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No AI-chip export policy to China can be “permissive, implementable, enforceable, and protective of US national security” at once.
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.