Explainer: The Commerce Department's October 2023 Export Control Update

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CSET Georgetown·cset.georgetown.edu/article/bis-2023-update-explainer/

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Relevant for understanding how U.S. export control policy intersects with AI safety and governance, particularly efforts to restrict adversarial access to frontier AI compute resources.

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Importance: 58/100organizational reportanalysis

Summary

This CSET explainer breaks down the Bureau of Industry and Security's (BIS) 2023 updates to U.S. export control regulations, focusing on new restrictions on advanced semiconductors, AI chips, and related technologies. It analyzes how these rules affect the flow of compute resources to adversarial nations, particularly China. The piece contextualizes the policy significance for AI development and national security.

Key Points

•BIS expanded export controls on advanced AI chips and semiconductor manufacturing equipment to limit China's access to cutting-edge compute.
•The 2023 update tightened loopholes from the October 2022 rules, addressing workarounds used to circumvent earlier restrictions.
•Controls target a broader range of countries and close gaps related to cloud computing access to restricted chips.
•The rules reflect U.S. strategy to maintain AI leadership by constraining adversaries' ability to train frontier AI models.
•CSET provides accessible analysis of complex regulatory language to help policymakers and researchers understand practical implications.

1 FactBase fact citing this source

Entity	Property	Value	As Of
Georgetown CSET	publication	A Bigger Yard, A Higher Fence (Dec 2023) — analyzes expanded US export controls on advanced computing chips, examining 100+ relevant chips	Dec 2023

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Explainer: The Commerce Department's October 2023 Export Control Update 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

 
 
 
 
 

 
 
 
 
 
 

 
 
 

 
 

 
 
 
 
 
 

 
 
 
 
 
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 CSET 

 A Bigger Yard, A Higher Fence: Understanding BIS&#8217;s Expanded Controls on Advanced Computing Exports

 
 
 Hanna Dohmen

 and Jacob Feldgoise

 
 December 4, 2023 
 
 On October 17, 2023, the Bureau of Industry and Security (BIS) issued an update to last year’s export controls on advanced computing, supercomputing and semiconductor manufacturing equipment. This blog post provides an overview of the updated advanced computing controls, analyzes more than 100 relevant chips, and discusses the licensing policies for the expanded chip restrictions and the increased country scope.

 
 

 

 
 
 
 
 On October 17, 2023, the Bureau of Industry and Security (BIS) at the U.S. Department of Commerce issued highly complex and extensive updates to the October 7, 2022, export controls restricting U.S. exports of advanced chips and semiconductor manufacturing equipment (SME) . These export control updates are intended to stay up-to-date with technological developments of AI systems and manufacturing of advanced chips, as well as address gaps in the October 7, 2022, controls that became apparent over the last year. 

 These latest controls are designed to more effectively advance the Biden administration’s stated objectives of blunting China’s military modernization and maintaining U.S. military leadership. More specifically, the aim of the controls is to limit China’s ability to use large-scale AI systems to develop weapons of mass destruction (WMD) and advanced conventional weapons by restricting access to the advanced chips needed to train frontier AI models and the SME necessary for the production of these chips. According to BIS , the agency is specifically concerned about chips that can be used to “train frontier AI models that have the most significant potential for advanced warfare applications, including unmanned intelligent combat systems, enhanced battlefield situational awareness and decision making, multidomain operations, automatic target recognition, autopiloting, missile fusion, precise guidance for hypersonic platforms, and cyber attacks.” With these updates, BIS expects that a “bigger yard” and a “higher fence”—controlling more chips and to more destinations—will be able to achieve these objectives more effectively.

 In this blog post, we aim to provide an overview of the updated export controls on advanced computing. 1 First, we address which chips are controlled by analyzing over 100 relevant chips. Then, we address which destinations are controlled for these chips. Lastly, we discuss an important and new “red flag” guidance and how this may affect foundries making chips for Chinese semiconductor companies.

 A Bigger Yard: More Chips Restricted

 To comply with the October 7, 2022, con

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