OTI submitted comments to the Office of Science and Technology Policy in response to the OSTP's request for information on AI-based biometric technologies, explaining how private and public sector entities are increasingly developing and deploying the tech, posing numerous threats to privacy, civil rights, and fundamental freedoms. As OTI outlined in our comments, a range of AI-based biometric surveillance tools are deployed by law enforcement and U.S. immigration authorities, often “in secret and without public awareness,” and by a number of private companies, to fuel their marketing and advertising practices. OTI’s comments highlight that despite the expansive use of AI-based biometric tools, there are few existing safeguards to protect privacy and generate fairness, accountability, and transparency. OTI argued that in some instances, such measures can help ensure that biometric tools are used responsibly, though with more dangerous use cases and technologies, bans are likely warranted.