HR 4142 · FederalIn Committee

HR 4142

No Adversarial AI Act

Medium RiskMay require changes to AI practices. Monitor and prepare.

TL;DR

Rep. John Moolenaar (R-MI) introduced the No Adversarial AI Act to ban federal agencies from buying or using AI systems developed by companies tied to foreign adversaries like China, Russia, Iran, and North Korea (think DeepSeek or other PRC-linked AI tools). The bill would create a federal blocklist of prohibited AI vendors and force agencies to rip out non-compliant systems.

How This Might Impact Your Business

Federal contractors and subcontractors selling AI tools to agencies would need to prove their AI models, training data, and ownership have no ties to China, Russia, Iran, or North Korea.

Government IT integrators (Booz Allen, Leidos, Accenture Federal, Palantir, etc.) would need to audit their AI supply chains and swap out any adversary-linked components before bidding on federal work.

Cloud and SaaS vendors serving federal customers would need to certify that embedded AI features (chatbots, analytics, copilots) are not built on models like DeepSeek, Qwen, or other PRC-origin systems.

Startups that fine-tuned products on Chinese open-source models (a common practice) could lose eligibility for federal contracts and grants.

Expect a published list of banned AI companies maintained by OMB or a similar federal body, with waiver processes for narrow exceptions.

Non-compliance would likely mean contract termination, debarment, and loss of federal revenue rather than direct financial fines.

Universities and research labs receiving federal funding may face parallel scrutiny of AI tools used in grant-funded work.

What Should You Do

1

Inventory every AI model, API, and open-source component used in products sold to federal customers, and flag anything with origins in China, Russia, Iran, or North Korea.

2

Ask your legal and procurement teams to draft supplier attestations covering AI model provenance, training data sources, and ownership structure.

3

If you fine-tuned on models like DeepSeek, Qwen, or Yi, begin evaluating US or allied-country replacements (Llama, Mistral, GPT, Claude, Gemini) before contract renewals.

4

Track the House Oversight Committee schedule for markup; this bill has bipartisan China-hawk momentum and could move quickly.

5

Brief your federal sales team so they can proactively answer procurement officers asking about adversarial AI exposure.

Who It Affects

Federal ContractorsDefense TechEnterprise AI/SaaSCloud ComputingGovernment IT ServicesCybersecurity

Sponsors

Status Timeline

  1. committee

    Referred to the House Committee on Oversight and Government Reform.

    June 25, 2025

AI-generated analysis for informational purposes only. Not legal advice. Always consult a qualified attorney for legal guidance.Last action Jun 25, 2025

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