What changed between these versions
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.
Overview
A significant number of changes, including several major additions and numerous modifications to existing provisions. · v2 expands the scope and detail required for the strategy report, broadens the range of risks to be considered, and increases the number of consulted agencies, while also refining the focus on "adversarial actors."
The most significant change in v2 is the expansion of the annual report's content, now requiring a classified annex and a description of public-private partnerships to combat AI-driven financial crimes. The list of specific risks to be considered has been substantially broadened to include AI-Driven Market Response, social engineering, cyber breaches, and number spoofing. Furthermore, the roster of officials to be consulted has been expanded to include additional financial regulatory bodies, while two trade-related officials were removed.
Major additions
v2 adds a requirement that the annual report "shall include a classified annex and may include an unclassified summary, provided that no sensitive information is disclosed publicly."
This addition significantly increases the depth and sensitivity of the information to be reported to Congress, allowing for the inclusion of classified intelligence regarding AI-driven financial crimes without public disclosure. This ensures a more comprehensive and secure assessment of threats.
This new subsection requires the report to include "A description of public-private partnerships, collaborative arrangements, and other coordinated activities of Federal departments and agencies in cooperation with the private-sector to defend United States financial markets, United States persons, United States businesses, and global supply chains from the national and economic security risks posed by the use of artificial intelligence by adversarial actors in the commission of financial crimes."
This addition mandates reporting on collaborative efforts between government and the private sector, recognizing the critical role of industry in combating AI-driven financial crimes. It highlights the importance of shared defense strategies and information exchange.
v2 adds "Artificial Intelligence-Driven Market Response," "Attacks involving AI-supported social engineering," "Cyber breaches," and "Number Spoofing" to the list of risks that the reports must take into consideration.
These additions broaden the scope of threats that the strategy must address, reflecting a more comprehensive understanding of how AI can be leveraged in financial crimes. "AI-Driven Market Response" points to algorithmic manipulation, while "social engineering," "cyber breaches," and "number spoofing" cover a wider range of digital attack vectors.
v2 adds the Comptroller of the Currency, the Chairperson of the Federal Deposit Insurance Corporation, the Chairman of the National Credit Union Administration, the Chairman of the Federal Communications Commission, and the Chairman of the Federal Trade Commission to the list of officials to be consulted for the report.
This significantly widens the range of expertise and regulatory perspectives involved in developing the strategy, particularly by including key financial regulators and consumer protection agencies. This ensures a more holistic approach to addressing AI-driven financial crimes across various sectors.
Deletions
v1 required consultation with the United States Trade Representative and the Under Secretary of Commerce for Industry and Security. These officials are removed from the list in v2.
The removal of these trade-focused officials suggests a slight shift in emphasis, potentially streamlining the consultation process to focus more directly on financial and cybersecurity regulatory bodies, rather than broader trade policy implications.
Modifications
While "fraud" and "misinformation" (as "foreign election interference") are still listed as considerations within the report, their removal from the main title of the strategy section slightly refines the overarching framing, emphasizing "financial crime" as the primary category.
Before
The title of subsection 2(b) was "Strategy To Defend Against Risks Posed by Misinformation, Fraud, and Financial Crime Conducted With Artificial Intelligence."
After
The title of subsection 2(b) is now "Strategy to Defend Against Risks Posed by Financial Crime Conducted With Artificial Intelligence."
This modification broadens the institutional scope of the strategy to include international cooperation and working groups. The explicit inclusion of "adversarial actors" clarifies the target of the defense strategy. The removal of specific examples here streamlines the language, as these are covered in the "Considerations" list.
Before
Required a description of interagency policies and procedures to defend against national and economic security risks posed by AI in financial crimes, including fraud and misinformation.
After
Requires a description of "interagency and applicable intergovernmental policies, procedures, and working groups" to defend against risks posed by AI "by adversarial actors" in financial crimes. It removes the specific mention of "including fraud and the dissemination of misinformation."
This modification significantly increases the analytical depth required for the report regarding existing resources. It moves beyond a mere inventory to a strategic assessment, including human capital, which provides a more actionable understanding of current capabilities.
Before
Required an itemized list of readily available resources (hardware, software, technologies) to combat AI financial crimes.
After
Requires "An itemized list of, and accompanying analysis of, readily available resources, including hardware, software, technologies, and people that can be immediately deployed by Federal departments and agencies to combat the use of artificial intelligence in the commission of financial crimes, with an assessment of their capabilities, limitations, and tradeoffs."
This modification demands a more rigorous and strategic evaluation of future resource needs, providing Congress with a clearer picture of gaps and investment priorities, including an assessment of potential effectiveness and drawbacks.
Before
Required an itemized list of needed resources (hardware, software, technologies, people, budgetary estimates) to combat AI financial crimes.
After
Requires "An itemized list of, and accompanying analysis of, resources, including hardware, software, technologies, and people, and budgetary estimates needed to help Federal departments and agencies to combat the use of artificial intelligence in the commission of financial crimes, with an assessment of their capabilities, limitations, and tradeoffs."
This broadens the scope of digital financial crimes to be considered, ensuring that the strategy addresses not just technical fraud but also various forms of digital deception.
Before
Listed "Overall digital fraud" as a consideration.
After
Lists "Overall digital fraud and scams" as a consideration.
This modification aligns the recommendations section with the refined focus on "adversarial actors" seen elsewhere in v2, ensuring that legislative and best practice proposals are specifically tailored to counter state-sponsored or organized criminal use of AI.
Before
Required legislative recommendations and best practices to address risks posed by AI in financial crimes, including fraud and misinformation.
After
Requires legislative recommendations and best practices to address risks posed by AI "by adversarial actors" in financial crimes. It removes the specific mention of "including fraud and the dissemination of misinformation."
Scope
Meaningful expansion or narrowing — Changes are concentrated within Section 2, which defines the core strategy and reporting requirements, but are pervasive throughout its subsections. — v2 represents a refinement and expansion within the same policy direction. It deepens the analytical requirements, broadens the range of threats considered, and widens the consultative body, rather than altering the fundamental purpose of the bill. — The changes primarily expand and detail the requirements of the strategy report and its associated recommendations, directly impacting how the federal government will assess and respond to AI-driven financial crimes. The expanded list of consulting officials also broadens interagency coordination.
Impact analysis
Federal departments and agencies (Treasury, Homeland Security, Commerce, and consulting agencies)
Procedural change and increased responsibility.
These agencies are now required to produce a more detailed annual report, including a classified annex and an analysis of public-private partnerships. They must also consider a broader range of AI-driven financial crime risks and provide a more in-depth assessment of resources.
Private-sector entities engaged in financial markets, businesses, and global supply chains
Increased engagement and potential for collaboration.
The bill now explicitly requires reporting on public-private partnerships and collaborative arrangements to defend against AI-driven financial crimes. This suggests an increased emphasis on government engagement with the private sector.
Congress and policymakers
Increased information and oversight capability.
Congress will receive more detailed, comprehensive, and potentially classified reports on AI-driven financial crime risks and the strategy to combat them.
Adversarial actors utilizing AI for financial crimes
Increased governmental focus and defensive measures.
The bill's language is more explicitly focused on countering "adversarial actors," indicating a sharpened governmental focus on these specific threats.