22

May

2025

“One Big Beautiful Bill” would put moratorium on states’ ability to regulate AI following Trump’s unwinding of federal oversight

On May 22, 2025, the House of Representatives passed the “One Big Beautiful Bill,” a sweeping budget reconciliation measure that includes major artificial intelligence provisions. Section 43201, named the “Artificial Intelligence and Information Technology Modernization Initiative,” would allocate $500 million to modernize and secure federal IT systems by deploying commercial AI technologies. If the Senate passes the bill and President Donald Trump signs it into law, then states would also be under a 10-year moratorium prohibiting them from enacting or enforcing any regulation or oversight of the nascent and rapidly growing AI industry. In 2024, 45 state legislatures introduced AI-related bills, and 31 states enacted laws. The moratorium directly targets that surge in state activity and will likely trigger lawsuits challenging Congress’s ability to broadly preempt state law in any matter without establishing meaningful federal legislation to assume its place.

If the omnibus spending bill gets enacted, and absent the 119th Congress giving serious consideration to AI-focused legislation at any point, which it is highly unlikely to do, then regulation and oversight of AI in the U.S. would likely be nill to none on both the federal and state level. Trump moved to reverse course from President Joe Biden’s administration on AI regulation immediately upon assuming office. On January 20, 2025, Trump signed an executive order that not only revoked Biden’s October 2023 executive order on the safe and responsible development of AI but also effectively invalidated and nullified the final AI guidance promulgated by the Department of Commerce’s National Institute of Standards and Technology (NIST) in July 2024 on the basis of Biden’s directive. NIST’s final guidance documents had included the AI Risk Management Framework and Generative AI Profile (NIST AI 600-1), Secure Software Development Practices for Generative AI and Dual-Use Foundation Models (NIST SP 800-218A), and a Plan for Global Engagement on AI Standards (NIST AI 100-5). These documents were intended to provide a roadmap for organizations—particularly in emerging technologies like blockchain and digital assets—to manage AI risks and simultaneously attempt to promote innovation and global cooperation.

Last Updated 05/22/2025.

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Amil Malik

Amil assists with various client matters in connection with digital assets and the adoption of blockchain technology, including general corporate law, securities law, and financial services regulation. She joined DLx Law after receiving her J.D. from the George Washington University School of Law, where much of her studies focused on national security and cybersecurity law.

Amil received her B.B.A./B.A. with high honors from the University of Texas at Austin. Between university and law school, Amil worked as a mergers and acquisitions analyst in New York, where she performed financial valuations and analysis as part of advisory services provided to sell-side and buy-side clients across media, consumer, technology, shipping, and financial technology industries. Amil is licensed to practice law in the District of Columbia.

Tom Momberg

+17186645458 tom.momberg@dlxlaw.com

Tom advises clients in an array of matters related to blockchain technology, decentralized finance, banking and payments systems, financial products, and financial technology applications. He joined DLx Law as an attorney after working as in-house counsel for a payments and banking software service provider, advising on various legal and regulatory matters, operations, risk, customer due diligence, and corporate best practices.

Tom received his J.D. from George Mason University Law School in Virginia and his B.A. from the University of Wisconsin-Milwaukee. Tom is a former journalist, and, while in law school, he interned for DLx Law and served as a law clerk for several federal institutions in Washington, D.C., including the CFTC, FCC, and House Judiciary Committee. Tom is admitted to practice law in the District of Columbia and the State of Oregon.

Sarah Chen

+19296345691 sarah.chen@dlxlaw.com

Sarah advises clients in all matters related to the adoption of blockchain technology, including general corporate, venture financing, securities laws and financial regulatory. Prior to joining DLx Law, Sarah was a senior associate in the M&A group of an international law firm headquartered in New York City, advising public companies and private equity firms on mergers, acquisitions, and other corporate transactions.

Sarah received her B.A. from New York University, magna cum laude, and her J.D. from Columbia Law School where she was a James Kent Scholar. During law school, Sarah also served as a judicial extern to the Hon. Debra Ann Livingston of the U.S. Court of Appeals for the Second Circuit. Sarah is licensed to practice law in the State of New York.

Gregory Strong

+3027665535 greg.strong@dlxlaw.com

Greg focuses on advising entities regarding legal issues associated with the adoption of blockchain technology. Prior to joining DLx Law, Greg was a Deputy Attorney General in the Delaware Department of Justice. He served as the Director of the Investor Protection Unit for three years and was responsible for administering and enforcing the provisions of the Delaware Securities Act. Prior to his appointment as Director of the Investor Protection Unit, Greg was the Director of the Consumer Protection Unit for three years.

Greg has successfully represented the State of Delaware in many complex civil enforcement matters alleging violations of Delaware investor and consumer protection statutes and has extensive litigation experience. Greg graduated from Lehigh University with a B.S. in Finance and received his J.D./M.B.A. from Temple University.

Angela Angelovska-Wilson

+12023651448 angela@dlxlaw.com

Angela is an early distributed ledger technology adopter and a leading authority in the evolving global legal and regulatory landscape surrounding distributed ledger technology and smart contracts. Prior to co-founding DLx Law, Angela served as the Chief Legal & Compliance Officer of Digital Asset and was part of the founding team.

Prior to joining Digital Asset, Angela was a partner at Reed Smith where she regularly advised clients on the implementation of new technologies to finance and the complex regulatory schemes involved in the development, creation, marketing, sale and servicing of various financial services and products. Before Reed Smith, Angela spent most of her career in various roles at Latham & Watkins, where she was recognized by The Legal 500 US among the top finance attorneys in the U.S.

Angela has a deep understanding of the Fin-Tech industry and in particular the distributed ledger industry, having been involved in a number of startups in various roles, as an employee, entrepreneur and advisor. In addition to DLx Law, Angela is also co-founder of Sila Inc., an innovative technology company.