Regulatory Impact Pre-Scorer

Name: Scrutica Global Compute Infrastructure Database
Creator: Scrutica
License: https://scrutica.com/about

Walks the affiliate closure of a hypothetical designation target downward through the documented ownership graph (max 4 hops, mirroring the cascade rule used to backfill historical BIS designations), joins to facilities by operator/owner org, and enriches every closure entry with current BIS / SDN / EU Sanctions designation status, the entity's HQ jurisdiction posture from the Allied Coordination Gap regimes table, and any sovereign-LP linkage from PitchBook fund-LP chains. Each hop carries chain-of-control provenance — primary filing, research-database edge, or alias-resolved match — so the cascade can be audited, not just cited.

Estimates which Scrutica-tracked facilities would be reached by the structural cascade of a proposed BIS designation, run before the Federal Register notice — the input a committee staffer wants when scoping markup four weeks ahead of docket close. The output is a structural-reach estimate over the affiliate graph; legal determinations under 15 CFR Part 744 turn on entity-identity rules, end-user analysis, license-review presumptions, and foreign-policy criteria the Pre-Scorer does not encode. Inverse simulation models the structural reach lost if a current designation were removed.

Hypothetical designation target

Pre-scorer simulates new designations. Already-designated entities are flagged below; click to switch to inverse-simulation mode.

TryNvidiafabless designer · global affiliate network TSMCfoundry · Taiwan + Arizona + Kumamoto fabs SamsungKorean conglomerate · memory + foundry Huaweialready on Entity List · partial cascade visible

Inverse simulation (start from a current designation):BIS cross-reference →

What this answers

If BIS adds Entity X tomorrow, the pre-scorer estimates the downstream reach of the cascade: how many Scrutica-tracked facilities are caught, what compute capacity that represents, what countries they sit in, and which already-designated entities they overlap with. Legal determinations are BIS's, under separate criteria.

What it doesn't do

Walks the affiliate graph downward from a hypothetical target and returns the closure. The report does not interpret 15 CFR Part 744, predict whether BIS would designate, encode entity-identity rules (alias matching, transliteration, phonetic match), or include transactions not yet ingested in PitchBook. Inverse-simulation mode (start from a current designation, see what would be lost on de-listing) lives at the BIS cross-reference link above.

Methodologyclosure walk · facility match · enrichment · coverage limits

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 carries 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 or owner organization resolves to that entry through the canonical-org map. Direct seed-entity matches are reported as hop 0. Operator and owner are queried independently so a facility leased under a different operator from its beneficial owner matches through either path; deduplication is on facility id.

3. Cross-cutting enrichment

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 carries: BIS / SDN / EU Sanctions designation status, the entity's HQ jurisdiction posture (allied-coordinated / allied-partial / non-aligned / restricted) from the regimes table, and the sovereign LPs documented as committing to that entity in PitchBook fund-LP chains.

4. Substrate filters

SEC-EDGAR Item 21 ingestion produces both real operating subsidiaries (Inc., Corp., Ltd., GmbH) and securities-issuance / cover-page artefacts (rated debt notes, ADS/ADR cover-page text, share-class descriptions, table headers). The closure walk filters the latter by name pattern so they don't render as fake subsidiaries. Real operating subsidiaries ingested via SEC EDGAR are unaffected; the count of filtered artefacts is surfaced in the report's caveats when nonzero.

5. What it can't see

Transactions not yet ingested in PitchBook (weekly refresh), entities outside the canonical-org map, beneficial owners hidden behind unrecorded shell layers, JV partners not disclosed in PitchBook, and entity-identity rules BIS uses for designations (alias matching, transliteration, phonetic match) that a structural-graph approach does not encode.

Closure shape and confidence semantics match the offline cascade run that backfills historical designations, so a Pre-Scorer simulation and an actual cascade agree on what the affiliate graph implies. Each simulation carries a stable URL plus a computed timestamp, so a researcher returning to the URL re-runs against current data and can see when the original report was generated.