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 →
Simulated designation
The projection for Alibaba includes 2 affiliate entities and 24 Scrutica-tracked facilities across 16 countries.
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 3 entities to inspect its facilities, confidence and chain to the seed.
Jurisdictional distribution
Show the remaining 4 countries
Affected facilities
All 24 facilities — closure path: Direct match · hops: 0 · confidence: High · already designated not recorded
| Facility | Recorded organisation | Power MW | H100-eq | Coordination gap |
|---|---|---|---|---|
| Alibaba ZhangbeiCN · AI Training | — | ~203 | ~31,884 | Strong |
| Alibaba Cloud Hangzhou Yuhang Super Data CenterCN · Hyperscale DC | Alibaba | — | — | Opaque |
| Alibaba Cloud Nantong Super Data CenterCN · Hyperscale DC | Alibaba | — | — | Opaque |
| Alibaba Cloud Ulanqab Super Data CenterCN · Hyperscale DC | Alibaba | — | — | Opaque |
| Alibaba Cloud in UAEAE · AI Training | — | — | — | Strong |
| Alibaba Cloud in Silicon ValleyUS · AI Training | — | — | — | Strong |
| Alibaba Cloud in Malaysia Phase 2MY · AI Training | — | — | — | Strong |
| Alibaba Cloud in Saudi ArabiaSA · AI Training | — | — | — | Strong |
| Alibaba Cloud in United KingdomGB · AI Training | — | — | — | Strong |
| Alibaba Cloud in South Korea Phase 1KR · AI Training | — | — | — | Strong |
| Alibaba Cloud in SingaporeSG · AI Training | — | — | — | Strong |
| Alibaba Cloud in IndiaIN · AI Training | — | — | — | Strong |
Show the remaining 12 facilities
| Facility | Recorded organisation | Power MW | H100-eq | Coordination gap |
|---|---|---|---|---|
| Alibaba Cloud in Philippines Phase 2PH · AI Training | — | — | — | Strong |
| Alibaba Cloud in VirginiaUS · AI Training | — | — | — | Strong |
| Alibaba Cloud in South Korea Phase 2KR · AI Training | — | — | — | Strong |
| Alibaba Cloud in GermanyDE · AI Training | — | — | — | Strong |
| Alibaba Cloud in AustraliaAU · AI Training | — | — | — | Strong |
| Alibaba Cloud in Thailand Phase 1TH · AI Training | — | — | — | Strong |
| Alibaba Cloud in Malaysia Phase 1MY · AI Training | — | — | — | Strong |
| Alibaba Cloud in MexicoMX · AI Training | — | — | — | Strong |
| Alibaba Cloud in Philippines Phase 1PH · AI Training | — | — | — | Strong |
| Alibaba Cloud in IndonesiaID · AI Training | — | — | — | Strong |
| Alibaba Cloud in JapanJP · AI Training | — | — | — | Strong |
| Alibaba Cloud in Thailand Phase 2TH · AI Training | — | — | — | Strong |
Entities the ownership walk reached
| Hop | Entity | Reached via | Confidence | List status | HQ posture |
|---|---|---|---|---|---|
| 0 | Alibaba | seed entity | High | — | CNRestricted |
| 1 | Alibaba Cloud Computing | Alibaba subsidiary (SEC EDGAR) | High | — | CNRestricted |
| 1 | Pingtouge Semiconductor | Alibaba subsidiary (SEC EDGAR) | 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 | 3 | 9 | 80 | — |
| Affiliates / closure entriesexcludes seed; includes structural-cascade walk | 2 | 9 | — | — |
| Facilities (Scrutica-tracked)operator, owner, or hardware owner in the closure | 24 | 4 | — | +500% |
| Operating power (MW)summed across reached operating facilities | 203 | 212 | — | -4% |
| H100-equivalent GPUswhere disclosed | 31,884 | 89,439 | — | — |
| Countries reacheddistinct facility-country values | 16 | 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 Alibaba 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.
Sovereign capital
Sovereign fund linkage is withdrawn while its fund-type and identity checks are rebuilt.
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.
- 3 recorded ownership edges were not followed, because the ownership control review records that each confers no control (a funding-round stake, for instance); an entity reached only through such an edge is not in the closure.
Citation and export
Stable URL: https://scrutica.com/export-controls/impact?entity=org-alibaba&type=BIS_ENTITY_LIST
@misc{scrutica_prescorer_org_alibaba_20261025,
title = {Scrutica Regulatory Impact Pre-Scorer: Alibaba},
author = {{Scrutica}},
year = {2026},
url = {https://scrutica.com/export-controls/impact?entity=org-alibaba&type=BIS_ENTITY_LIST},
note = {Computed 2026-10-25; 2 affiliates, 24 facilities, 16 countries.},
}4 corrections · latest 25 Sep 2026
- 25 Sep 2026 · Export-control cross-reference: 101 of 102 ownership-chain matches could not be traced to the designated entity
- 25 Sep 2026 · Export-control alignment: four SEC filers read as unresolved because of their own subsidiaries
- 23 Sep 2026 · Regulatory impact pre-scorer: simulations shown from partial reads
- 23 Sep 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. An edge the ownership control review records as conferring no control (a funding-round stake, a holding its issuer says controls nothing) is not followed, so an investee is not counted as an affiliate of its investor; the report’s caveats count such edges.
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). Each closure entry separately lists: BIS / SDN / EU Sanctions designation status, and the entity’s HQ jurisdiction posture (allied-coordinated / allied-partial / non-aligned / restricted) from the regimes table. Sovereign fund linkage is withdrawn while its fund-type and identity checks are rebuilt.
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.