Oversight for Frontier AI through a Know-Your-Customer Scheme for Compute Providers

To address security and safety risks stemming from highly capable artificial intelligence (AI) models, we propose that the US government should ensure compute providers implement Know-Your-Customer (KYC) schemes. Compute - the computational power and infrastructure required to train and run these AI models - is emerging as a node for oversight. KYC, a standard developed by the banking sector to identify and verify client identity, could provide a mechanism for greater public oversight of frontier AI development and close loopholes in existing export controls. Such a scheme has the potential to identify and warn stakeholders of potentially problematic and/or sudden advancements in AI capabilities, build government capacity for AI regulation, and allow for the development and implementation of more nuanced and targeted export controls. Unlike the strategy of limiting access to AI chip purchases, regulating the digital access to compute offers more precise controls, allowing regulatory control over compute quantities, as well as the flexibility to suspend access at any time. To enact a KYC scheme, the US government will need to work closely with industry to (1) establish a dynamic threshold of compute that effectively captures high-risk frontier model development, while minimizing imposition on developers not engaged in frontier AI; (2) set requirements and guidance for compute providers to keep records and report high-risk entities; (3) establish government capacity that allows for co-design, implementation, administration and enforcement of the scheme; and (4) engage internationally to promote international alignment with the scheme and support its long-term efficacy. While the scheme will not address all AI risks, it complements proposed solutions by allowing for a more precise and flexible approach to controlling the development of frontier AI models and unwanted AI proliferation.