Protecting Our Communications Networks by Promoting Transparency Regarding Foreign Adversary Control
In this document, the Federal Communications Commission (Commission or FCC) addresses the risks of foreign adversary control of Commission-granted licenses and authorizations by adopting rules requiring a broad range of holders of such licenses, authorizations, or approvals to attest whether they are owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary, and, if so, to disclose additional information about such foreign adversary control. Among other things, the Commission defines categories of licenses and authorizations that are subject to the rules, and establishes a streamlined process by which license and authorization holders should file their foreign adversary control attestations and disclosures.
What this rule actually says
The FCC now requires anyone holding an FCC license or authorization to disclose whether a foreign adversary owns, controls, or can direct their business. "Foreign adversary" means countries like China, Russia, Iran, and North Korea. If the answer is yes, more detailed disclosures are required.
Who it applies to
- If you hold an FCC license or authorization (most AI founders don't—this typically means telecom, broadcast, or spectrum licenses), this applies.
- If you're a solo founder building a chatbot, medical scribe, or hiring tool with no FCC licenses, this does not apply.
- If you're building AI infrastructure that uses spectrum or telecom services you don't license yourself, you're not directly subject to this rule.
- If you have foreign investors or owners from China, Russia, Iran, or North Korea, and you somehow hold an FCC license, disclosure is required.
- If you operate only in the US and have no FCC licenses, you can safely ignore this.
The rule focuses on *who controls the license holder*, not on what data the AI processes or where users are located.
What founders need to do
- Check if you hold any FCC licenses (1 hour). Most indie AI founders don't. Search the FCC's license database for your company name. If nothing appears, you're done.
- If you do hold a license, map your ownership structure (2-3 hours). Document who owns your company, who sits on the board, and whether any foreign adversary countries have control or direction over decisions.
- File an attestation with the FCC if required (1-2 days). The FCC will provide a streamlined filing process. This involves submitting a form confirming your foreign adversary status.
- If foreign adversary control exists, disclose additional details (varies). You'll need to provide information about that control relationship. Consult an FCC attorney if this applies—it's complex.
- Monitor ongoing changes to your ownership (ongoing). If your cap table changes, document it in case foreign investment enters.
Bottom line
Unless you hold an FCC license (which is rare for AI founders), ignore this entirely—it doesn't affect medical scribes, chatbots, hiring tools, or most AI applications.