Export Controls

Corrected Mar 30, 2026 Changes RSSFresh2d

What is restricted, to whom, and by which rule — and whether the controls worked. Chip-level access constraints across the US, Dutch/EU, and Japanese regimes; the BIS Entity List cross-referenced to compute infrastructure; the pre-scored reach of a hypothetical designation; the trade-flow response; and where evasion routes.

Data vintageDesignations track the Federal Register continuously; the BIS license-action series ends at CY2022 (CY2023+ unreleased). The next statutory data drop — the Export Control Transparency Act per-entity report (H.R. 1316) — is due 2026-08-19. What that gap means.

Regulatory Impact Pre-Scorer

Walks the affiliate closure of a hypothetical designation target downward through the documented ownership graph (max 4 hops, mirroring the cascade rule used to backfill historical BIS designations), joins to facilities by operator/owner org, and enriches every closure entry with current BIS / SDN / EU Sanctions designation status, the entity's HQ jurisdiction posture, and any sovereign-LP linkage. Each hop carries chain-of-control provenance, so the cascade is auditable to the source record. Inverse simulation models the structural reach lost if a current designation were removed. The output is a structural-reach estimate; legal determinations under 15 CFR Part 744 turn on rules the Pre-Scorer does not encode.

Cross-viewPick an entity or chip on any view to carry the selection across — designate an entity, then trace which chips, facilities, corridors, and diversion exposure it reaches.Open in Overview →Open in Trade →Open in Diversion →

Hypothetical designation target

Pre-scorer simulates new designations. Already-designated entities are flagged below; click to switch to inverse-simulation mode.

TryNvidiafabless designer · global affiliate network TSMCfoundry · Taiwan + Arizona + Kumamoto fabs SamsungKorean conglomerate · memory + foundry Huaweialready on Entity List · partial cascade visible

Inverse simulation (start from a current designation):BIS cross-reference →

Multi-removal scenarios (comma-separated ?designation=)

Worked exampleA default run on the current Huawei Entity List cascade — Huawei is already designated, so the report below shows the cascade that its listing already reaches. Search any entity above to run your own.

Methodologyclosure walk · facility match · enrichment · coverage limits

1. Closure walk

Breadth-first walk down the documented ownership graph in the subsidiary / JV / affiliate direction (parent and acquired-by edges are inverted to a parent→child orientation). Max depth 4 hops, matching the offline cascade rule used to backfill historical BIS designations. Each hop carries its source and confidence; a closure entry inherits the lowest confidence along its path.

2. Facility match

For each closure entry, facilities are matched where the operator or owner organization resolves to that entry through the canonical-org map. Direct seed-entity matches are reported as hop 0. Operator and owner are queried independently so a facility leased under a different operator from its beneficial owner matches through either path; deduplication is on facility id.

3. Cross-cutting enrichment

Each affected facility is enriched with: (a) current BIS-match status from the cross-reference index, (b) the Allied Coordination Gap classification (NONE / MILD / STRONG / OPAQUE), (c) any sovereign-LP linkage tracing back through fund managers. Each closure entry separately carries: BIS / SDN / EU Sanctions designation status, the entity's HQ jurisdiction posture (allied-coordinated / allied-partial / non-aligned / restricted) from the regimes table, and the sovereign LPs documented as committing to that entity in the licensed fund/LP database's fund-LP chains.

Pre-Scorer · simulated designation

Hypothetical designation of Huawei Technologies would cascade through 3 affiliate entities to affect 5 Scrutica-tracked facilities across 2 countries.

Computed 7/20/2026, 2:56:30 PM · closure depth ≤ 4 hops · designation type BIS_ENTITY_LIST

BIS license-presumption tier · China

Huawei Technologies's HQ jurisdiction sits in BIS's Presumption-of-friction band (23.9% denial+RWA share).

Denial + RWA share ≥15%. Notable proportion of applications denied or returned-without-action; the licensing regime itself is a binding constraint at the application layer.

24,992 approved1,890 denied5,964 returned (RWA)CY2018-CY2022

Aggregate across all ECCNs; specific-ECCN posture may diverge (e.g., 3A090 advanced-compute ICs after the Oct 2022 rule). Source: BIS OTE per-country PDFs under Section 1765 of ECRA / 50 USC §4824. Authority tier 1.

Read first · structural estimate, not legal interpretation

The Pre-Scorer models the structural reach of an affiliate graph built from licensed corporate-ownership databases (affiliate disclosures and ownership edges). The output stops short of legal interpretation: BIS designations under 15 CFR Part 744 (and the parallel SDN and EU Sanctions frameworks) turn on entity-identity rules, end-user analysis, license-review presumptions, and foreign-policy criteria the Pre-Scorer does not encode. The output is a structural-reach estimate; the policy recommendation that follows is the analyst’s job.

The pre-scorer models structural reach via resolved corporate-affiliate edges plus licensed corporate-ownership edges. It does not encode 15 CFR Part 744 legal criteria, BIS license-review presumptions, or end-user analysis.
Closure depth capped at 4 hops to mirror cascade-bis-designations.ts. Cycles and JV branches are not pruned beyond depth 4; some downstream entities may exist further out.
Facility match is operator-or-owner level. A facility leased to one operator under another beneficial owner is double-counted only when both org IDs resolve into the closure; a single match is counted once.
Confidence on each closure entry is the lowest-confidence hop in the chain (HIGH dominates only when every hop is HIGH). Entries reached via JV or AFFILIATE edges typically carry MEDIUM confidence by construction.
Licensed corporate-affiliate data reflects the most recent refresh; recent ownership-change transactions may not yet be ingested.

Calibration evidence · auto-picked anchor

Comparing this simulation against Huawei 2019 (2019-05-21)

Selected as the structural-cascade reference for Chinese-seed designations, where Huawei 2019 remains the most documented analogue. 84 FR 22961.

Switch anchorHuawei 2019chinese semiconductor conglomerate SMIC 2020chinese fab YMTC 2022chinese memory reset to auto

Metric	Projected	Anchor — structural cascade (live, computed)	Anchor — BIS-named (initial batch)	Δ vs structural (±15% / ±25% band)
Total entities reached includes seed for forward simulations	4	51	80	—
Affiliates / closure entries excludes seed; includes structural-cascade walk	3	51	79	—
Facilities (Scrutica-tracked) operator or owner ∈ closure	5	5	—	+0%
Power capacity (MW) summed across reached facilities	247	247
BIS-named-entity total cumulative (across all batches in Huawei 2019 family): 132 · structural reach is the union of named-entity facilities AND licensed-database-cascade facilities.

How was Huawei 2019’s reach reconstructed?

BIS designated Huawei Technologies Co., Ltd. and 68 non-U.S. affiliates on 2019-05-16, effective 2019-05-21 (FR 84 FR 22961). Subsequent batches on 2019-08-21 (FR 84 FR 43495, +46 affiliates) and 2020-08-20 (FR 85 FR 51603, +38 affiliates) raised the cumulative Huawei-family Entity List count to 132 active designations by 2026-05-03. Scrutica's substrate carries all 132 in export_control_designations. The 80 initial-batch designations anchor the comparable structural reach: a hypothetical Huawei designation announced today would equate structurally to the May 2019 batch, not the cumulative.

Structural-vs-legal divergence: BIS's Entity List determinations apply 15 CFR Part 744 entity-identity rules (alias matching, transliteration, phonetic match), end-user analysis, license-review presumptions, and foreign-policy criteria the Pre-Scorer's licensed-database affiliate-graph cascade does not encode. For state-linked Chinese conglomerates whose subsidiary networks are partially undisclosed in public records, BIS's named-entity reach typically EXCEEDS the structural cascade reach (Pre-Scorer's affiliate graph is missing entities BIS named via manual research). For Western publicly-listed corporations with subsidiaries disclosed in the licensed corporate-ownership database, the two typically agree within ±15% facility / ±25% capacity bands. The Huawei 2019 anchor is a high-divergence case — BIS reach > structural reach by 4-5x for the initial batch.

Live numbers (computed at this render): structural cascade reaches 5 Scrutica-tracked facilities via the affiliate-graph walk.

Follow-on batches:

2019-05-21 · 84 FR 22961 · ~80 entities · Initial Huawei + 68 non-US affiliates
2019-08-21 · 84 FR 43495 · ~11 entities · Added 46 additional non-US affiliates (consolidated into 11 unique parent-anchored sub-designations in Scrutica's substrate)
2020-08-20 · 85 FR 51603 · ~36 entities · Added 38 additional non-US affiliates

Affiliate cascade structure3 affiliates · depth 1

ShapeFront-loaded: half the facilities are caught within the seed itself.

Affiliates reached

including the seed entity → 4 total

seedh1

Facilities affected

across 2 countries

seedh1

Power capacity

247 MW

summed across affected facilities

seedh1

H100-equivalent GPUs

124,939

where disclosed by the facility record

seedh1

Already on a list

affected facilities already on a BIS / SDN / EU list

seedh1

STRONG coordination gap

facilities classified STRONG by Feature 15

seedh1

Jurisdictional distribution

5 facilities across 2 countries · 247 MW total · 124,939 H100-eq

Top: China80%

China

242 MW

4facil242MW123,799H100

(unspecified)

1facil5MW1,140H100

Affected facilities (5)

Facility	Operator / Owner	Closure path	Power MW	H100-eq	Confidence	Coord. gap	Already designated
Huawei Horinger CN · ai_training	Huawei Technologies	direct match	242	~123,799	HIGH	n/a	8 active matches
Huawei Pangu Ultra MoE 910Bs — · ai_training	— owner: Huawei Technologies	direct match	5	~1,140	HIGH	STRONG	8 active matches
Huawei Cloud Gui'an Data Center CN · hyperscale_dc	Huawei Technologies	direct match	—	—	HIGH	n/a	8 active matches
Huawei Cloud Ulanqab Data Center CN · hyperscale_dc	Huawei Technologies	direct match	—	—	HIGH	n/a	8 active matches
Huawei Dongguan Cloud Data Center (Songshan Lake) CN · hyperscale_dc	Huawei Technologies	direct match	—	—	HIGH	n/a	8 active matches

Closure audit (per-entity chain provenance + cross-cutting flags)

1 on a list1 with sov-LP linkage3 with HQ posture resolved

Hop	Entity	Reached via	Confidence	BIS / list status	HQ posture	Sovereign LPs
0	Huawei Technologies org-huawei	seed entity	HIGH	Entity List ×8	CNrestricted	Kuwait Investment Authority · GIC Private · Temasek Holdings · Mubadala Investment Company4 LPs
1	Huawei International Co., Limited org-bis-huawei-international-co-limited	Huawei TechnologiessubsidiaryFederal Register (BIS)Huawei International Co.,…	HIGH	—	HKunrecognized	—
1	Huawei International Pte. Ltd. org-bis-huawei-international-pte-ltd	Huawei TechnologiessubsidiaryFederal Register (BIS)Huawei International Pte.…	HIGH	—	SGnon-aligned	—
1	Shanghai HiSilicon Technologies Co., Ltd. org-hisilicon-shanghai	Huawei TechnologiessubsidiaryHKEX / SSE public filingShanghai HiSilicon Techno…	HIGH	—	CNrestricted	—

Sovereign-LP downstream surface

1 closure entity with sov-LP positions$300M total disclosed exposure4 LPs

Sovereign LPs (state-linked investors) with documented fund-position commitments to entities in the affiliate closure. Stage-aware caveat: the LP→fund→target chain does not resolve whether the fund manager has actually deployed capital INTO each named target — the substrate carries commitment status (Current / Recommended / Former), not target-level disbursement. Treat “Current” as evidence of an active fund position, not as evidence of deployed capital at the target.

Sovereign LP	Type	Disclosed $M (across positions)	Closure entities (targets)	Affected facilities	Fund mgrs.	Stage breakdown	Cross-link
Kuwait Investment Authority	Investor	$300M 2/2 disclosed	1	5	1	cur 2	/sovereign-ai/kuwait →
GIC Private	SWF	— 0/2 disclosed	1	5	1	cur 2	/sovereign-ai/singapore →
Mubadala Investment Company stage qualification required	Sovereign	— 0/3 disclosed	1	5	2	cur 3	/sovereign-ai/uae →
Temasek Holdings	SWF	— 0/1 disclosed	1	5	1	cur 1	/sovereign-ai/singapore →

Disbursement-stage qualification:Saudi PIF and UAE Mubadala (and similarly-positioned Gulf SWFs) carry a documented gap between announced fund commitments and capital actually deployed into target entities. A “Current” commitment status reflects the fund position, not the target-level deployment. Where the fund manager has not yet disbursed, the LP→fund→target chain is structurally incomplete; counting these positions as deployed exposure overstates the LP’s footprint at the target. Mark them as “announced/signed but undeployed” until disbursement evidence is added to the LP’s sovereign-program record.

Sovereign-investment linkage

Sovereign LPs (state-linked investors) with documented fund/LP-database commitments to entities in the affiliate closure. Per session prompt: structural fact, not motive inference.

Kuwait Investment Authority· 5 affected facilities
GIC Private· 5 affected facilities
Temasek Holdings· 5 affected facilities
Mubadala Investment Company· 5 affected facilities

Cite, export, or watch this simulation

Stable URL: https://scrutica.com/export-controls/impact?entity=org-huawei&type=BIS_ENTITY_LIST

@misc{scrutica_prescorer_org_huawei_20260720,
  title  = {Scrutica Regulatory Impact Pre-Scorer: Huawei Technologies},
  author = {{Scrutica}},
  year   = {2026},
  url    = {https://scrutica.com/export-controls/impact?entity=org-huawei&type=BIS_ENTITY_LIST},
  note   = {Computed 2026-07-20; 3 affiliates, 5 facilities, 2 countries.},
}