The defining geoeconomic regime of 2022-2025. Four sequenced actions across three jurisdictions:
1. 2022-10-07 US BIS — the foundational rule. Item-level controls + end-use rules + Foreign Direct Product extension + US-persons rule. Set the perimeter. 2. 2023-03-31 Japan METI — 23-category export-licensing amendment to the Foreign Exchange Act. Tokyo Electron, Hitachi, Lasertec, Nikon, Canon advanced-node tools. 3. 2023-06-30 Netherlands — national Strategic Goods Decree amendment covering ASML's TWINSCAN NXT:2000i and successor DUV immersion-litho. Closes the EU side of the perimeter. 4. 2023-10-17 US BIS expansion — closes the H800 workaround via "performance density" metric, adds 13 chipmaking-tool ECCNs, pulls 21 additional countries into regional licensing, adds 13 Chinese entities to the Entity List.
Combined coverage: ~85% of the global wafer-fab equipment market under licence-conditioned exports to China. Chinese fabs (SMIC, YMTC, CXMT) lost access to leading-edge tooling and refocused on mature nodes — a meaningful headwind to MCHI's tech-heavy weighting.
Durability
High. Held through the 2024 US political transition. The 2025 US administration has shown no appetite to roll back chip controls; H20 and HBM additions through 2024-25 (separate filings pending) tightened the perimeter further. EUV systems were already blocked from China since 2019 by Dutch policy + US pressure; this regime extended that to advanced DUV.
What to watch
- Subsequent BIS additions (Sep-2024 quantum/biotech, Dec-2024
HBM/equipment, 2025 H20 cycle) — separate IPTM filings pending.
- Japanese / Dutch enforcement statistics: licence-approval
rates for "controlled destinations" are the leading indicator of whether the regime is tightening or relaxing in practice.
- Korean parallel measures: 2024-11-15 Korea outbound-investment
screening (filed) is the capital-flow analogue forming around the same chokepoints.