Checked 2026-09-09 · unchanged since 2026-08-21RSS

Export Controls

Export restrictions matched to the chips and facilities they reach, and to semiconductor trade before and after each action.

20 of 26 countries are classed as full or allied access; 4 as embargoed.

Scroll the matrix for all six chips and access-basis columns →

Country profiles.

Accelerators from the United States profile. Classifications reviewed July 17, 2026.

156

Chip–country cells: 67 available, 4 case-by-case, 15 restricted, 1 unclassified, 69 not listed.

Named-chip throughput comparison (square, ~ = estimate). The other entries are category codes: 19 destination-access at 1.00, 3 embargo at 0.00 (cross), 3 unstated.

Profile has moved between tiers (amber triangle).

Solid = available, half = case-by-case, struck = restricted, open dot = unclassified, small dot = not listed; each chip name carries how many profiles list it.

The profiles

26 of 26 profiles

Counts cover the chips enumerated in each profile.

Full Access · 6

Japan4000Destination category

The listed accelerators are recorded as available. Japan also controls exports of specified semiconductor-manufacturing equipment.

Per-chip status · 4

H100Available: —
H200Available: —
B200Available: —
MI300XAvailable: —

Regulatory notes

Japan added 23 semiconductor-manufacturing equipment items to its export controls on July 23, 2023.

Chip industry

Rapidus reported 2 nm gate-all-around transistor prototypes at IIM-1 in July 2025; its announcement targeted mass production for 2027. Renesas manufactures semiconductors in Japan, and Kioxia produces flash memory at Yokkaichi. Tokyo Electron supplies semiconductor-manufacturing equipment.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 JP. Sovereign AI programme record.

Netherlands3000Destination category

The listed accelerators are recorded as available. Dutch export controls also govern specified chipmaking equipment and related services.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Regulatory notes

The Netherlands expanded its national export-authorization requirement for specified DUV equipment on September 7, 2024. The preceding controls had taken effect on September 1, 2023.
The Dutch requirement applies to covered exports outside the EU and provides case-by-case review.
Dutch controls also cover servicing exports involving specified parts, software and technology for controlled equipment. Applications are assessed individually.

Chip industry

ASML develops EUV and DUV lithography systems, which chipmakers use to print circuit patterns on wafers. Its Veldhoven factories assemble both types of system. NXP manufactures semiconductors at Nijmegen and has automotive-electronics design teams in Delft.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 NL. Sovereign AI programme record.

South Korea4000Destination category

Samsung and SK hynix supply high-bandwidth memory for AI computing. The listed accelerators are recorded as available.

Per-chip status · 4

H100Available: —
H200Available: —
B200Available: —
MI300XAvailable: —

Chip industry

Samsung announced HBM4 mass production and commercial shipments in February 2026. Its HBM4 combines DRAM with a 4 nm logic base die. SK hynix reported that its HBM4 mass shipments began in Q2 2026.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 KR. Sovereign AI programme record.

Taiwan3000Destination category

Home to TSMC, the foundry that manufactures NVIDIA Blackwell GPUs. The listed accelerators are recorded as available.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Regulatory notes

Taiwan’s legislature passed its AI Basic Act on December 23, 2025.
Foreign-produced chips can be subject to the EAR; the applicable rules depend on the item, technology and transaction.

Chip industry

CSET’s October 2021 report put Taiwan’s share of leading-edge pure-play foundry manufacturing at ~92%. This is a historical country-level estimate.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 TW. Sovereign AI programme record.

United Kingdom5000Destination category

The listed accelerators are recorded as available. The UK launched its £500 million Sovereign AI programme in April 2026.

Per-chip status · 5

H100Available: —
H200Available: —
B200Available: —
MI300XAvailable: —
MI325XAvailable: —

Regulatory notes

The UK launched Sovereign AI on April 16, 2026, with £500 million to support domestic AI companies. Its support includes investment and access to computing resources.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

UK Sovereign AI launch and support, April 2026

ISO 3166-1 alpha-2 GB. Sovereign AI programme record.

United States6000Destination category

The United States is the domestic destination for the US export rules compared here.

Per-chip status · 6

A100Available: —
H100Available: —
H200Available: —
B200Available: —
MI300XAvailable: —
MI325XAvailable: —

Regulatory notes

The CHIPS and Science Act appropriated $52.7 billion for semiconductor manufacturing, research and related workforce programmes.

Chip industry

TSMC’s first Arizona fab entered N4 production in Q4 2024. Intel also manufactures in the US, and GlobalFoundries operates facilities in New York and Vermont.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 US. Sovereign AI programme record.

U.S.-Allied · 14

Australia3000Destination category

The listed accelerators are recorded as available. Recipient and end-use conditions still apply.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 AU. Sovereign AI programme record.

Brazil3000Destination category

The listed accelerators are recorded as available. Brazil’s AI plan includes public supercomputing infrastructure.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Regulatory notes

An August 2026 selection process seeks an integrated high-performance computing system for AI, with planned installation in Macaíba. The procurement notice does not establish delivered hardware.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

LNCC AI-supercomputer procurement, August 2026

ISO 3166-1 alpha-2 BR. Sovereign AI programme record.

Canada3000Destination category

Budget 2025 proposed C$925.6 million over five years, starting in 2025–26, for sovereign public AI infrastructure. The listed accelerators are recorded as available.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Regulatory notes

C$800 million of the Budget 2025 sovereign-compute proposal came from previously provisioned funds. The budget proposal does not establish expenditure completed.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

Budget 2025 sovereign public AI infrastructure proposal

ISO 3166-1 alpha-2 CA. Sovereign AI programme record.

France3000Destination category

The listed accelerators are recorded as available. Mistral AI announced a French cloud-infrastructure collaboration with NVIDIA in June 2025.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Regulatory notes

NVIDIA’s June 2025 announcement described a first phase of 18,000 Grace Blackwell systems for Mistral AI’s planned cloud platform.

Chip industry

STMicroelectronics manufactures chips at Crolles, alongside design and research activities.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 FR. Sovereign AI programme record.

Germany3000Destination category

The listed accelerators are recorded as available. ESMC’s Dresden fab adds a manufacturing project aimed at automotive and industrial chips.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Regulatory notes

The EU Chips Act applies in this EU member state.
EU AI Act obligations apply to in-scope providers of general-purpose AI models; the Commission’s guidance explains provider status and open-source exemptions.

Chip industry

Infineon has semiconductor production and development operations in Regensburg. ESMC, the TSMC–Bosch–Infineon–NXP joint venture, broke ground on its Dresden fab in August 2024.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 DE. Sovereign AI programme record.

India3000Destination category

The listed accelerators are recorded as available. Recipient and end-use restrictions still apply.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Chip industry

Tata Electronics is building a foundry in Dholera with planned processes from 28 nm to 110 nm, in partnership with Taiwan’s PSMC.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

Tata Electronics Dholera foundry plans

ISO 3166-1 alpha-2 IN. Sovereign AI programme record.

Indonesia3000Destination category

The listed accelerators are recorded as available. Microsoft opened its Indonesia Central cloud region in May 2025.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Regulatory notes

Microsoft’s May 2025 announcement reports an operational cloud region. It does not specify the accelerator allocation available to a particular customer.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

Indonesia Central cloud-region opening, May 2025

ISO 3166-1 alpha-2 ID. Sovereign AI programme record.

Israel3000Destination category

The listed accelerators are recorded as available. Israel hosts semiconductor manufacturing and chip-design operations.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Chip industry

Intel manufactures semiconductors in Kiryat Gat. Tower Semiconductor operates fabs in Migdal Haemek for technologies including sensors, power semiconductors and silicon photonics.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 IL. Sovereign AI programme record.

Italy3000Destination category

The listed accelerators are recorded as available. Recipient and end-use conditions still apply.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Chip industry

STMicroelectronics manufactures semiconductors at Agrate and Catania. Agrate also houses design and research for MEMS and smart-power technologies.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

STMicroelectronics Italian manufacturing sites

ISO 3166-1 alpha-2 IT. Sovereign AI programme record.

Malaysia3000Destination category

The listed accelerators are recorded as available. March 2026 reporting described a planned Malaysian Blackwell cluster for remote use by ByteDance.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Regulatory notes

March 2026 reporting described a planned 36,000-GPU Blackwell cluster operated by Aolani Cloud for remote use by ByteDance. The report does not establish operation of the full cluster or transaction-specific export authorization.

Chip industry

Intel operates assembly and test facilities in Penang and Kulim.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 MY. Sovereign AI programme record.

Norway3000Destination category

The listed accelerators are recorded as available. Norway’s digital strategy includes national AI infrastructure and Norwegian and Sámi language models.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Regulatory notes

On August 4, 2026, the Norwegian government announced a further consultation on its AI bill for autumn 2026. The minister aimed to submit the bill to Parliament in spring 2027.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 NO. Sovereign AI programme record.

Singapore3000Destination category

The listed accelerators are recorded as available. Singtel’s RE:AI offers a domestic AI-cloud initiative.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Regulatory notes

NVIDIA reported the launch of Singtel’s RE:AI in May 2025, with AI-cloud services intended for enterprises, government and researchers.

Chip industry

GlobalFoundries opened its Singapore fab expansion in September 2023.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 SG. Sovereign AI programme record.

Sweden3000Destination category

The listed accelerators are recorded as available. Recipient and end-use conditions still apply.

Per-chip status · 3

H100Available: —
H200Available: —
B200Available: —

Regulatory notes

The EU Chips Act applies in this EU member state.
EU AI Act obligations apply to in-scope providers of general-purpose AI models; the Commission’s guidance explains provider status and open-source exemptions.

Chip industry

Ericsson designs silicon for radio-access networks, including neural-network accelerators for AI inference in radios. This describes its products, without establishing wafer manufacture in Sweden.

Access basis1.00

This value encodes the destination-level access category.

This value encodes destination-level access for the listed accelerators. The recipient or end use can still trigger a license requirement.

ISO 3166-1 alpha-2 SE. Sovereign AI programme record.

United Arab Emirates4000Basis not classifiedRatio unstated

Country Group A:5 since July 10, 2026. Specified advanced-computing items may reach approved UAE recipients without a license; the ultimate consignee and every end user must qualify.

Per-chip status · 4

H100Available: The July 2026 rule permits specified advanced-computing items for approved recipients. The ultimate consignee and all end users must qualify; EAR part 744 controls still apply. Source
H200Available: The July 2026 rule permits specified advanced-computing items for approved recipients. The ultimate consignee and all end users must qualify; EAR part 744 controls still apply. Source
B200Available: The July 2026 rule permits specified advanced-computing items for approved recipients. The ultimate consignee and all end users must qualify; EAR part 744 controls still apply. Source
B300Available: The July 2026 rule permits specified advanced-computing items for approved recipients. The ultimate consignee and all end users must qualify; EAR part 744 controls still apply. Source

Regulatory notes

The July 2026 rule removed the UAE from Country Groups D:3 and D:4 and added it to A:5.
Supplement no. 8 to part 740 approves UAE government agencies, including the Ministry of Defense and Armed Forces. That government-agency approval excludes state-owned corporations, contractors and grantees.
The supplement separately lists G42, Core42, and eight US-headquartered AI companies and their subsidiaries: Amazon, Apple, Google, Meta, Microsoft, OpenAI, Oracle and X.AI.
The ultimate consignee and every end user must be approved recipients; EAR part 744 end-use and end-user controls still apply. G42 and Core42’s authorization expires April 6, 2027 absent subsequent BIS notice.
Before this rule, Commerce announced authorization on November 19, 2025 for G42 purchases equivalent to up to 35,000 GB300 chips, subject to security and reporting requirements.
Microsoft’s November 2025 account projected $15.2 billion in UAE investment and spending across 2023–2029, including its $1.5 billion G42 equity investment, datacenter capital costs and local operating costs. The total includes future spending.

Access basis

No ratio is stated because no source on record establishes the quantity.

The approved-recipient rules establish conditional access to advanced-computing items. They do not supply a quantitative discount for licensing friction. G42 and Core42’s authorization expires April 6, 2027 unless BIS gives subsequent notice.

UAE approved-recipient rule, July 2026

Tier movement on record

Restricted → U.S.-Allied, effective 2026-07-10: Enhanced Favorable Treatment for the United Arab Emirates Under the Export Administration Regulations — Country Group A:5 placement, license-free advanced computing to supplement-no.-8 approved entities (91 FR 43034).

ISO 3166-1 alpha-2 AE. Sovereign AI programme record.

Restricted · 1

Saudi Arabia0301Basis not classifiedRatio unstated

Advanced-chip access depends on export authorization. In November 2025, Commerce approved HUMAIN purchases equivalent to up to 35,000 GB300 chips, subject to security and reporting requirements.

Per-chip status · 4

H100Case-by-case review: Export authorization depends on the recipient and transaction; cloud access does not establish permission to procure the hardware.
H200Case-by-case review: —
B200Unclassified: The cited HUMAIN approval specifies GB300-equivalent purchases. It does not establish a separate B200 classification or authorization. Source
B300Case-by-case review: Commerce announced approval for HUMAIN purchases equivalent to up to 35,000 GB300 chips on November 19, 2025, subject to security and reporting requirements. This is a recipient-specific authorization. Source

Regulatory notes

Commerce announced the HUMAIN authorization on November 19, 2025; the approval is conditional on security and reporting requirements, with ongoing BIS monitoring.
NVIDIA’s May 2025 announcement described a planned first phase of 18,000 GB300 chips. That announcement did not report delivery or operation.

Access basis

No ratio is stated because no source on record establishes the quantity.

The cited authorization establishes a conditional procurement route for HUMAIN. It provides no calibrated measure of licensing friction or Saudi access to frontier compute.

Commerce authorization for HUMAIN, November 2025

ISO 3166-1 alpha-2 SA. Sovereign AI programme record.

Heavily Restricted · 1

China02125Named-chip comparison

Advanced-chip exports face extensive restrictions. The January 2026 rule provides conditional case-by-case review for qualifying US exports, including H200 and MI325X. Chinese-designed alternatives require their own legal assessment.

Per-chip status · 19

A100Restricted: Oct 2022 rule (87 FR 62186)
A800Restricted: Oct 2023 rule (88 FR 73458) — TPP metric closed interconnect loophole
H100Restricted: Oct 2022 rule (87 FR 62186)
H800 SXM5Restricted: October 2023 rule (88 FR 73458): revised TPP and performance-density criteria under ECCN 3A090. Source
H800 PCIeRestricted: October 2023 rule (88 FR 73458): revised TPP and performance-density criteria under ECCN 3A090. Source
H200Case-by-case review: January 2026 rule: case-by-case review for qualifying US exports to China or Macau. Conditions include a cap on aggregate TPP exported to China/Macau: at most 50% of TPP shipped to US customers for US end-use for the same commodities, from first commercial US shipment through application. Supply, end-use, security and independent US testing requirements also apply. Source
B200Restricted: Exceeds TPP threshold (21,000) and DRAM bandwidth threshold (6,500 GB/s). No case-by-case pathway for Blackwell-class.
B300Restricted: Exceeds all BIS advanced computing thresholds (ECCN 3A090/4A090)
NVIDIA Rubin GPURestricted: Preliminary NVIDIA individual-GPU specifications yield TPP 140,000 (17,500 dense FP8 TFLOPS × 8 bits, tied by 35,000 dense FP4 TFLOPS × 4 bits), above the 4,800 3A090.a parameter.
B30AUnclassified: Designed to fall below BIS Performance Density thresholds. No formal BIS ruling as of Q3 2025. Jensen Huang (Aug 2025): "That's not our decision to make. It's up to the United States government."
MI300XRestricted: Exceeds compute and memory bandwidth thresholds
MI325XCase-by-case review: January 2026 rule: case-by-case review for qualifying US exports to China or Macau. Subject to the same aggregate-TPP cap and additional application requirements as H200; see the cited rule. Source
MI350XRestricted: Memory bandwidth (8,000 GB/s) exceeds DRAM bandwidth threshold (6,500 GB/s). Performance metrics exceed TPP threshold.
MI355XRestricted: Exceeds BIS advanced computing thresholds
MI400Restricted: Exceeds all BIS thresholds by wide margin
Ascend 910BUnclassified: Named in BIS’s May 2025 guidance on chips presumptively subject to General Prohibition 10. Chinese design does not establish an exemption from the EAR. Source
Ascend 910CUnclassified: Named in BIS’s May 2025 guidance on chips presumptively subject to General Prohibition 10. Chinese design does not establish an exemption from the EAR. Source
Ascend 910DUnclassified: Named in BIS’s May 2025 guidance on chips presumptively subject to General Prohibition 10. Chinese design does not establish an exemption from the EAR. Source
Ascend 920Unclassified: Chinese-designed accelerator. The cited reporting does not establish whether particular items or transactions are subject to the EAR.

Access routes and alternatives

Domestic production

Huawei’s Ascend 910C provides a Chinese-designed accelerator alternative.

Example: SemiAnalysis estimated CloudMatrix 384 at 300 PFLOPS of dense BF16 in April 2025: about 1.7 times GB200 NVL72 throughput at 4.1 times all-in system power, including networking and storage. These are analyst estimates of system specifications.

SemiAnalysis, April 16, 2025

Cloud routing

March 2026 reporting described plans for ByteDance to access 36,000 Blackwell GPUs through Aolani Cloud in Malaysia.

Example: The report concerns planned remote access to overseas hardware. It does not establish that the full cluster was operational or that this transaction had US export authorization.

Tom’s Hardware, March 13, 2026, citing the Wall Street Journal

Compliant variant

TrendForce reported a proposed China-focused B30A Blackwell variant in August 2025.

Example: Its report described possible September 2025 test samples. This announcement does not establish later product availability or BIS approval.

TrendForce, August 19, 2025

Stockpile

The sources recorded in this profile do not establish the size or composition of pre-control accelerator stockpiles.

Regulatory notes

The January 2026 pathway applies to qualifying US exports to China or Macau below 21,000 TPP and 6,500 GB/s total DRAM bandwidth. H200 and MI325X are examples, not an exhaustive eligibility list.
The rule caps aggregate TPP exported to China and Macau against 50% of TPP shipped to US customers for US end-use for the same commodities, from first commercial US shipment through application. Supply, end-use, security and testing conditions also apply.
BIS’s May 2025 GP10 guidance treats Ascend 910B, 910C and 910D as presumptively subject to the EAR and implicated in unauthorized transactions. Its knowledge and authorization conditions matter; Chinese design is not an exemption.

Chip industry

Huawei designs the Ascend family. SemiAnalysis’s April 2025 review of Ascend 910C described continued reliance on foreign memory and fabrication; domestic design alone does not establish a domestic supply chain.

Access basis~0.35

This value compares the named chips’ peak throughput.

A dated comparison of dense BF16 peak throughput: SemiAnalysis reported 780 TFLOPS per Ascend 910C chip/package in April 2025; NVIDIA lists 2,250 TFLOPS for B200 without sparsity. The quotient, 780 ÷ 2,250, rounds to 0.35. Country-level compute availability is not quantified by this chip comparison.

Ascend 910C: 780 dense BF16 TFLOPS, April 2025

B200: 2,250 non-sparse BF16 TFLOPS

ISO 3166-1 alpha-2 CN. Sovereign AI programme record.

Embargoed · 4

Belarus0020Embargo category

Exports of EAR-controlled items on the Commerce Control List generally face a policy of denial. The rules retain specified case-by-case review pathways and narrow license exceptions.

Per-chip status · 2

H100Restricted: Embargoed
B200Restricted: Embargoed

Access routes and alternatives

Third-party

This profile records no verified AI-accelerator transfer through Russian or Chinese intermediaries.

Regulatory notes

EAR 746.8 requires licenses for items subject to the EAR and listed on the Commerce Control List. Paragraph (b) provides the review policy, including specified case-by-case purposes and recipients; paragraph (c) lists narrow exceptions.

Access basis0.00

This value encodes the embargoed category; it does not measure installed compute.

The value encodes the embargoed access category. The sources recorded here do not quantify installed AI compute or capacity obtained through intermediaries.

Russia and Belarus sanctions, EAR 746.8

Russia and Belarus licensing requirements and review policies

ISO 3166-1 alpha-2 BY.

Iran0020Basis not classifiedRatio unstated

A comprehensive US trade and investment embargo applies. Advanced-chip transactions require assessment under the EAR and OFAC’s Iranian Transactions Regulations.

Per-chip status · 2

H100Restricted: Embargoed
B200Restricted: Embargoed

Access routes and alternatives

Third-party

An electronics-diversion allegation: a January 2024 indictment alleged that four defendants routed US components through China and Hong Kong to Iranian military-affiliated entities.

Example: The alleged conduct extended from 2007 through at least July 2020. The announcement concerns military-use electronics and does not establish procurement of AI accelerators.

US Department of Justice, January 31, 2024

Third-party

This profile records no verified Iranian procurement of Huawei Ascend accelerators.

Regulatory notes

EAR 746.7 generally denies licenses outside specified humanitarian and civil-aviation purposes. OFAC authorization can also satisfy the EAR authorization requirement for transactions covered by both regimes.

Access basis

No ratio is stated because no source on record establishes the quantity.

The sources recorded here do not quantify Iran’s access to AI compute. Reported intermediary routes and possible Chinese hardware procurement do not establish a comparable ratio.

Iran controls and OFAC authorization, EAR 746.7

ISO 3166-1 alpha-2 IR.

North Korea0020Embargo category

Broad US export restrictions apply. License applications for specified high-performance computing items generally face denial under EAR 742.19.

Per-chip status · 2

H100Restricted: Embargoed
B200Restricted: Embargoed

Regulatory notes

EAR 746.4 requires a license for exports and reexports of items subject to the EAR, with specified exclusions and narrow exceptions. For Commerce Control List items, it points to the review policies in EAR 742.19.

Access basis0.00

This value encodes the embargoed category; it does not measure installed compute.

The value encodes the embargoed access category. No inventory or calculation in this profile establishes the amount of AI compute in use.

ISO 3166-1 alpha-2 KP.

Russia0050Embargo category

Exports of EAR-controlled items on the Commerce Control List generally face a policy of denial. The rules retain specified case-by-case review pathways and narrow license exceptions.

Per-chip status · 5

A100Restricted: Embargoed
H100Restricted: Embargoed
H200Restricted: Embargoed
B200Restricted: Embargoed
MI300XRestricted: Embargoed

Access routes and alternatives

Third-party

An electronics-diversion precedent: Nikolay Goltsev was sentenced in January 2025 for a scheme that routed US components to Russia through intermediary companies, including in Turkey and the UAE.

Example: DOJ identified components used in Russian weapons. This case does not establish advanced-AI-GPU procurement or quantify compute capacity.

US Department of Justice, January 8, 2025

Regulatory notes

EAR 746.8 requires licenses for items subject to the EAR and listed on the Commerce Control List. Paragraph (b) provides the review policy, including specified case-by-case purposes and recipients; paragraph (c) lists narrow exceptions.

Chip industry

Baikal Electronics describes itself as a Russian fabless developer of processors and microcontrollers. Fabless design does not establish domestic wafer fabrication.

Access basis0.00

This value encodes the embargoed category; it does not measure installed compute.

The value encodes the embargoed access category. The sources recorded here do not quantify installed AI compute or capacity obtained through intermediaries.

Russia and Belarus sanctions, EAR 746.8

ISO 3166-1 alpha-2 RU.

20 of 26 countries are classed as full or allied access; 4 as embargoed.

The access lattice

The profiles

20 of 26 countries are classed as full or allied access; 4 as embargoed.

The access lattice

The profiles