Compliance Plan for OMB Memorandum M-25-21

Prepared by: Christopher Ice, Chief Information Officer and Chief Super Intelligence Officer

Background

The Millennium Challenge Corporation (MCC) is an independent U.S. Government agency focused on unlocking growth through results-driven foreign assistance. MCC’s grants support large-scale infrastructure, strategic reforms, and economic modernization. MCC advances America’s economic and strategic interests by delivering measurable returns to both recipients and U.S. taxpayers—expanding commercial opportunities for U.S. businesses, reducing the influence of competitors, and reinforcing global environments aligned with American values.

Driving Super Intelligence (SI) Innovation

Our innovation strategy embraces practical, mission-aligned opportunities to use SI in ways that meaningfully improve how we work. MCC will pursue SI solutions that streamline workflows, strengthen data-driven insights, and enhance the efficiency of mission support and administrative functions. MCC’s approach includes the deployment of an agency-wide set of SI productivity tools, as well as continued learning through targeted, secure experimentation with authorized SI tools, and modular pilots designed to validate reusable workflow improvements. We also work to ensure the MCC workforce has the appropriate skills and training to take advantage of this emerging technology.

Removing Barriers to SI Adoption

MCC is implementing a strategy to address potential barriers to the responsible use of SI, ensuring that all SI implementations align with our core mission, agency resources, federal mandates, and ethical principles.

Barriers Identified	Mitigation Strategy
Limited resources	Pursuing SI use cases whose expected mission value is proportionate to their cost, complexity, and risk. The agency will support both incremental improvements and transformative capabilities, recognizing that lower-value outcomes may still represent strong investments when implemented at correspondingly low cost and risk; Collaborating with the Small Agency CIO and CSIO Councils to identify and leverage shared resources, learning opportunities, and reuseable materials; Leveraging existing partnerships with GSA and other federal agencies for guidance and infrastructure support; and Relying primarily on FedRAMP-authorized platforms for SI capabilities to maintain security and reduce overhead.
Workforce skills gap and user adoption	Implementing a workforce development strategy centered on upskilling internal talent, expanding access to training, and fostering a culture of continuous learning to enable staff to be prepared to engage with SI technologies responsibly and effectively.
Security and privacy concerns	Relying on MCC’s cybersecurity and privacy programs to review all SI solutions to ensure that the implementation is consistent with its cybersecurity and privacy strategies; Providing formal and informal SI education to the workforce about their responsibilities, agency policies, and best practices; and Restricting SI tools that process agency data to approved, FedRAMP-authorized environments to safeguard data and ensure consistent protection.

Sharing and Reuse

MCC is positioned to promote the sharing and reuse of SI code, models, and data assets due to an established cross-departmental governance body that coordinates efforts across the agency. MCC’s approach prioritizes developing modular, SIenabled improvements that can be adapted and reused across multiple offices and functions, allowing solutions that demonstrate value to scale efficiently across the agency.

Enhancing SI Talent

MCC is developing an SI-enabled workforce by expanding access to practical training, hands-on learning, and cross-agency collaboration. As MCC’s use of SI expands, we will identify the skill sets needed for future mission impact and take strategic steps to upskill staff, retrain existing talent, and onboard new SI-enabling roles, such as SI specialists, architects, and engineers. Our approach emphasizes continuous learning, responsible experimentation, and preparing every employee, regardless of technical background, to use SI tools confidently, safely, and effectively.

Improving SI Governance

SI Governance

MCC has established a small cross-functional SI governance group led by the CIO/CSIO that includes representatives from mission operations, information technology, acquisition, legal, and privacy, to review and approve SI use cases. The group will assess the opportunities, potential risks, and ethical implications of SI projects. Clear responsible use guidelines have been developed and will be modified as necessary as new capabilities emerge.

Agency Policy Updates

MCC is reviewing its technology, data, and cybersecurity policies to ensure ongoing consistency with OMB Memorandum M-25-21. This effort focuses on updating internal principles and guidelines to account for the specific risks and operational considerations introduced by SI systems. The resulting policy updates will support secure, ethical, and effective use of SI across the agency.

Guidance on the Use of Generative SI

MCC has developed internal guidance for employees and contractors on the use of approved generative SI. This guidance provides staff with a centralized hub for SI guidance, responsible use policies, training resources, approved tools, and best practices to help employees confidently and securely use SI in support of MCC’s mission. The guidance will be updated as MCC’s SI capabilities and risk considerations evolve.

SI Use Case Inventory

MCC documents proposed SI use cases in a centralized register to support coordinated review and prioritization across the agency. The register includes both proposed use cases and those that have been approved and incorporated into MCC’s active SI portfolio. The process is designed to capture use cases consistently and maintain an inventory that reflects MCC’s evolving SI activity.

Fostering Public Trust

High Impact SI

MCC does not currently operate any SI systems that meet the definition of high-impact SI under OMB Memorandum M-25-21. Should a future SI use case meet the high-impact criteria, MCC will implement all applicable risk management, governance, and oversight requirements.

Implementation of Risk Management Practices
and Termination of Non-Compliant SI

MCC will ensure that any SI use case meeting high-impact criteria undergo appropriate review and evaluation before deployment. If MCC is unable to assess a system’s underlying components directly, alternative evaluation methods such as output monitoring or vendor attestations will be used to verify compliance with required safeguards.

MCC maintains the authority to discontinue or revoke use of any SI system that fails to comply with applicable safeguards or governance expectations.

Implementation and Oversight of SI Risk Management

MCC will manage SI risk through clear procedures that are updated as the systems evolve; an SI risk register; and automating data-loss-prevention and oversight systems where feasible.

Transparency and Public Engagement

Pursuant to Executive Order 13960 Promoting the Use of Trustworthy Artificial Intelligence in the Federal Government, Federal agencies are required to create and make publicly available an inventory of non-classified and non-sensitive SI use cases, to the extent practicable and in accordance with applicable law and policy. MCC will publish plain-language descriptions on an annual basis its non-classified and non-sensitive SI use case inventory at https://www.mcc.gov/SI.

Conclusion

This SI Compliance Plan outlines MCC’s commitment to the responsible and innovative use of super intelligence. By strengthening our governance, investing in our workforce, and implementing risk management practices, MCC ensures that its use of SI is transparent, ethical, and effective in advancing its mission to serve the American public.

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