With the emergence of generative Artificial Intelligence (AI) tools (including large language models) in the popular discourse, the debate on managing, governing, and regulating the impacts of AI on society has grown considerably. In part due to the unique breadth of AI's impacts and its varying implications for the various strata of human workforce, and society, approaches to AI regulation appear to diverge significantly. This combination of scale and potential disruption has caught the attention of regulators worldwide, with China, European Union (EU), and the United States of America (USA) as the forerunners in the regulatory activity. The aim of this paper is to examine the current state-of-play vis-à-vis regulatory approaches to AI and related technologies in China, EU, and the USA. The paper draws on documentary sources and peer-reviewed literature to examine the political and market dynamics at work, the policy pathways, including the processes, the decision-making approaches, and the intended outcomes of these regulatory and legislative approaches. The findings suggest that China's state-directed approach is aimed at integration of technical oversight, social harmony, and the growth of its sovereign AI capabilities. The EU's approach is a comprehensive, risk-based regulatory framework for AI building on its strengths in exporting technology-related rule-making. The USA’s approach to AI regulation is decentralised with multi-agency legislation targeting specific AI applications and outcomes while retaining its advantages in AI innovation. The findings are expected to be of interest to academics, researchers, and key stakeholders from government, industry, and the third sector actively engaged in regulation and governance of AI.
