Analysis of Proposed Artificial Intelligence Regulations: Perspectives from the United States, China, and the European Union

This paper presents a comprehensive analysis of artificial intelligence (AI) regulations in the European Union (EU), China, and the United States (US). The evolving landscape of AI governance reflects distinct approaches rooted in legal traditions and societal priorities. In the EU, the regulatory framework, epitomized by the proposed AI Act, emphasizes a balance between AI innovation and safeguarding fundamental rights. The Act classifies AI systems based on risk, introducing prohibitions, requirements, and transparency obligations. The General Data Protection Regulation (GDPR) serves as a foundation, ensuring a unified approach to data protection. In the US, the regulatory landscape is characterized by a decentralized model with a focus on consumer protection. The Federal Trade Commission (FTC) plays a pivotal role in addressing AI-related challenges, emphasizing transparency, fairness, and accountability. The absence of a comprehensive federal privacy law is compensated by a combination of federal and state regulations. China's approach centers on a centralized regulatory model that seeks to harmonize AI innovation with content quality, ethics, and data privacy. The measures introduced for generative AI technologies emphasize adherence to existing laws, including the Cybersecurity Law, Data Security Law, and Personal Information Protection Law. The regulations aim to strike a balance between responsible AI development and societal well-being. However, centralized control over generative AI services empowers authorities with substantial influence over their deployment, leading to questions about the possibility of leveraging these regulations for political purposes. Comparative analysis reveals common principles across regions, such as the importance of transparency, fairness, and accountability. However, significant differences emerge in the emphasis placed on protecting consumers and user rights in the US and EU, contrasted with China's focus on content quality, ethics, data privacy and governmental oversight. These distinctions underscore the multifaceted nature of AI and privacy regulation on the global stage, shaped by diverse legal frameworks and cultural priorities. Understanding these variations is essential for stakeholders navigating the complex landscape of AI governance.