ScholarWorks@숙명여자대학교

초록

Despite their historical closeness, the UK and the US have developed distinct AI regulatory policies, influenced by their unique political, economic, and cultural characteristics. These policies have shaped their respective regulatory frameworks. The UK emphasizes a flexible regulatory policy that promotes the advancement and innovation of AI technology, aiming to assert leadership on the international stage. The UK has established an agency-specific AI regulatory framework based on principles and outcomes, advocating for pro-business and pro-innovation regulatory principles. Concurrently, the UK seeks to counter the growing trend towards stringent and comprehensive AI regulations globally by building bilateral and multilateral AI regulatory cooperation frameworks. In contrast, following President Biden's executive order in October 2023, the US is showing signs of moving away from its previously growth-centric self-regulatory AI policy. The US has a dual AI regulatory framework based on its federal and state decentralized legal systems. While state governments have implemented AI regulatory policies through legislative measures, the federal government has mainly adopted soft and voluntary AI regulatory policies. However, with the emergence of various normative and ethical issues related to AI and the corresponding regulatory needs raised by various sectors of society, the federal government has begun to demonstrate a strong commitment to AI regulation through executive orders. This shift is particularly significant given that, under the strict separation of powers in the US, executive orders are evolving into de facto legislative tools with equivalent status to congressional legislation. Both the UK and US AI regulatory policies are framed within a broader “adaptive regulation” paradigm experienced by the international community. Despite being developed according to their respective regulatory principles, goals, and normative systems, both countries' AI regulatory policies revolve around specific principles. These principles focus on the safety, sustainability, and innovation of AI technology. Through these policies, the UK and the US aim to enhance the competitiveness of their AI technology and maintain regulatory leadership in the international arena. Research on these regulatory policies is crucial as they provide essential foundational data for predicting the future development of inter-country cooperation frameworks.

키워드