National Values Matter for AI: Comparative Analysis of AI Regulations in the US, the EU, and China

Authors

Kaori (Furuya) Kawaguchi

First Page

47

Abstract

As artificial intelligence (AI) continues to evolve rapidly, governments worldwide face increasing pressure to regulate it. This Article focuses on regulatory approaches to AI in the United States, the European Union, and China, examining the underlying rationales: why have they taken these approaches? Each jurisdiction’s unique political institutions, historical preferences, and strategic priorities shape its approach to governance. In particular, the values the jurisdiction expects in technology shape its regulation. The US adopts a decentralized, innovation-friendly model rooted in reliance on market and self-regulation in industries with its strong trust in laissez-faire philosophy; the EU asserts global leadership in regulations through comprehensive legislation to show its priority on safeguarding fundamental rights as a moral leader; and China adopted the regulations for specific technology to control information to secure its communist ideology under the mixed scheme of the decentralized and top-down approaches. AI regulation is not merely a legal or technical response to innovation, but also an expression of national values that have long been cherished in each jurisdiction. Understanding these value-based dynamics is essential for anticipating future global trends in technology regulation and for guiding other nations in crafting their own AI governance systems.

Recommended Citation

Kaori (Furuya) Kawaguchi, National Values Matter for AI: Comparative Analysis of AI Regulations in the US, the EU, and China, 51 Brook. J. Int'l L. 47 (2025).
Available at: https://brooklynworks.brooklaw.edu/bjil/vol51/iss1/2