A further relationship is corroborated only against subscription-held corporate records, which confirm it and cannot be cited as its source; the count above leaves it out. A framework for auditing diversion-thesis claims at the primary-source-disclosure layer (the Culper Research 2026-05-13 NVIDIA short thesis as the worked example). The magnitude studio recomputes peak and effective ExaFLOPS live as trade-volume, chip-mix, MFU, and ASP move; a Tier-1-only counterfactual toggle strips the Tier-3 input and shows what the framework establishes without it. Scrutica builds the cascade chain from corporate filings, flags where the trade-record claims diverge from disclosed corporate topology, and cross-references Chinese-hyperscaler peering at SE-Asian facilities via PeeringDB. Every claim shows the authority tier of its source.
Diversion-rate inference is structurally bounded above by absent CY2023+ BIS license data. The CY2017 - CY2022 license-action substrate documents what was licensed (denied + RWA + approved + ECCN top-10) for the pre-Oct-2023-rule window; the post-rule window — exactly the period the Culper-NVDA worked example operates over — has no BIS license-action substrate to corroborate against. The framework substitutes bilateral-trade-flow measurement of HS 854231/8542 advanced-chip-class proxies and corporate-disclosure topology, and labels every inference accordingly.
CY2017 - CY2022
2,587 rows × 33 jurisdictions · BIS OTE Annual Country Licensing & Trade Analysis
bis.gov · OTE ↗No public timetable
CY2023 ≈30 months overdue vs the CY2022→early-2023 (~2-4 mo) historical cadence. No suppression / delay announcement issued.
CRS R48642 (Sep 2025) ↗Past due 2026-08-19
Export Control Transparency Act of August 2025 (H.R. 1316, 119th Cong.) mandates a separate, narrower per-entity license-action report — Entity-List / MEU-List scope only — to Congress no later than one year from enactment. The statutory date has passed and no such report is in this platform’s substrate; whether one has been delivered to Congress is not something Scrutica measures.
H.R. 1316 ↗Comtrade · BACI · Customs
UN Comtrade + CEPII BACI (231 reporters) + Taiwan Customs + China GACC + Japan e-Stat. HS 8542 advanced-chip-class proxies through 2026. Measures what shipped under customs declarations — NOT what BIS licensed.
See what we can / cannot answer about the post-CY2022 window for the per-question crosswalk. Substrate refresh will land on the BIS publication, not on inference; the platform’s “Verify, never hedge” data-quality principle holds — analyst commentary is not a substitute for the government measurement.
Every relationship the worked example alleges, drawn once. A connector's ink is what stands behind the claim: a primary-source filing, or a single Tier-3 citation. Hover any connector for its relationship kind, its corroboration state, and the strongest authority tier in its evidence chain.
Worked example The chain alleged in the Culper Research 2026-05-13 report. Each connector is a claimed relationship; its ink grades the evidence behind the claim.
Alleged relationships a primary-source filing corroborates, on 7 Tier-1 records from corporate registries and a DoJ indictment
Carry no filing a reader can open: a single Tier-3 citation, or corroboration held only under subscription. Drawn in amber, and the reason the control above leaves 3 connectors standing
Distinct relationship kinds across the 11 connectors — ownership, rename, financing, trade flow, lease, and director clustering among them
Evidence records behind the figure, each with its own source, authority tier and vintage; every connector names the strongest tier it holds
Each edge has one of these states. 4 of 11 edges are corroborated by a record independent of the report; the definitions are the method, so the same grading runs on the next thesis without reading this page’s conclusions.
If Culper's $4.74B trade-flow figure holds and the assumed chip mix is broadly correct, the alleged channel represents ~160K GPUs / 166 ExaFLOPS peak BF16 dense / 67 ExaFLOPS effective at 40% MFU — approximately 1.58× China's MIIT 2025 intelligent-computing target (105 EFLOPS; six-agency Computing Power Infrastructure Action Plan, October 2023), sufficient to train ~98 GPT-4-class models annually on aggregate effective compute, and accounting for 4.1% of Nvidia's FY2025 Data Center revenue.
How to read this number. Per-card FLOPS data is Tier 1 (Nvidia spec sheets). Chip-mix and MFU are Tier 2 derived metrics. The trade-volume input is Tier 3 (Culper Research 2026-05-13 citing Tradesparq) and is unverified at the primary-source layer. Use the controls below to test how the magnitude moves with each assumption, or toggle the counterfactual Tier-1-only mode to see what the framework reports when the Tier-3 input is stripped.
Cards / FLOPS by SKU at current scenario
| SKU | Mix | ASP $K | PFLOPS / card | Cards |
|---|---|---|---|---|
| H200 SXM5 | 50% | 30.0 | 0.990 | 79,033 |
| H100 SXM5 | 30% | 30.0 | 0.990 | 47,420 |
| H800 SXM5 | 15% | 25.0 | 0.990 | 28,452 |
| B300 Blackwell Ultra | 5% | 45.0 | 2.500 | 5,269 |
| Total | 100% | — | 166.5 EFLOPS | 160,174 |
| At 40% MFU → 66.6 EFLOPS effective | ||||
Caveats
Each edge is one corporate-filing or trade-record relationship in the alleged Culper-NVDA chain. Edge color encodes primary-source corroboration (green), single-sourced via Tier-3 analyst citation (amber dashed), or absent from the licensed supply-chain disclosure topology (stone dotted). Toggle “fade Tier-3 edges” to keep only the links a corporate filing or trade record directly supports.
The cascade graph rendered as a cross-tab. Each of the 11 alleged edges appears in exactly one matrix cell (corroboration status × tier) and one relationship-kind row — showing which channels a primary source supports and which rest only on a Tier-3 analyst citation (Tradesparq, WSJ, or Culper).
Status × cascade tier
| Corroboration status | OEM | Intermediary | End-customer | Total |
|---|---|---|---|---|
| Primary-source corroborated | 1 | 2 | · | 3 |
| Subscription-source corroborated | 1 | · | · | 1 |
| Tradesparq via Culper | · | 4 | · | 4 |
| WSJ via Culper | · | · | 2 | 2 |
| Culper narrative only | · | · | 1 | 1 |
| Total per tier | 2 | 6 | 3 | 11 |
Relationship-kind breakdown · ordered by primary-source share
1 primary-source corroborated
1 primary-source corroborated
1 primary-source corroborated
3 tradesparq via culper
2 wsj via culper
1 subscription-source corroborated
1 culper narrative only
1 tradesparq via culper
Each edge appears in exactly one row and one column. The asymmetry the matrix exposes, counted from the same payload as every figure above: the financing via pledged charge, corporate rename and shared-director clustering edges rest on 7 filings a reader can open; the wholly-owned subsidiary edge is corroborated only against subscription corporate-data sources, which confirm it and cannot be cited for it; the remaining 7 reach the framework on a Tier-3 citation and nothing else. Every edge names its own records in the cascade graph below.
The records behind that count · Tier 1
If BIS designates Aivres alongside Inspur Group; if the corridor behind the March 2026 DoJ indictment is severed (per the DoJ release, a front company purchased ~$2.5B of AI servers from the manufacturer, unnamed in the release, and at least ~$510M worth was diverted to China; Sen. Warren’s letter ties the case to a Supermicro co-founder); if a Beijing- or Washington-side action cuts the post-restriction Asian-routed Nvidia flow — what propagates downstream through Scrutica’s licensed supply-chain graph? Four scenarios, each with a severity, decay rate, direction, and the countries and firms hit hardest; a companion probe adds the 14 additional edges Culper alleges, so the effect of the weaker evidence is visible on its own. The supply-chain graph is built from a licensed supply-chain database held under subscription and not redistributed.
The DoJ-indicted corridor as proxy. Severity 100% at the Supermicro OEM node, downstream-only propagation with 0.85 per-hop decay. The narrowest enforcement footprint of the four scenarios.
Weighted impact by supply-chain tier
Top affected nodes by tier · per-node impact = severity × decay^depth
L0 Materials/Foundry
L3 Systems/OEM
L4 Cloud/End-User
+4 more on record
Tier-3-aware probes · cannot be modeled on the canonical graph alone
The Aivres → Speedmatrix → Megaspeed → Novagate → Aolani chain rides on 14 additional edges that exist only at Culper Research’s analyst synthesis. Their reach into Alibaba, ByteDance, IFLYTEK, PT Indosat, and Opera appears here at the Tier-3 layer, and is absent from the canonical-graph scenarios above by construction.
TIER-3-AWARE: Aivres channel shutoff (Aivres + alleged downstream)
BIS enforcement extends across the full Culper-alleged Aivres + Speedmatrix + Megaspeed + Novagate + Aolani chain. It cannot be modeled on the canonical graph alone: depth-4 reach into Alibaba, IFLYTEK, PT Indosat, Opera requires the Tier-3 edges.
NARROW: Aivres alone shutoff (the cleanest Culper-thesis test)
The cleanest Culper-thesis test: BIS extends to Aivres only. Depth-2 reach via Speedmatrix and Aolani; ByteDance and Alibaba appear at depth 2 only because Tier-3 edges connect them.
Weighted impact = per-node severity × decay^depth, normalized by graph-level node weighting. Propagation uses the existing Scrutica cascade-simulation engine against the licensed supply-chain graph. The single load-bearing Tier-3 input is the set of 14 additional Culper-alleged edges; with the toggle off, no Tier-3 edge enters the model.
Where public primary-source disclosure (SEC, A-share + HK + Bizfile / SSM) and the licensed corporate-disclosure substrate read against the Tier-3 narrative for the same entity; the Tier-1 measurement sits next to the Tier-3 interpretation, and both can be true at once. 2 of 8 substrate rows render: where a tension rests entirely on subscription sources, the card states that it was corroborated and withholds the record, and where no such statement has been written the row does not render at all.
Geographic-revenue methodology change within the disclosure window
Nvidia stated change reflects 'better representation of the geographic profile of our revenue' — companies' HQ location now overrides Singapore-based billing
Nvidia Q3 FY2026 10-Q (October 2025) — methodology change disclosure· 2025-10
Corroborated against subscription corporate-data sources that cannot be republished (1 record, values withheld). How the licensed layer is held
Per Culper, the methodology change makes pre-2025 vs. post-2025 geographic-revenue compositions directly non-comparable; absent the disclosure shift, Singapore would likely still surface as a material exposure even with operational changes.
Revenue growth counter-cycle to export restrictions
USD 2.5B alleged smuggling via 'Company-1' (Bloomberg-identified as OBON Corp)
DoJ SDNY indictment of Wally Liaw (March 2026)· 2026-03
Corroborated against subscription corporate-data sources that cannot be republished (1 record, values withheld). How the licensed layer is held
Per Culper, revenue growth during a tightening window is itself a signal worth scrutinizing; the DoJ indictment quantifies one corridor at $2.5B but Culper's narrative interpretation is that this 'is the tip of the iceberg' with multiple parallel OEM/intermediary channels.
Public IX peering tables disclose which networks are present at which SE-Asian facilities. A direct peering between a Culper-named facility and a Chinese-hyperscaler AS-number is evidence of network-level proximity, independent of any Tier-3 analyst interpretation. The True IDC East Bangna ↔ Huawei Cloud (AS136907) finding leads; four representative adjacent disclosures and the calibrated nulls follow.
True IDC (Charoen Pokphand Group / True Corporation subsidiary)·IX: SYMPHONY THAI - IX BANGKOK - 1
Culper relevance. True IDC signed MOU with Siam AI per Culper p.38 (Dec 2024) — 'establish Thailand as the Regional AI data center hub'. Direct Culper-named entity.
AS136907Chinese hyperscaler / state-telecom AS-numbers disclosed at PeeringDB-listed facilities across the Malaysian, Thai, Indonesian, Vietnamese, and Singaporean data-center cluster. Not directly Culper-named but in the same diversion-corridor metropolitan areas.
| Facility | Operator | Disclosed Chinese peers |
|---|---|---|
| STT Bangkok 1 | ST Telemedia (Singapore-Thai joint venture) | Alibaba (Aliyun)AS45102Huawei Cloud GlobalAS136907 |
| NTT Cyberjaya Data Center (CBJ) | NTT Global | Alibaba (Aliyun)AS45102 |
| DCI Indonesia (JK5) | DCI Indonesia (Salim Group) | Huawei Cloud GlobalAS136907ByteDance / TikTokAS396986 |
| China Mobile International - Singapore DC | — | China Mobile InternationalAS58453China Mobile International - NIIAS58807 |
YTL Green Data Center / YTL AI Cloud / YTL Communications · Equinix JH1 - Johor · Singapore Equinix SG1-SG5 cluster.
PeeringDB visibility partitions Asian data centers into two structurally different topologies: (a) MID-TIER facilities (NTT, BDx, DCI, STT, TM ONE, True IDC East Bangna) where Chinese hyperscaler peering is openly disclosed via public IX — these are 'Chinese tech is here' facilities; (b) HYPERSCALE facilities (YTL Green, Bridge DC, Singapore Equinix flagships) where tenant relationships are private cross-connect, invisible to public peering tables. The single direct Culper-corroborating finding is True IDC East Bangna ↔ Huawei Cloud — a facility-participation record Huawei Cloud Global publishes itself, which strengthens Culper's CP Group / True IDC / Chinese-tech-tenancy thesis with non-narrative-dependent evidence. 105 SE-Asian facilities scanned; 13 with Chinese-hyperscaler peering. Source: PeeringDB, analyzed 2026-05-14.
7 milestones from the 2023 BIS designation of Inspur Group through the 2026-06-01 Warren letter to Nvidia's General Counsel and Audit Committee Chair. Each clicks through to its primary source. A further 2 Tier-3 milestones (NYT shipment, Tradesparq window) are held back from this page; what appears here is an editorial selection, marked per milestone on the record.
U.S. Department of Commerce, Bureau of Industry and Security designates Inspur Group Co., Ltd. on the Entity List “for acquiring and attempting to acquire U.S.-origin items in support of China’s military modernization efforts.” Designation is the upstream regulatory anchor for every subsequent disclosure-anomaly card.
California Secretary of State business filing records the corporate name change from Inspur Systems Inc. to Aivres Systems Inc. — approximately two months after the BIS designation of parent Inspur Group. The rebrand raised the uplift question the Tracker’s cascade graph renders — whether designation reaches a US operating entity through an intermediate that carries none of its own. BIS answered it by enumeration rather than by uplift: it designated that intermediate, Inspur Electronic Information Industry Co., Ltd. (Inspur Information / IEIT Systems), separately on 25 March 2025. See the milestone below.
BIS adds six Inspur Group subsidiaries: Inspur (Beijing) Electronic Information Industry Co., Ltd.; Inspur Electronic Information Industry Co., Ltd.; Inspur Electronic Information (Hong Kong) Co., Ltd.; Inspur (HK) Electronics Co., Ltd.; and Inspur Software Co., Ltd. under China, plus Inspur Taiwan — all for all items subject to the EAR, under a policy of denial, with a Footnote 4 designation. The second of those is the Shenzhen-listed issuer 000977-CN that owns the US OEM Aivres Systems Inc.; the Federal Register records “Inspur Information” and “IEIT Systems Co. Ltd.” among its aliases, which is what ties the entry to the entity the cascade graph draws. This is the answer to the uplift question the May 2023 rebrand milestone raises: designation reached the intermediate directly, two years after the parent, rather than extending to it.
Nvidia’s Q3 FY2026 10-Q discloses a shift in geographic-revenue methodology: from billing-location-of-customer to customer-headquarters-location — because “the end customer and shipping location may be different from customer’s billing location.” Singapore’s share of disclosed revenue collapses; United States share rises to ~70%. Cross-source disclosure-anomaly card “da-nvidia-georev-methodology-shift” anchors to this filing.
The U.S. Department of Justice unseals an indictment of Yih-Shyan (“Wally”) Liaw, Ruei-Tsang (“Steven”) Chang, and Ting-Wei (“Willy”) Sun for allegedly conspiring to divert high-performance AI servers, assembled in the United States, to China in violation of U.S. export-control law. Per the DoJ release: a front company purchased approximately $2.5B of servers from the U.S. manufacturer (unnamed in the release) across 2024–2025, and at least approximately $510M worth was diverted to China between late April and mid-May 2025 alone, using false documents, staged dummy servers, and transshipment. Senator Warren’s June 1, 2026 letter to Nvidia characterizes the case as involving a Supermicro co-founder and “$510 million in diverted servers.” The indictment provides primary-source corroboration of the structural pattern — OEM→intermediary→end-customer — the Tracker’s cascade graph encodes.
Culper Research publishes its NVDA short thesis, synthesizing the Inspur / Aivres / Speedmatrix structural topology, the Tradesparq trade-volume aggregations, the Nvidia disclosure-methodology shift, and the BIS designation chain. The Tracker’s render of this publication is the worked example — not endorsement of every claim, and not a stand-in for the underlying primary sources.
Senator Elizabeth Warren (Ranking Member, Senate Banking Committee) writes to Nvidia General Counsel Tim Teter and Audit Committee Chair Brooke Seawell — not to CEO Jensen Huang — requesting information about Nvidia’s compliance with U.S. export control laws and the accuracy of its public statements about chip diversion. The letter cites three DOJ enforcement actions: the Nov 20, 2025 arrests for exporting AI technology to China via Malaysia and Thailand (“millions of dollars in GPUs”); the Dec 8, 2025 shutdown of a China-linked AI tech smuggling network (“$160 million in H100 and H200 chips”); and the Mar 19, 2026 indictment (“$510 million in diverted servers”). It quotes CEO Jensen Huang’s public statements that “[t]here’s no evidence of any AI chip diversion” and that Nvidia chip market share in China has “dropped to zero,” and puts four numbered questions to the Audit Committee, response deadline June 18, 2026.
2 of the 4 levers the framework identified, each naming the statutory authority under which reform could proceed and the structural-engineering gap the lever would close; the other 2 were assessed as derivative of these and are held on record with that reason. The selection is editorial and no ranking metric was applied. Every factual premise has its own source and authority tier, and 3 of them have no tier, because nobody on this project has opened the instrument they cite. This is descriptive: not a prediction of legislative likelihood, and not advocacy.
Designation reached this ownership chain entity by entity, not by uplift. Inspur Group was added to the Entity List effective 2 March 2023 (88 FR 13673); its A-share-listed subsidiary Inspur Electronic Information Industry Co., Ltd. — recorded there under the aliases Inspur Information and IEIT Systems Co. Ltd., and the owner of the US OEM Aivres Systems Inc. — was added separately, effective 25 March 2025 (90 FR 14046). For the two years between the two additions, the US operating entity sat below an intermediate carrying no designation of its own.
What that rests on · 5 premises
Inspur Group Co., Ltd. (a.k.a. Inspur Group; IGL) was added to the Entity List effective 2 March 2023, presumption of denial, Footnote 4.
Federal Register, "Additions and Revisions of Entities to the Entity List", 88 FR 13673 (2023-03-06), document 2023-04558 ↗ · retrieved 2026-08-14
Inspur Electronic Information Industry Co., Ltd. — recorded with the aliases Inspur Information and IEIT Systems Co. Ltd. — was added to the Entity List effective 25 March 2025, policy of denial for all items subject to the EAR, Footnote 4, as a subsidiary of Inspur Group.
Federal Register, "Additions to the Entity List", 90 FR 14046 (2025-03-28), document 2025-05427 ↗ · retrieved 2026-08-14
The US OEM in this chain is Aivres Systems Inc. The California register returns exactly one Aivres entity — AIVRES SYSTEMS INC., entity 3815827, Stock Corporation - CA - General, initial filing 2015-08-11, active. No Aivres LLC is registered.
California Secretary of State business search (bizfileonline.sos.ca.gov) ↗ · retrieved 2026-08-14
Inspur Electronic Information Industry Co., Ltd. owns Aivres Systems Inc.
Licensed corporate-ownership record, corroborated; the corresponding cascade edge is filed licensed-corroborated for this reason · retrieved 2026-05-14
The one premise on this card that no public filing in this substrate carries. It is corroborated and it is not citable; both halves render.
For the two years between the two additions, the US operating entity sat below an intermediate carrying no designation of its own.
Scrutica, from the two Federal Register notices above
Reform direction
Proposal, not a findingAmend the 50% rule so that designation of any entity in an ownership chain uplifts to every entity that ultimately controls, or is ultimately controlled by, the designated party — regardless of jurisdiction of intermediate holding entities. The Inspur Group / Inspur Information / Aivres Systems chain is the worked case: designation reached the US entity only when BIS added the intermediate separately, two years after the parent.
SEA beneficial-ownership disclosure exists on paper (Singapore Companies Act §386AF; Malaysian Companies Act 2016 §60A; Indonesian Presidential Regulation 13/2018) but is not API-accessible to allied export-control authorities. End-customer identity verification requires bilateral mutual-legal-assistance requests that move at jurisdictional-court timescale.
What that rests on · 2 premises
Singapore, Malaysia and Indonesia each impose a beneficial-ownership / registrable-controller disclosure obligation by statute.
Singapore Companies Act §386AF; Malaysian Companies Act 2016 §60A; Indonesian Presidential Regulation 13/2018
No instrument was opened — an attempt to retrieve the Singapore statute on 2026-08-14 returned HTTP 403 — so the citation stands unverified rather than being asserted at Tier 1.
None of those registers is API-accessible to allied export-control authorities; end-customer identity verification runs through bilateral mutual-legal-assistance requests at jurisdictional-court timescale.
Scrutica assessment
An assessment of an ABSENCE — that no such access channel exists. No source establishes it and none is claimed; it is the premise a reader should press hardest on this card.
Reform direction
Proposal, not a findingBilateral agreements with SG / MY / ID / TH / VN to provide allied export-control authorities API-level access to registered beneficial-ownership data — analogous to FATCA-style information sharing but for dual-use technology end-use verification. Closes the verification-latency gap the Culper thesis turns on.