Scrutica
Full EAR classification (ECCN 3A090, 4A090) with specific performance thresholds (TOPS, bandwidth, interconnect parameters). License exception applicability per chip-destination pair.
Each AI chip is classified by its computing power. Above certain thresholds set by the US government, sales to certain countries require government approval or are prohibited entirely.
The BIS Entity List subsidiary-extension rule (50% ownership threshold, codified September 30, 2025 as a Final Rule per 90 FR 2025-19001 and suspended for one year on November 10, 2025 per 90 FR 2025-19846) is structurally vulnerable to corporate rebranding when a designated parent entity holds slightly less than 50% of a US-incorporated subsidiary. The canonical worked example is Aivres Systems Inc. — formerly "Inspur Systems Inc." — which rebranded in May 2023 shortly after parent Inspur Group was added to the U.S. Entity List in March 2023. A licensed corporate-ownership database entity-tree (2026-05-14) still surfaces the pre-rebrand name "Inspur Systems, Inc." at depth-1 of IEIT Systems Co., Ltd. (000977-CN) — see licensed-database provenance for the auditable methodology.
Aivres remains approximately one-third Chinese-state-linked via Inspur Information's licensed corporate-ownership holder-type disclosure (33.26% "Private Company" insider on the 000977-CN A-share listing), while the sister listing (Inspur International / Inspur Digital Enterprise Technology Limited, 596-HK) records 50.88% "Government" insider ownership for the same group. The cross-listing disclosure asymmetry is the structural mechanism that lets Aivres technically fall outside both Nvidia trade restrictions and the BIS Entity List 50%-subsidiary-extension threshold — an analytical pattern surfaced in the Culper Research 2026-05-13 short thesis (Tier 3 analyst publication) and corroborated at every disclosed node by a licensed corporate database 2026-05-14 (Tier 2).