's defensive posture and resource needs, enabling informed legislative action.
Critics contend
Critics might suggest that annual reports, while informative, can become bureaucratic exercises that consume resources without necessarily leading to timely, decisive action. They may argue that the pace of AI development and threat evolution demands more agile and frequent updates or direct operational mandates, rather than just strategic documentation.
Tradeoffs
This provision balances the need for a comprehensive, coordinated strategy with the potential for bureaucratic overhead. It aims to provide transparency and accountability to Congress regarding AI threats, but relies on the effectiveness of interagency cooperation and the willingness of Congress to act on the recommendations.
Section 2(b)(2)
Specific Risk Considerations for Strategy Development
This section mandates that the annual strategy reports must specifically consider a range of AI-related risks. These include deepfakes, voice cloning, foreign election interference, synthetic identities, AI-driven market responses, false flags disrupting markets, AI-supported social engineering attacks, cyber breaches, number spoofing, and overall digital fraud and scams. This ensures the strategy is comprehensive in its scope of threats.
Section 2(c)
Legislative Recommendations and Best Practices
Within 90 days after each annual strategy report, the Secretaries of the Treasury, Homeland Security, and Commerce must jointly submit a set of recommendations to Congress. These recommendations are to include proposed legislation to address AI-driven financial crime risks and best practices to help American businesses and government entities mitigate risks and respond to incidents.