On July 23, 2025, the Trump Administration released Winning the Race: America's AI Action Plan, setting out a whole-of-government approach and policies regarding US artificial intelligence strategy. The AI Action Plan includes over 90 recommended federal policy changes across three pillars: 1) Accelerate AI Innovation, 2) Build American AI Infrastructure, and 3) Lead in International AI Diplomacy and Security.1
The goal of the AI Action Plan is for America to take the lead in developing the AI standards, policies, infrastructure and technology that would enable the US and its allies to win the global AI competition – for both economic and national security purposes.
Three Executive Orders
After publishing the AI Action Plan, the President quickly followed up by releasing three related Executive Orders (EOs) on Promoting the Export of the American AI Technology Stack, Accelerating Federal Permitting of Data Center Infrastructure, and Preventing Woke AI in the Federal Government.
These EOs are intended to focus the efforts of various departments such as the Department of Commerce, Department of State, Department of Energy, and others.
For example, they aim to establish and implement the American AI Exports Program, coordinate mobilization of Federal financing tools in support of priority AI export packages, and facilitate the rapid and efficient buildout of AI infrastructure by easing Federal regulatory burdens.
Key areas to monitor
The EOs are the first of many expected to support the AI Action Plan. However, the plan itself covers several vital areas that financial institutions will want to monitor, including efforts to identify, revise, or repeal regulations, guidance documents, policy statements, and interagency agreements that financial institutions are presently required to comply with but that might be deemed to unnecessarily hinder AI development.
These efforts could turn out to have implications in areas such as credit denials by lenders using AI, the use of AI chatbots in banking and the application of credit models using complex algorithms.
The plan also sets the scene for initiatives to promote policies that enable a "healthy financial market for compute" and it encourages the adoption of open-source and open-weight models by small and medium-sized businesses. It includes calls to establish regulatory sandboxes or AI Centers of Excellence, including at the US Securities and Exchange Commission (SEC).
The role of FI regulators
While the AI Action Plan mentions several domain-specific efforts in healthcare, energy, and agriculture to develop and adopt national standards for AI systems, there is little mention of domain-specific banking, capital markets and wealth management initiatives.
However, financial industry regulators will play an essential part in establishing future AI governance and risk management when they "conduct their evaluations of AI systems for their distinct missions and operations and for compliance with existing law," which could include AI-specific regulations under the regulators' purview.2
Other areas that financial institutions will need to monitor to understand specific requirements as they evolve include changes made by the National Institute of Standards and Technology (NIST) as it revises the NIST AI Risk Management Framework, private sector requirements to protect AI from security risks, the development of AI incident response doctrines, and the creation of an AI Information Sharing and Analysis Center (AI-ISAC) to promote the sharing of AI-security threat and vulnerability information and intelligence.
Leveraging the FI response
The AI Action Plan offers financial institutions a chance to contribute to AI advancements. It encourages firms to make critical investments in new data centers, semiconductor manufacturing and energy infrastructure.
There will also be the opportunity, if adopted, for employees to use educational assistance under the Internal Revenue Code to obtain AI literacy and skills development training. This could help to upskill employees in the financial industries and transform how work is done.
As the AI Action Plan is implemented, there will be both challenges and opportunities for financial institutions. Capco will be both closely monitoring developments and helping position our clients to fundamentally reshape their businesses within the next five years through AI. The challenge now lies in identifying the most strategic and impactful ways to leverage this technology to maximize its potential.
References
1 https://www.whitehouse.gov/articles/2025/07/white-house-unveils-americas-ai-action-plan/
2 https://www.whitehouse.gov/wp-content/uploads/2025/07/Americas-AI-Action-Plan.pdf, page 10