Context: Enforceability claim still open before the 2027-12-31 horizon, but the agency itself has now recorded a gap: BIS's FY2025 annual report to Congress says that "in certain areas, there remains a lack of alignment between U.S. controls and those of partners and allies," naming semiconductor manufacturing equipment as a particular concern. The August compute-rental review — into conduct the rules may not reach at all — is the next milestone.