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Checked 2026-10-26 · unchanged since 2026-08-21RSS

Export Controls

Impact Pre-Scorer

Export controls on AI chips and computing infrastructure, with designation records and semiconductor trade data.

Structural reach of a designation or removal

Simulated designation

The projection for NVIDIA includes 19 affiliate entities and 21 Scrutica-tracked facilities across 5 countries.

Computed 2026-10-26 · closure depth ≤ 4 hops · BIS Entity List

The reach in six measures

Affiliates reached1920 entities in the closure, including the seed
Facilities affected21across 5 countries · of 4,583 tracked facilities
Operating power~40 MWsummed across the affected facilities that are operating (21% estimated rather than disclosed); a further 59 MW is planned, under construction or otherwise not operating
Operating H100-equivalent GPUs~22,044summed where disclosed on operating facility records; per-facility values are estimates
Already on a list0affected facilities that already have a BIS, SDN or EU Sanctions match
Strong coordination gap0classified strong by the allied coordination-gap analysis; a further 1 classified opaque
Historical reference countsmeasured against Huawei 2019 · 84 FR 22961calibration detail below
Huawei 2019 — designation records (initial batch)80
Huawei 2019 — entities reached (all batches)9
This simulation — projected20seed + 19 affiliates, all one hop out

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 strip groups projected entities by relationship distance. The bar labelled “This simulation” is the simulated designation.

Affiliate cascade structure19 affiliates · depth 1

Choose any of the 20 entities to inspect its facilities, confidence and chain to the seed.

Seed1 entity · 20 facilHop 119 entities · 1 facilNVIDIA20 facil · +1 via subtreeLepton Ai1 facilBright Computing BVDeepMap Cayman Ltd.DeepMap GmbHDeepMap Hongkong Ltd.Excelero, Inc.Illumex Technologies Ltd.IPtronics A/SKotura, Inc.Mellanox Technologies India Pvt Ltd.Mellanox Technologies, LtdNvidia Belfast Ltd.NVIDIA Brasil Computação Visual Ltda.NVIDIA Graphics Pvt Ltd.NVIDIA International, Inc.NVIDIA Italy Srl+ 3 more affiliates
Half the facilities are matched within the seed itself. Each column is one hop from the seed. A mark is an entity in the closure, sized by the facilities that record it directly (in any role), filled where it has any, and ringed where those facilities already sit on a designation list. Each hop draws at most 16 entities, ranked by the facilities in its subtree, so 16 of 19 affiliates are marked here; the rest are counted at the foot of their column and listed in the closure audit.

Jurisdictional distribution

21 facilities across 5 countries · ~40 MW total · ~22,044 H100-equivalentTop: United States67%Top 390%
United States14facil~33MW~18,114H100
Israel3facil~3MW~2,048H100
(unspecified)2facil2MW~1,121H100
Taiwan1facil1MW~559H100
United Kingdom1facil1MW~202H100

Affected facilities

21 facilities reached

All 21 facilities — recorded organisation not recorded · confidence: High · already designated not recorded

FacilityClosure pathPower MWH100-eqHopsCoordination gap
NVIDIA CoreWeave Eos-DFW Phase 1US · AI Trainingdirect match—~10,7520None
NVIDIA Eos Phase 2US · AI Trainingdirect match7~4,6080None
NVIDIA Selene Phase 2US · AI Trainingdirect match5~1,4130None
NVIDIA SATURN V Phase 3US · AI Trainingdirect match~4~880None
NVIDIA Israel-1 Phase 2IL · AI Trainingdirect match~3~2,0480None
NVIDIA Helios— · AI Trainingdirect match1~1,0240None
LeptonAI H100 ClusterUS · AI TrainingNVIDIA subsidiary Lepton Ai~1~1,0241Opaque
NVIDIA Taipei-1TW · AI Trainingdirect match1~5590None
NVIDIA DGX SuperPOD 2019— · AI Trainingdirect match1~970None
NVIDIA Cambridge-1GB · AI Trainingdirect match1~2020None
NVIDIA CirceUS · AI Trainingdirect match0~360None
NVIDIA In-house DGX A100 ClusterUS · AI Trainingdirect match~0~1260None
Show the remaining 9 facilities
FacilityClosure pathPower MWH100-eqHopsCoordination gap
NVIDIA SATURN V VoltaUS · AI Trainingdirect match0~170None
NVIDIA TethysUS · AI Trainingdirect match0~500None
NVIDIA CoreWeave Eos-DFW Rumored Phase 2US · AI Trainingdirect match~45 · announced~32,0000None
NVIDIA Israel Blackwell SupercomputerIL · AI Trainingdirect match~30 · announced—0None
NVIDIA SATURN V Phase 2US · AI Trainingdirect match—~3340None
NVIDIA Israel-1 Phase 1IL · AI Trainingdirect match—~1,0240None
NVIDIA SATURN V Phase 1US · AI Trainingdirect match—~90None
NVIDIA Selene Phase 1US · AI Trainingdirect match—~7060None
NVIDIA Eos Phase 1US · AI Trainingdirect match—~1,0240None

Entities the ownership walk reached

All 20 entries0 on a list 15 with HQ posture resolved
HopEntityReached viaConfidenceList statusHQ posture
0NVIDIAseed entityHigh—USAllied, coordinated
1Illumex Technologies Ltd.NVIDIA subsidiary (Company disclosure (press / IR))High—ILNon-aligned
1Lepton AiNVIDIA subsidiary (Company disclosure (press / IR))High—HQ unknown
1Mellanox Technologies, LtdNVIDIA subsidiary (SEC EDGAR)High—ILNon-aligned
1NVIDIA International, Inc.NVIDIA subsidiary (SEC EDGAR)High—USAllied, coordinated
1NVIDIA Singapore Pte LtdNVIDIA subsidiary (SEC EDGAR)High—SGNon-aligned
1NVIDIA Italy SrlNVIDIA subsidiary (SEC EDGAR)High—ITAllied, partial
1Kotura, Inc.NVIDIA subsidiary (SEC EDGAR)High—USAllied, coordinated
1Mellanox Technologies India Pvt Ltd.NVIDIA subsidiary (SEC EDGAR)High—INAllied, partial
1NVIDIA Brasil Computação Visual Ltda.NVIDIA subsidiary (SEC EDGAR)High—BRNon-aligned
1NVIDIA Graphics Pvt Ltd.NVIDIA subsidiary (SEC EDGAR)High—INAllied, partial
1Runai Labs Ltd.NVIDIA subsidiary (Company disclosure (press / IR))High—ILNon-aligned
Show the remaining 8 closure entries
HopEntityReached viaConfidenceList statusHQ posture
1Excelero, Inc.NVIDIA subsidiary (Company disclosure (press / IR))High—USAllied, coordinated
1IPtronics A/SNVIDIA subsidiary (SEC EDGAR)High—DKNot classified
1NVIDIA Poland Sp zooNVIDIA subsidiary (SEC EDGAR)High—PLNot classified
1Bright Computing BVNVIDIA subsidiary (SEC EDGAR)High—NLAllied, coordinated
1DeepMap Cayman Ltd.NVIDIA subsidiary (SEC EDGAR)High—KYNot classified
1DeepMap GmbHNVIDIA subsidiary (SEC EDGAR)High—DEAllied, partial
1DeepMap Hongkong Ltd.NVIDIA subsidiary (SEC EDGAR)High—HKNot classified
1Nvidia Belfast Ltd.NVIDIA subsidiary (SEC EDGAR)High—GBAllied, partial

Comparison with a historical designation

Auto-picked anchor

This simulation is set beside Huawei 2019 (2019-05-21). Huawei 2019 is the default when the entity name matches neither the memory nor foundry keywords. 84 FR 22961.

Change the comparison anchor ↑

MetricProjectedAnchor · structural cascade(live, computed)Anchor · Designation records(initial batch)Δ vs structural(±15% / ±25% band)
Entities / designation recordsincludes seed for forward simulations20980—
Affiliates / closure entriesexcludes seed; includes structural-cascade walk199——
Facilities (Scrutica-tracked)operator, owner, or hardware owner in the closure214—+425%
Operating power (MW)summed across reached operating facilities40212—-81%
H100-equivalent GPUswhere disclosed22,04489,439——
Countries reacheddistinct facility-country values51——

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

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.

Citation and export

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

@misc{scrutica_prescorer_org_nvidia_20261026,
  title  = {Scrutica Regulatory Impact Pre-Scorer: NVIDIA},
  author = {{Scrutica}},
  year   = {2026},
  url    = {https://scrutica.com/export-controls/impact?entity=org-nvidia&type=BIS_ENTITY_LIST},
  note   = {Computed 2026-10-26; 19 affiliates, 21 facilities, 5 countries.},
}

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.