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Last amendment: Trump administration BIS rescinds the AI Diffusion Rule before the 15 May 2025 primary compliance date; replaced with interim guidance, a policy statement, and red-flag enforcement notice. New replacement rule promised but not yet issued. on 2025-05-13.
Base rate computed from analyst-asserted responds_to: edges in the reverse direction (target-country → issuer-country) for prior issuer-actions on the same target. Modal type + lag percentiles only — not a model output. Treat as a historical anchor for sizing counter-response scenarios, not a forecast in itself.
The rule layered three controls on top of the existing trilateral chip-equipment perimeter (2022-10-07 → 2024-12-02):
1. Country-tier framework. Tier 1 (~18 jurisdictions — the Five Eyes, EU members, Japan, Korea, Taiwan, and a few others) gets license-free flows under existing exceptions. Tier 2 (~120 countries — most of the world, including India, Israel, Singapore, the Gulf states, Mexico, Brazil) gets per-country compute caps with two new authorisation pathways: National VEU (country-level allocations awarded by BIS) and Universal VEU (firm-level for trusted cloud / chip providers). Tier 3 — US arms-embargoed destinations — stays at comprehensive denial.
2. ECCN 4E091 — closed-weight model weights. First-ever US export control on AI model weights. Caught any model trained on >10^26 cumulative compute ops with closed weights. Open-weight models (Llama, Mistral, etc.) were carved out. The threshold sat just above frontier 2024-vintage models (GPT-4-class, Claude 3, Gemini Ultra), so the rule reached the leading labs only.
3. Data-centre / end-user controls. Per-country compute caps, plus VEU pathways with firm-level commitments (security plans, end-use monitoring, audit rights). Closed the cloud-export workaround that had let Chinese firms train on US chips in third-country data centres.
would have hard-capped data-centre GPU shipments to ~120 countries. The 13 May rescission removed this exposure but the four-month compliance build-out cost was real.
applicants in waiting. The rescission left them in limbo; the replacement rule is the open question.
Tier 1 status, no direct compliance burden but became conduits for US-aligned compute flows under the design.
Tier 2 destinations that lobbied hard against the rule during the Jan-May 2025 window. UAE and Saudi positioning shifted markedly post-rescission.
is the template the replacement rule is expected to inherit in modified form. Even rescinded, it set the policy frame.
like, and when does it land?
any form, or is the AI-model-weight control vector abandoned?
G42, Saudi data-centre announcements) compare in scope to what would have been Tier-2 VEU allocations?