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

CTT Quick Cut Wrap Up: Experts Assess Implications of Export Controls for YMTC, Apple

The U.S. is at a key moment with its China-focused export control policy. On October 7, the Commerce Department issued a slew of new regulations targeting China’s semiconductor industry, triggering a crucial 60-day period when Commerce Department will decide whether to add firms like YMTC and CXMT to the Entity List. Meanwhile, a new Congress looks poised to exert pressure on Commerce to maintain a tough stance, with the potential new chairman of the House Foreign Affairs Committee, Michael McCaul, saying he will be “focused like a laser on export control issues.” And the New York Times wants to know if Apple will permanently step back from a dangerous Apple-YMTC deal, but Apple hasn’t yet commented. On November 15, CTT’s… 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

A Huge Week for American Policies on Chinese Technology, But More Must Be Done

The Bureau of Industry and Security (BIS) made waves last Friday when it announced new (and long-awaited) export controls to restrict the People’s Republic of China’s (PRC’s) ability to both purchase and manufacture certain high-end chips used in military applications. It also put YMTC on the Unverified List and made clear that this action could be a prelude to the Entity List. Multiple commentators have highlighted the significance of these moves. Greg Allen of the Center for Strategic and International Studies (CSIS) described the moves as “an unprecedented degree of U.S. government intervention to not only preserve chokepoint control but also begin a new U.S. policy of actively strangling large segments of the Chinese technology industry—strangling with an intent to… Read More

BIS Explains New China-Focused Export Controls, Entity List Regulations

Last Friday, the Bureau of Industry and Security (BIS) introduced new export controls to restrict the People’s Republic of China’s (PRC) ability to purchase or manufacture certain high-end chips, a move which China Tech Threat applauds. This timely action also includes the addition of 31 China-based companies and institutions, including Yangtze Memory Technologies Corporation (YMTC), which is China’s top memory chip maker and linked to the Chinese military, to the Unverified List. The rules are having an immediate impact. The Wall Street Journal reported yesterday – just under a week later – that American semiconductor manufacturing equipment companies such as KLA Corp and Lam Research are hitting pause on their operations in China and pulling out their staff based at… 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

BIS Can Take Action to Stop China from Surpassing the U.S. in Artificial Intelligence

China Tech Threat’s Future of BIS project recently released a new paper about the need to “Build an AI Workforce at BIS to Strengthen Controls and Stop Illicit Acquisition of American Artificial Intelligence Technologies.” To recap, AI is a critical technology for achieving economic and military advantages. China already spends billions every year to integrate AI components into its weaponry, and Chinese companies like Dahua, Megvii, and Hikvision have built surveillance camera empires around the world. China-based Lenovo also has funded and employs dangerous facial recognition technologies like Face++. The Chinese government will use its AI prowess to entrench authoritarian regimes, capture facial recognition and other data from the world’s citizens, and compromise American liberties and national security. Chinese investment into American companies… Read More

The Future Ruler of the World?

China Tech Threat’s Future of BIS project is out today with a new paper: “Build an AI Workforce at BIS to Strengthen Controls and Stop Illicit Acquisition of American Artificial Intelligence Technologies”. AI – which essentially causes machines to perform human-like functions – is one technology that is poised to live up to the hype. Five years ago Russian President Vladimir Putin said “Whoever becomes the leader in this sphere will become the ruler of the world.” What would make him make such a sweeping statement about something we normally associate with iPhone autocorrect and Netflix recommendations? In a military context, AI has enormous application for intelligence, surveillance, reconnaissance, logistics, command and control capabilities, lethal autonomous weapons systems, and many… 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