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Emerging Opportunities & Implications of the “AI Manhattan Project”
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Curtis Law - Pro Bono
Client Alert 17 Dec. 2025
Download the full client alert here.
Key Takeaways
1. The Genesis Mission establishes a federally coordinated effort to accelerate AI-backed scientific discovery organized under the Department of Energy.
2. The initiative has significant implications across multiple sectors, including energy infrastructure, data governance, and trade. This not only introduces complex regulatory considerations, but also creates novel opportunities.
3. The Genesis Mission fits within a broader geopolitical strategy aimed at maintaining U.S. technological dominance and strategic advantage.
Overview
On November 24, 2025, President Trump signed an Executive (EO) launching the Genesis Mission. In essence, the Mission is a coordinated federal initiative to accelerate scientific progress through advanced AI systems and computing systems. Notably, the Mission is “comparable in urgency and ambition to the Manhattan Project,” the massive, top-secret program launched by the U.S. government during WWII to mobilize the country’s top talent and resources to successfully develop the first nuclear weapons. Given the scope and impact of the Manhattan Project, the comparison with the Genesis Mission seems especially striking.
The EO directs the Department of Energy (DOE) to build an “American Science and Security Platform.” This platform would serve as a uniform and secure infrastructure to integrate DOE supercomputers, cloud-based AI systems, scientific models, and federal datasets. This platform would be intended for model training, experimentation, and AI-augmented research across critical sectors such as biotechnology, manufacturing, and semiconductors.
Echoing the public-private partnerships that were key to the Manhattan Project, the EO calls for a combined effort that will combine “the efforts of brilliant American scientists, including those at our national laboratories, with pioneering American businesses; world-renowned universities; and existing research infrastructure, data repositories, production plants, and national security sites—to achieve dramatic acceleration in AI development and utilization.”
The EO also lays out an aggressive implementation timeline. Within months, the DOE is directed to inventory resources, identify datasets and models, establish regulatory frameworks, and assess national laboratory facilities. Then, within 270 days, the DOE is further tasked with demonstrating initial operational capability of the American Science and Security Platform in the context of at least one national science challenge. Altogether, the Genesis Mission represents a significant expansion of AI infrastructure and a shift towards centralized stewardship of scientific assets—developments that will shape energy, data governance, and trade practices.
The Energy Sector
The Genesis Mission is arriving at a point in time in which AI computing is critically reshaping energy consumption. According to an article published by the MIT Technology Review, AI-specific power usage will rise to 326 terawatt-hours per year by 2028 – the equivalent of the electricity required to power 22% of all U.S. households. Large-scale model training, simulations, and inferences soon to be managed by the DOE, combined with similar endeavors in the private sector, are projected to add multi-gigawatts to national electricity demand, exponentially increasing the need for new generation capacity, storage, and grid capacity and modernization.
Recent private-sector activity illustrates the sheer scale of such demands. For instance, Microsoft signed a 20-year power purchase agreement (PPA) with Constellation Energy to support the restart of the Crane Clean Energy Center (formerly known as Three Mile Island Unit 1). This energy center would generate large amounts of carbon-free electricity needed to power Microsoft’s data centers for its growing AI operations. The PPA is backed by a $1 billion DOE loan guarantee—demonstrating the growing alignment between federal priorities and private-sector infrastructure needs. Accordingly, nuclear repowering, alongside renewables, batteries, and hybrid clean-energy systems, is becoming a key element of meeting newly emerging AI-backed power needs.
For international investors, this environment presents opportunities across the clean energy and grid modernization value chain. Increasing electricity demand is expected to accelerate utility-scale renewable development, hybrid clean-energy projects, and interest in advanced nuclear technologies, as well as continued deployment of conventional natural gas-fired generation. Such dynamics create entry points for foreign developers and infrastructure investors seeking exposure to the U.S. market. At the same time, participation by non-U.S. entities will require careful legal and strategic assessment of federal incentives, long-term contracting arrangements, and regulatory requirements and sensitivities.
Data Governance
The Administration has begun treating data not merely as a basic input but as a central, regulated resource, akin to more traditional energy assets such as oil and gas. As such, data quality and provenance have become new points of consideration when determining the U.S.’s (or any country’s) capacity for breakthrough innovation and competitive positioning in emerging technologies. Accordingly, access to data will likely become increasingly conditioned on meeting federal standards related to cybersecurity and supply-chain integrity. The EO reinforces this direction by requiring DOE’s platform to provide “secure access to appropriate datasets . . . consistent with applicable laws . . . classification, privacy, and intellectual property protections; and Federal data-access and data-management standards.” With these directives, the Administration hopes to move the United States toward a more centralized and security-conscious model of data governance.
Perhaps a useful comparison is to the “Smart Data Framework” adopted by the United Arab Emirates, which established a tiered cloud-security and data-governance structure to manage sensitive data. Under this model, access to data is permitted and governed by security standards. Three distinct core standards underline the Smart Data Framework: data classification, data exchange, and data quality. Each of these three standards come together to govern all aspects of how data is created, managed, used, and reused within the UAE. Then, underlying measures such as controls on encryption, identity verification, data location, and ongoing auditability are used to create a regulated ecosystem. Ultimately, this leads to an environment in which providers and users alike are required to demonstrate compliance before they are permitted to work with sensitive information. The EO direction to create the Genesis Mission, and other related federal directives, suggest a similar trajectory for the U.S., wherein the DOE is a central gatekeeper for high-value data and AI models.
Within this context, organizations seeking to engage with the agencies and private stakeholders as part of the implementation of the Genesis Mission should anticipate having to comply with structured access controls, maintain in-depth documentation, meet stringent reporting expectations, and generally receive oversight of their data-handling practices. Further, individuals or entities operating in or tied to higher-risk jurisdictions such as China may face additional constraints related to national security issues. Early counsel may support participants in navigating and complying with such evolving requirements.
The Genesis Mission also parallels the European Union’s comprehensive effort to reconceptualize data as a strategic asset underpinning economic competitiveness and societal resilience. The European Union aims at creating a Single Market for Data grounded in interoperability, user trust, and technological sovereignty. Through its 2020 European Strategy for Data, the EU is building a network of sectoral Common European Data Spaces—including manufacturing, energy, mobility, finance, agriculture, skills, scientific research, and the green transition. Since then, additional data spaces have emerged in areas such as cultural heritage, tourism, media, and language technologies, with the long-term goal of interconnecting these environments into an interoperable, EU-wide data ecosystem. This signals a shift toward an opening to access European data, even if such access is mediated by standardized rules, intermediaries and sector-specific governance mechanisms.
At the legislative level, two core instruments define the current trajectory. The Data Governance Act (DGA) creates the framework for re-use of protected public-sector data. Its purpose is to increase data availability while ensuring that entities accessing or reusing such data operate within high-trust, highly supervised arrangements. The Data Act, entered into application in September 2025, goes further by requiring manufacturers and service providers to make connected-device data accessible to users and, in some cases, to third parties. It also imposes interoperability requirements for cloud services and sets conditions for business-to-government data access. These obligations will affect global companies operating IoT devices, cloud platforms, industrial systems, and AI models within the EU. Importantly, the Data Act also restricts non-EU governmental access to EU-stored data, which may complicate cross-border compliance strategies for companies subject to foreign disclosure regimes.
Taken together, the U.S., EU, and UAE approaches reflect a global trend toward more centralized, security-conscious, and standards-driven data ecosystems, yet with differing degrees of openness and regulatory oversight that multinational companies must strategically navigate.
Trade & Export Controls
The Genesis Mission is also likely to reshape regulations governing the cross-border movement of tech, data, and scientific tools. In fact, the EO specifically requires the Secretary of Energy to implement “data access and management processes and cybersecurity standards … [in] compliance with classification, privacy, and export-control requirements.” This likely implies that, as federal infrastructure for dynamic computing, AI models, and fundamental datasets becomes more integrated and consolidated, foreign groups and individuals working with U.S. institutions may face even tighter limitations on what information they can access or share. Likewise, global technology transfers through licensing, academic collaboration, or even commercial alliances may face additional procedural requirements as U.S. agencies work to safeguard certain information.
These developments could also have implications beyond traditional export classifications or licensing steps. In particular, companies with cross-border operations may need to better understand how the Administration’s heightened security posture affects research, supply-chain planning, and handling of technical flows, and to implement stronger due-diligence processes to ensure that both business objectives and regulatory requirements are met. Foreign investment in infrastructure associated with the Genesis Mission, including data centers and other computing facilities that support AI workloads, may also warrant a national-security review, depending on the type of ownership or involvement. Participants operating internationally may therefore benefit from an analysis to ensure that their activities abide by export-control laws so they can effectively manage cross-border engagements and transfers accordingly.
Broader Geopolitical Context
Overall, the implications for energy, data governance, and trade positions of this new EO fall squarely within the U.S.’s broader push to consolidate its technological edge. The Genesis Mission continues a trajectory set forth by prior policy efforts such as the CHIPS and Science Act, the Inflation Reduction Act, the One Big Beautiful Bill Act, and other executive initiatives focused on R&D efforts.
Collectively, these measures reflect a strategic effort to build and protect capabilities viewed as essential to the U.S.’s long-term competitiveness in the global market. Moreover, the Genesis Mission also fits into a broader geopolitical context shaped by intensifying economic and technological rivalries, especially with China. More generally, the EO is consistent with the U.S.’s recent issuance of its National Security Strategy of the United States of America, which in part declares a “Trump Corollary” to the Monroe Doctrine to check what it views as undue foreign commercial and military influence in the Western Hemisphere. By centralizing sensitive datasets and scientific processes, the U.S. is signaling a shift towards a more security-conscious, streamlined model.
International participants must therefore weigh commercial opportunities against the Trump Administration’s competitive posture and align cross-border investment and collaboration with evolving U.S. priorities.
Artificial Intelligence
Energy (Oil & Gas)
Data Protection and Privacy Law
International Trade
Elisa Botero
Partner
Charles B. Howland
Marwa Farag
Associate
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