Tim Fist, Tao Burga and Vivek Chilukuri
Introduction
Advanced artificial intelligence (AI) systems, built and deployed with specialized chips, show vast potential to drive economic growth and scientific progress. However, U.S. policymakers are increasingly concerned about the dual-use potential of AI capabilities. Irresponsible actors could use advanced AI systems to support cyberattacks, biological weapons design, and mass surveillance.6 Securing the supply chain for AI chips is therefore vital for mitigating risks to U.S. national security.
This logic has spurred moves to restrict foreign actors, especially China, from accessing American AI technology. In October 2022, the U.S. Department of Commerce imposed sweeping export restrictions on AI chips and associated hardware to China. These were tightened in October 2023 to address perceived shortcomings but added greater burdens on U.S. firms, including requiring permission to export certain consumer graphics processing units (GPUs) and extending an export license requirement to dozens of additional countries suspected of diverting AI chips to China.7 Recently, the controls were expanded again, this time affecting all chips using advanced high-bandwidth memory.8 Now, concerns about China’s rapid catch-up to U.S. AI capabilities are prompting U.S. policymakers to consider further export restrictions, such as:9
- Further expanding the use of the Foreign Direct Product Rule, a sweeping regulation to prevent companies abroad from selling products using American components, tools, and software to Chinese chipmaking companies10
- Limiting China’s access to U.S. cloud computing services through the bipartisan Remote Access Security Act11
- Further expanding the applicable scope of “deemed exports,” which restrict the transfer of technology or source code to foreign nationals who are in the United States12
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