New Year, New BIS Standards to Safeguard U.S. National Security

The end of 2022 brought good news for those working to keep Americans safe from Chinese tech threats: the federal government banned TikTok on federal government devices, and several state governments did the same. Most importantly, the Bureau of Industry and Security (BIS) added Yangtze Memory Technologies (YMTC) and 35 other Chinese entities to the Entity List, depriving them of American technologies that will almost find their way into the hands of the Chinese military. This major listing isn’t just a needed national security action – it sets a new standard for how BIS should approach Chinese tech companies. There is no doubt Under Secretary Alan Estevez and his team put loads of work into the process, and learned lessons… Read More


Is Commerce Getting Played By The Chinese Government On Export Controls?

China Tech Threat Co-Founder Dr. Roslyn Layton issued the below statement following the U.S. Commerce Department’s announcement today that YMTC, a state-backed chip maker with close ties to the People’s Liberation Army (PLA), has been added to the Entity List, along with several other Chinese companies.  “The Commerce Department passed the 60-day window it set for itself to determine if PRC national champion chipmaker YMTC should be moved from the Unverified List to the Entity List. Its October 7 Export Control announcement seemed to signal a new era of enforcement at Commerce’s Bureau of Industry and Security (BIS), but praising ‘better behavior’ and ‘changes in attitude’ from China is not a strategy that will protect America’s national and economic security, especially given the Chinese… Read More

BIS is on the Clock: Experts Assess Export Controls, Effectiveness with Regard to China

We have 7 DAYS left in the BIS Countdown that started on October 7 when the Bureau issued long-awaited export controls targeting Chinese chipmakers. Will YMTC, a national champion chipmaker, and others on the Unverified List (UVL) allow for and pass end-use checks, or will they get put on the Entity List? That’s one of our big questions. Earlier this month, Roslyn Layton hosted a virtual event to dive into the new export controls and related issues with Nazak Nikakhtar (Partner and National Security Co-Chair, Wiley; former Department of Commerce Lead on CFIUS) and Dustin Carmack (Research Fellow, Heritage Foundation). They discussed the impact of the controls on China’s semiconductor capabilities, the Apple-YMTC relationship, and how the new Congress should… Read More

New CTT Memo on Export Controls: “Five Areas to Watch During This Critical 60 Day Window”

On October 27, China Tech Threat released a new memo calling attention to five priority areas worthy of attention in the wake of the Department of Commerce’s new China-focused export controls issued on October 7. The new set of rules have been described as “wreaking havoc on China’s chip industry” and “strangling with intent to kill.” But it’s hard to gauge their full impact after only three weeks. Alan Estevez, the Under Secretary of the Bureau of Industry and Security, has said “we are not done” on focusing on the Chinese semiconductor sector. We’re now 20 days into an important 60 day window that will mark a critical time for analysts, reporters, and industry observers to assess how serious the… Read More

Bipartisan Group of Senators Urges U.S. Intelligence Community to Investigate YMTC’s Risks to National Security

Last week Senators John Cornyn, Marco Rubio, Charles Schumer, and Mark Warner sent a letter to Director of Intelligence Avril Hanes warning about the national security threat of Chinese memory chip maker YMTC and its impending partnership with Apple. Seizing on the growing awareness that Apple is preparing to put YMTC chips in the iPhone 14, the Senators noted that, “Such a decision would introduce significant privacy and security vulnerabilities to the global digital supply chain that Apple helps shape given YMTC’s extensive, but often opaque, ties to the Chinese Communist Party (CCP) and concerning PRC-backed entities.” This letter is especially timely in light of recent congressional efforts to support the American semiconductor industry through the CHIPS Act. Spending billions… Read More

Commerce Department Reportedly Focused on SMIC, But What About YMTC and CXMT?

Reuters reports that the Commerce Department is considering banning exports of chipmaking tools to Chinese factories that make advanced semiconductors at the 14 nanometer node and smaller. This would significantly impact the ability of Chinese military-linked chipmaker SMIC from making the most advanced chips. The threat of SMIC is already clear. In a widely covered report provided to federal officials, James Mulvenon and his SOSI colleagues determined that SMIC – the largest and most sophisticated Chinese government-owned semiconductor maker – has multiple close ties to the People’s Liberation Army (PLA). Specifically, PLA researchers use SMIC chips and processes, indicating it is tailored for their purposes. For example, radiation hardening – which is used for military and space purposes – employ… Read More

Estevez Senate Hearing: Mixed Messages on YMTC Continue

Bureau of Industry and Security (BIS) Under Secretary Alan Estevez testified to the Senate Banking Committee on Thursday about issues related to U.S. Export Controls. There is still no clarity what the U.S. government’s stance is on Chinese military-linked chipmaker YMTC. Senator Mark Warner of Virginia told Estevez that American memory chip manufacturers have complained to him about YMTC’s activities, which he said are “typical of a lot of the new Chinese memory and chip-related firms.” That is to say, they are tied to the Chinese military and benefit from massive subsidies designed to kill off foreign competitors. Sen. Warner also noted a recent Financial Times story detailing YMTC’s ties to Huawei, the Chinese telecommunications firm on the Commerce Department’s… Read More

8 Solutions for Mitigating the Threat of an Apple-YMTC Deal

Last week China Tech Threat and the Coalition for a Prosperous America released the report Silicon Sellout: How Apple’s Partnership with Chinese Military Chip Maker YMTC Threatens American National Security. In our first blog post, we detailed Apple’s motivations for doing business with YMTC. Our second post outlined the risks of this partnership. Policymakers inside the U.S. government have multiple options to mitigate the damage from a YMTC-Apple deal. Three of them are most important: 1) Restrict technology exports to and imports from YMTC (Best option) The best, most effective protection of national security restricts U.S. technology exports to and imports from YMTC. This requires three steps: (a) adding YMTC to the Entity List; (b) creating a Foreign Direct Product… Read More

BIS Leader Previews New Civil Penalties for Export Control Violations

The Commerce Department’s Bureau of Industry and Security’s (BIS) Assistant Secretary for Export Enforcement, Matthew Axelrod, sounded all the right notes at a speech to the Society for International Affairs on May 16th. Recognizing that adversaries like Russia and China advance their own interests at the expense of the United States, Axelrod previewed strengthened civil penalties from BIS designed to deter American firms from violating export control laws. The proposed new penalties include: BIS publicly disclosing which companies it investigates for export control violations when a case opens, not when it is resolved, often years later Forcing companies to admit wrongdoing if they are found to have violated export control laws Increasing financial penalties for violations These ideas are welcome… Read More

China Tech Threat Applauds Confirmation of Alan Estevez to Lead BIS

China Tech Threat applauds the confirmation of Alan Estevez to lead the Department of Commerce’s Bureau of Industry and Security (BIS), which is the most important agency most Americans have never heard of. Mr. Estevez brings unprecedented experience to the role with some 30 years in defense, supply chain, and logistics. It has been 5 years since there was a confirmed BIS Director, and 9 months since Mr. Estevez was nominated. The clock has been ticking, and as Mira Ricardel, former Deputy National Security Advisor and BIS Under Secretary for Export Administration, told us, “The only parties that benefit from a lack of senior leadership at BIS are our adversaries.” China Tech Threat Co-Founder Roslyn Layton, PhD welcomed the news… Read More