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Checked 2026-10-05 · 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 Super Micro Computer, Inc. includes 17 affiliate entities and 0 Scrutica-tracked facilities across 0 countries.

Computed 2026-10-05 · closure depth ≤ 4 hops · BIS Entity List

The reach in six measures

Affiliates reached1718 entities in the closure, including the seed
Facilities affected0across 0 countries · of 4,582 tracked facilities
Operating power—no affected facility has a disclosed power figure
Operating H100-equivalent GPUs—no affected facility has a disclosed H100-equivalent figure
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
Historical reference countsmeasured against Huawei 2019 · 84 FR 22961calibration detail below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 — projected18seed + 17 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 structure17 affiliates · depth 1

Choose any of the 18 entities to inspect its facilities, confidence and chain to the seed.

Seed1 entityHop 117 entitiesSuper Micro Computer, Inc.seedSuper Micro Asia Science and Technology P…Super Micro Computer Arabia Ltd.Super Micro Computer B.V.Super Micro Computer GmbHSuper Micro Computer Holdings B.V.Super Micro Computer International Inc.Super Micro Computer Korea YHSuper Micro Computer LimitedSuper Micro Computer Malaysia Sdn BhdSuper Micro Computer SARLSuper Micro Computer Singapore Pte. Ltd.Super Micro Computer Spain, S.L.Super Micro Computer US LLCSuper Micro Computer, Inc. TaiwanSuper Micro Computer, S.R.L.Supermicro KK+ 1 more affiliate
The cascade reaches entities, but no Scrutica-tracked facility records any of them. 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 17 affiliates are marked here; the rest are counted at the foot of their column and listed in the closure audit.

Affected facilities

No Scrutica-tracked facility records an entity in the closure in any role, which can also mean the facility records carry operator or owner ids that did not resolve through the canonical-org map.

Entities the ownership walk reached

All 18 entries0 on a list 0 with sovereign-LP linkage 17 with HQ posture resolved
HopEntityReached viaConfidenceList statusHQ postureSovereign LPs
0Super Micro Computer, Inc.seed entityHigh—USAllied, coordinated—
1Super Micro Asia Science and Technology Park, Inc.Super Micro Computer, Inc. subsidiary (SEC EDGAR)High—TWNon-aligned—
1Super Micro Computer Arabia Ltd.Super Micro Computer, Inc. subsidiary (SEC EDGAR)High—SANon-aligned—
1Super Micro Computer B.V.Super Micro Computer, Inc. subsidiary (SEC EDGAR)High—NLAllied, coordinated—
1Super Micro Computer GmbHSuper Micro Computer, Inc. subsidiary (SEC EDGAR)High—DEAllied, partial—
1Super Micro Computer Holdings B.V.Super Micro Computer, Inc. subsidiary (SEC EDGAR)High—NLAllied, coordinated—
1Super Micro Computer, Inc. TaiwanSuper Micro Computer, Inc. subsidiary (SEC EDGAR)High—TWNon-aligned—
1Super Micro Computer International Inc.Super Micro Computer, Inc. subsidiary (SEC EDGAR)High—KYNot classified—
1Super Micro Computer Korea YHSuper Micro Computer, Inc. subsidiary (SEC EDGAR)High—KRAllied, partial—
1Super Micro Computer LimitedSuper Micro Computer, Inc. subsidiary (SEC EDGAR)High—GBAllied, partial—
1Super Micro Computer Malaysia Sdn BhdSuper Micro Computer, Inc. subsidiary (SEC EDGAR)High—MYNon-aligned—
1Super Micro Computer, S.R.L.Super Micro Computer, Inc. subsidiary (SEC EDGAR)High—ITAllied, partial—
Show the remaining 6 closure entries
HopEntityReached viaConfidenceList statusHQ postureSovereign LPs
1Super Micro Computer SARLSuper Micro Computer, Inc. subsidiary (SEC EDGAR)High—FRAllied, partial—
1Super Micro Computer Singapore Pte. Ltd.Super Micro Computer, Inc. subsidiary (SEC EDGAR)High—SGNon-aligned—
1Super Micro Computer Spain, S.L.Super Micro Computer, Inc. subsidiary (SEC EDGAR)High—ESAllied, partial—
1Super Micro Computer US LLCSuper Micro Computer, Inc. subsidiary (SEC EDGAR)High—USAllied, coordinated—
1Supermicro KKSuper Micro Computer, Inc. subsidiary (SEC EDGAR)High—JPAllied, coordinated—
1Supermicro Technology (Beijing) Co., Ltd.Super Micro Computer, Inc. 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 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 simulations18980—
Affiliates / closure entriesexcludes seed; includes structural-cascade walk179——
Facilities (Scrutica-tracked)operator, owner, or hardware owner in the closure04—-100%
Operating power (MW)summed across reached operating facilities0278—-100%
H100-equivalent GPUswhere disclosed0123,799——
Countries reacheddistinct facility-country values01——

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

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-supermicro&type=BIS_ENTITY_LIST

@misc{scrutica_prescorer_org_supermicro_20261005,
  title  = {Scrutica Regulatory Impact Pre-Scorer: Super Micro Computer, Inc.},
  author = {{Scrutica}},
  year   = {2026},
  url    = {https://scrutica.com/export-controls/impact?entity=org-supermicro&type=BIS_ENTITY_LIST},
  note   = {Computed 2026-10-05; 17 affiliates, 0 facilities, 0 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.

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.