BSA appreciates the opportunity to provide comments on the Department of Commerce’s Bureau of Industry and Security’s (BIS) Notice of Proposed Rulemaking (NPRM or Proposed Rule) to implement aspects of the Executive Order on Taking Additional Steps to Address the National Emergency With Respect to Significant Malicious Cyber-Enabled Activities signed by President Trump on January 19, 2021 (EO 13984) and the Executive Order on Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence signed by President Biden on October 20, 2023 (EO 14110).