Artificial Intelligence Governance: Comparing U.S. and French Approaches for Iran

The rapid transformation in the field of artificial intelligence (AI), particularly following the emergence and proliferation of generative AI in ۲۰۲۲, has reshaped power dynamics in the international system, positioning this technology as a central pillar of power, security, and governance in the emerging global order. Within this context, the United States and France—representing distinct discursive paradigms (American market-oriented liberalism and European law-centered continentalism)—have adopted divergent approaches to AI governance, reflecting a strategic competition over the architecture of the future technological order. This study employs an analytical-comparative approach and a qualitative methodology based on the examination of official documents, national strategies, and policy frameworks to investigate and compare the developments and initiatives of the United States and France from ۲۰۲۲ to ۲۰۲۵. The innovation of this research lies in its integration of conceptual analysis with structural-institutional assessment, identifying strategic gaps between the two governance models and elucidating their international implications in shaping global AI norms. The findings indicate that the United States, emphasizing market dynamism, industry self-regulation, and a facilitative governmental role, pursues a flexible and innovative governance model. Through the influence of leading corporations and industrial standards, it seeks to globally propagate its light-touch regulatory approach. In contrast, France, aligned with the European Union, emphasizes proactive regulation, active industrial policy, and substantial investment, advancing a law-centered, value-driven model aimed at safeguarding technological sovereignty and promoting responsible AI development. The comparative analysis reveals that beyond differences in governance philosophy, the two approaches diverge significantly in institutional structures, modes of engagement with the private sector, degree of government intervention, and participation in multilateral initiatives. This divergence has contributed to the emergence of a global regulatory duality and challenges in achieving international consensus, although geopolitical pressures arising from competition with China have created opportunities for functional convergence. The study concludes that this competition encompasses not only technological but also normative and civilizational dimensions, potentially leading over the long term to the development of a hybrid and balanced model that combines the strengths of both the American and European frameworks in shaping the future architecture of AI governance.

کلیدواژه ها:

Artificial intelligence governance ، active industrial policy ، risk-based regulation ، industry self-regulation ، technological governance