Structural reach of a designation or removal
Entities already on a list are marked in the results. The projection uses their recorded corporate relationships.
Multi-removal scenarios 3 worked cases
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 projection for Huawei Technologies includes 3 affiliate entities and 4 Scrutica-tracked facilities across 1 country.
The reach in six measures
The designation-record count covers the initial batch and was captured on 3 May 2026. The current count of entities reached through corporate relationships covers all batches in the Huawei 2019 family. The two populations differ, so the number of designated entities the model missed is not derivable from them. The bar labelled “This simulation” is the simulated designation.
Affiliate cascade structure
Choose any of the 4 entities to inspect its facilities, confidence and chain to the seed.
Jurisdictional distribution
Affected facilities
All 4 facilities — closure path: Direct match · hops: 0 · confidence: High · already designated: 1 active designation
| Facility | Recorded organisation | Power MW | H100-eq | Coordination gap |
|---|---|---|---|---|
| Huawei HoringerCN · AI Training | — | ~278 | ~123,799 | Strong |
| Huawei Cloud Gui'an Data CenterCN · Hyperscale DC | Huawei Technologies | — | — | Opaque |
| Huawei Cloud Ulanqab Data CenterCN · Hyperscale DC | Huawei Technologies | — | — | Opaque |
| Huawei Dongguan Cloud Data Center (Songshan Lake)CN · Hyperscale DC | Huawei Technologies | — | — | Opaque |
Entities the ownership walk reached
| Hop | Entity | Reached via | Confidence | List status | HQ posture | Sovereign LPs |
|---|---|---|---|---|---|---|
| 0 | Huawei Technologies | seed entity | High | BIS Entity List | 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 | — |
Comparison with a historical designation
Auto-picked anchor
This simulation is set beside Huawei 2019 (2019-05-21). Huawei 2019 is the default for a Chinese entity whose name matches neither the memory nor foundry keywords. 84 FR 22961.
Change the comparison anchor ↑
| Metric | Projected | Anchor · structural cascade(live, computed) | Anchor · Designation records(initial batch) | Δ vs structural(±15% / ±25% band) |
|---|---|---|---|---|
| Entities / designation recordsincludes seed for forward simulations | 4 | 9 | 80 | — |
| Affiliates / closure entriesexcludes seed; includes structural-cascade walk | 3 | 9 | — | — |
| Facilities (Scrutica-tracked)operator, owner, or hardware owner in the closure | 4 | 4 | — | +0% |
| Operating power (MW)summed across reached operating facilities | 278 | 278 | — | +0% |
| H100-equivalent GPUswhere disclosed | 123,799 | 123,799 | — | — |
| Countries reacheddistinct facility-country values | 1 | 1 | — | — |
The Huawei 2019 designation table contains 132 active records across all batches; only the initial-batch count is shown above. These records have not been reconciled to distinct entities named in the notices. For the historical corporate-relationship comparison, entity totals include the affiliates reached from designated entities; facility, capacity and country totals also include the designated entities themselves.
How the Huawei 2019 counts were derived
The May 2019 rule named Huawei Technologies and 68 non-U.S. affiliates, effective 16 May and published 21 May (84 FR 22961). The local designation table captured on 3 May 2026 contains 80 active records assigned to that initial batch and 132 across the Huawei family. These stored record counts have not been reconciled to the entities enumerated in the notices; follow-on batches are listed below.
Structural-vs-legal divergence: The historical comparison uses a frozen designation-record count and a current count of distinct entities reached through recorded corporate relationships. A difference between those totals does not establish which entities were missed. Legal identity, end use and licence conditions require separate assessment.
4 tracked facilities have an operator, owner or hardware owner among the entities reached through corporate relationships or matched directly to designation records.
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
In China, where Huawei Technologies is headquartered, 23.9% of the recorded applications were denied or returned without action. Denial + RWA 15% or higher
24,992 approved 1,890 denied 5,964 returned without action CY2018–CY2022
Country totals cover all export-control classifications and do not establish the licensing requirements for this company or a particular transaction. The percentage includes approved, denied and returned applications in its denominator. Source: BIS Office of Technology Evaluation, annual country licensing reports.
State-linked investors in these entities
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 | $150M1/1 disclosed | 1 | Current 1 | Sovereign AI dashboard → |
| GIC Private | Sovereign wealth fund | —0/1 disclosed | 1 | Current 1 | Sovereign AI dashboard → |
| Mubadala Investment Companystage qualification required | Sovereign entity | —0/2 disclosed | 2 | Current 2 | Sovereign AI dashboard → |
| Temasek Holdings | Sovereign wealth fund | —0/1 disclosed | 1 | Current 1 | Sovereign AI dashboard → |
Limits of this reading
- The pre-scorer models structural reach via resolved corporate-affiliate edges plus licensed corporate-ownership edges.
- Closure depth capped at 4 hops to mirror the BIS designation affiliate-cascade closure. Cycles and JV branches are not pruned beyond depth 4; some downstream entities may exist further out.
- Facility match runs at operator, owner or hardware-owner level. A facility that matches on more than one of the three is counted once, attributed to whichever of those matches the walk recorded first.
- Confidence on a closure entry is the lowest confidence of any hop in its chain. An entry reached through a joint-venture or affiliate edge is usually medium by construction.
- Licensed corporate-affiliate data reflects the most recent refresh; recent ownership-change transactions may not yet be ingested.
Citation and export
Stable URL: https://scrutica.com/export-controls/impact?entity=org-huawei&type=BIS_ENTITY_LIST
@misc{scrutica_prescorer_org_huawei_20261019,
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 2026-10-19; 3 affiliates, 4 facilities, 1 country.},
}4 corrections · latest Sep 25, 2026
- Sep 25, 2026 · Export-control cross-reference: 101 of 102 ownership-chain matches could not be traced to the designated entity
- Sep 25, 2026 · Export-control alignment: four SEC filers read as unresolved because of their own subsidiaries
- Sep 23, 2026 · Regulatory impact pre-scorer: simulations shown from partial reads
- Sep 23, 2026 · Capacity totals: planned capacity counted as present capacity
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 whose fields name different organisations is reached through whichever of them sits in the closure; a facility that matches on more than one is kept once, keyed on facility id. A match means the organisation is recorded at the facility; the relationship its source establishes there is stated on the facility record.
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 sovereign investors linked through fund managers. The recorded commitments are to funds; investment by those funds in the entity is not established by the linkage.
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, 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.