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U.S. Comprehensive Upgrade of Its Controls on Semiconductor Exports to China

11.02.23

On October 7, 2022, the Bureau of Industry and Security of the U.S. Department of Commerce (“BIS”) issued regulations aimed at curbing China’s ability to acquire high-end chips and manufacture advanced semiconductors.

Just over one year later, on October 17, 2023, BIS released two new rules related to exports of semiconductors to China with an effective date of November 17. (Note that in an SEC filing released on October 24, 2023, Nvidia stated that it was informed by the U.S. government that the licensing requirements under the new rules are effective immediately as applied to certain Nvidia products.) The new rules are presented as an update to last year’s measures, but would perhaps be more accurately described as a comprehensive upgrade of the existing controls.

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