Commentary

Updated U.S. Export Controls on Advanced Chips Seek to Close Loopholes and Push Allied Alignment

Key Takeaways

  • The latest Department of Commerce export controls on advanced semiconductors and semiconductor manufacturing equipment seek to close existing loopholes by expanding controls on foreign exports of chipmaking tools that contain U.S. technology and restricting the trade of high bandwidth memory products critical for supporting data center growth and AI development.
  • In exchange for carve-outs in the updated controls on chipmaking tools, Japan and the Netherlands are expected to announce their own, related export control policies in the coming days and weeks.
  • China quickly responded by enforcing new “dual use” export controls on critical minerals to any U.S. military end users. Beijing may contemplate additional measures targeted at U.S. companies while also preserving political space to react to President-elect Trump’s China policies in 2025.
  • While the updated chip export control rules may be the last technology competition measure the Biden Administration unveils before the end of the term, the Commerce Department may seek to update the proposed “know your customer” rules for the cloud computing sector by the end of the year.

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