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.

What a hypothetical designation would reach

Hypothetical designation target

Results mark entities already on a list; choosing one reports the reach that listing already has.

Example targets

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

Multi-removal scenarios 3 worked cases

SMIC group (parent + 3 fabs) · 4 designationswhat comes off the list if BIS removes all four SMIC entries YMTC parent + Japan subsidiary · 2 designationsmemory-policy unwind: trade-deal scenario for the 2022 NAND-fab listings CETC research-institute cluster · 2 designationscoordinated removal of CETC-7 + CETC-30 (military-civil-fusion R&D)

Each scenario starts from designations now in force and totals the reach that comes off the list when they are removed together. Entity List →

Designation in force

The designation of Huawei Technologies cascades through 3 affiliate entities to affect 4 Scrutica-tracked facilities across 1 country.

Computed 2026-09-09 · closure depth ≤ 4 hops · BIS Entity List

Worked example Huawei is already on the Entity List, so this report shows the reach its current listing has.

The reach in six measures

Affiliates reached34 entities in the closure, including the seed

Facilities affected4across 1 country · of 4,573 tracked facilities

Power capacity242 MWsummed across affected facilities

H100-equivalent GPUs~123,799summed where disclosed by the facility record; per-facility values are estimates

Already on a list4affected facilities that already have a BIS, SDN or EU Sanctions match

Strong coordination gap4classified strong by the allied coordination-gap analysis

Cross-viewNo entity or chip selected.Open in Overview →Open in Trade →Open in Diversion →

Methodology · closure walk · facility match · designation, jurisdiction and investor flags · filtered rows · coverage gaps

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 names 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, owner, or hardware-owner organization resolves to that entry through the canonical-org map. Direct seed-entity matches are reported as hop 0. The three queries run independently, so a facility leased to one operator but beneficially owned by another is reached through whichever of the three sits in the closure; a facility that matches on more than one is kept once, keyed on facility id.

3 · Designation, jurisdiction and investor flags

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 lists: 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.

4 · Filtered rows

A registrant’s Exhibit 21 subsidiary list, ingested from SEC EDGAR, yields two kinds of row: operating subsidiaries (Inc., Corp., Ltd., GmbH) and securities-issuance or cover-page artefacts (rated debt notes, ADS/ADR cover-page text, share-class descriptions, table headers). The closure walk filters the second kind by name pattern, and the count it filtered appears in the report’s caveats whenever it is nonzero.

5 · Coverage gaps

Transactions not yet ingested from the licensed fund/LP database (weekly refresh), entities outside the canonical-org map, beneficial owners hidden behind unrecorded shell layers, JV partners not disclosed in the licensed fund/LP database, and entity-identity rules BIS uses for designations (alias matching, transliteration, phonetic match) that a structural-graph approach does not encode.

Closure shape and confidence semantics match the offline cascade run that backfills historical designations, so a pre-scorer simulation and an actual cascade agree on what the affiliate graph implies.

Affected facilities

4 facilities reached

All 4 facilities — closure path: Direct match · hops: 0 · confidence: High · coordination gap: Strong · already designated: 4 active designations

Facility	Operator / owner	Power MW	H100-eq
Huawei HoringerCN · AI Training	—	242	~123,799
Huawei Cloud Gui'an Data CenterCN · Hyperscale DC	Huawei Technologies	—	—
Huawei Cloud Ulanqab Data CenterCN · Hyperscale DC	Huawei Technologies	—	—
Huawei Dongguan Cloud Data Center (Songshan Lake)CN · Hyperscale DC	Huawei Technologies	—	—

Entities the ownership walk reached

All 4 entries1 on a list 1 with sovereign-LP linkage 3 with HQ posture resolved

Hop	Entity	Reached via	Confidence	List status	HQ posture	Sovereign LPs
0	Huawei Technologies	seed entity	High	BIS Entity List ×4	CNRestricted	Kuwait Investment Authority · GIC Private · Temasek Holdings · Mubadala Investment Company4 LPs
1	Huawei International Co., Limited	Huawei Technologies subsidiary (Federal Register (BIS))	High	—	HKNot classified	—
1	Huawei International Pte. Ltd.	Huawei Technologies subsidiary (Federal Register (BIS))	High	—	SGNon-aligned	—
1	Shanghai HiSilicon Technologies Co., Ltd.	Huawei Technologies subsidiary (HKEX / SSE public filing)	High	—	CNRestricted	—

Calibration against a historical designation

Auto-picked anchor

This simulation is set beside Huawei 2019 (2019-05-21). A Chinese seed with no industry-specific keyword; the anchor is the most documented Chinese designation. 84 FR 22961.

Change the comparison anchor ↑

Metric	Projected	Anchor · structural cascade(live, computed)	Anchor · BIS-named(initial batch)	Δ vs structural(±15% / ±25% band)
Total entities reachedincludes seed for forward simulations	4	51	80	—
Affiliates / closure entriesexcludes seed; includes structural-cascade walk	3	51	79	—
Facilities (Scrutica-tracked)operator, owner, or hardware owner in the closure	4	—	—	—
Power capacity (MW)summed across reached facilities	242	—	—	—
H100-equivalent GPUswhere disclosed	123,799	—	—	—
Countries reacheddistinct facility-country values	1	—	—	—

BIS has named 132 entities across all batches in the Huawei 2019 family; the column holds the initial batch alone. The structural-cascade column mixes two populations: its entity rows count the affiliates the cascade reaches from the named entities, while its facility, capacity and country rows count those affiliates together with the named entities themselves.

How Huawei 2019’s reach was reconstructed

BIS designated Huawei Technologies Co., Ltd. and 68 non-U.S. affiliates on 2019-05-16, effective 2019-05-21 (84 FR 22961). Further batches on 2019-08-21 (84 FR 43495, 46 affiliates) and 2020-08-20 (85 FR 51603, 38 affiliates) brought the Huawei family to 132 active designation records by 2026-05-03, all of which Scrutica holds. Every count on this panel is a record in Scrutica's designation table filtered to those still active, which is a different quantity from the affiliate counts the notices themselves state and does not line up with them one for one: the initial batch is 80 records. It is that figure the structural comparison uses, since a Huawei designation announced today would be the equivalent of one batch rather than of the whole family.

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 exceeds the structural cascade reach, the affiliate graph missing entities BIS named through 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. Huawei 2019 is a high-divergence case: the two counts and the shortfall between them are measured for each report, so the margin is not a fixed multiple.

Live numbers (computed for this report): the structural cascade reaches 4 Scrutica-tracked facilities via the affiliate-graph walk.

Follow-on batches:

2019-05-21 · 84 FR 22961 · ~80 designation records · The initial rule: Huawei Technologies and the 68 non-US affiliates it names
2019-08-21 · 84 FR 43495 · ~11 designation records · 46 further non-US affiliates named, consolidated here into 11 parent-anchored records
2020-08-20 · 85 FR 51603 · ~36 designation records · 38 further non-US affiliates named

BIS license outcomes — China

Huawei Technologies’s HQ jurisdiction sits in the Presumption-of-friction band (23.9% denial and RWA share). Denial + RWA share ≥15%. At that rate the license application is itself a gate on what ships, so the regime binds whether or not the buyer is designated.

24,992 approved 1,890 denied 5,964 returned without action CY2018–CY2022

Aggregate across all ECCNs; specific-ECCN posture may diverge (for instance 3A090 advanced-compute integrated circuits after the October 2022 rule). Source: BIS OTE per-country publications under Section 1765 of ECRA / 50 USC §4824.

State-linked investors in these entities

1 closure entity with sovereign-LP positions $300M total disclosed exposure 4 LPs

A row’s status (Current, Recommended or Former) records the state of a commitment to a fund; whether that manager has since placed capital in the entity beside it is not recorded.

All 4 rows — closure entities: 1 · affected facilities: 4

Sovereign LP	Type	Disclosed $M(across positions)	Fund mgrs.	Stage breakdown	Cross-link
Kuwait Investment Authority	Sovereign investor	$300M2/2 disclosed	1	Current 2	Sovereign AI dashboard →
GIC Private	Sovereign wealth fund	—0/2 disclosed	1	Current 2	Sovereign AI dashboard →
Mubadala Investment Companystage qualification required	Sovereign entity	—0/3 disclosed	2	Current 3	Sovereign AI dashboard →
Temasek Holdings	Sovereign wealth fund	—0/1 disclosed	1	Current 1	Sovereign AI dashboard →

Disbursement-stage qualification Saudi PIF and UAE Mubadala, and Gulf sovereign wealth funds positioned like them, have a documented gap between announced fund commitments and capital deployed into target entities, so counting the flagged positions as deployed exposure overstates the LP’s footprint at the target.