If the US is serious about outcompeting China in AI, it needs to strengthen, not weaken, its AI chip export regime. A crucial first step is eliminating the widespread occurrence of AI chip smuggling.
> can you point me to where in the doc this is claimed? I can't find it
It's a little ambiguous in that source, but implied by: "Right now, we have ECO [= Export Control Officer] positions located in seven places around the world, in Beijing, Hong Kong, Frankfurt, Singapore, Istanbul, New Delhi, and Dubai. I’m excited to share that we’re now adding two more ECO positions, one in Helsinki and the other in Taiwan."
I know from private channels that Singapore was not one of the places with two ECOs, at least as of last year. An ECO is just a single person, usually working with a local assistant.
> This also doesn't mention China using datacenters in e.g. Malaysia to get around controls, or how feasible this is.
Yes, that's another important way the controls are circumvented. I don't cover it here since it's not smuggling. It also seems somewhat better than smuggling since, if the GPUs are in Malaysia, say, it should at least be possible for BIS to locate and confiscate those and maybe penalize the nominal owner/operator, which would not be the case if the GPUs were smuggled into China.
> Is there an estimate anywhere for the number of legit purchased H800s in China?
I'm unfortunately not aware of any such estimates, but would love to see them if you find any.
That makes sense, thanks. But ECOs are physically located in the assigned country—are there not also other officers supporting work in that country based in the US?
Ah, I don't know exactly where the threshold is for considering people responsible for a thing or to be assigned to that thing. But yes, ECOs definitely get some non-zero assistance from BIS colleagues in DC, and also from State Department employees located in the countries where they work. Still my impression is that that assistance is pretty limited and the ECO ends up needing to do a lot of stuff, e.g., I think all the in-person inspections in a region will be done by the responsible ECO.
Great article! Some feedback:
> BIS has only one export control officer responsible for investigations
can you point me to where in the doc this is claimed? I can't find it
This also doesn't mention China using datacenters in e.g. Malaysia to get around controls, or how feasible this is.
Is there an estimate anywhere for the number of legit purchased H800s in China?
Thanks Herbie!
> can you point me to where in the doc this is claimed? I can't find it
It's a little ambiguous in that source, but implied by: "Right now, we have ECO [= Export Control Officer] positions located in seven places around the world, in Beijing, Hong Kong, Frankfurt, Singapore, Istanbul, New Delhi, and Dubai. I’m excited to share that we’re now adding two more ECO positions, one in Helsinki and the other in Taiwan."
The recent Blumenthal report says roughly the same thing (https://www.hsgac.senate.gov/wp-content/uploads/The-U.S.-Technology-Fueling-Russias-War-in-Ukraine-Examing-BISs-Enforcement-of-Semiconductor-Export-Controls.pdf): "BIS has one analyst in Canada and 11 ECOs in 9 countries around the world: (1) Germany, (2) United Arab Emirates, (3) Finland, (4) Taiwan, (5) Turkey, (6) Singapore, (7) Hong Kong, (8) China, and (9) India. Each ECO carries out export control checks in their assigned country and area of responsibility (AOR)."
I know from private channels that Singapore was not one of the places with two ECOs, at least as of last year. An ECO is just a single person, usually working with a local assistant.
> This also doesn't mention China using datacenters in e.g. Malaysia to get around controls, or how feasible this is.
Yes, that's another important way the controls are circumvented. I don't cover it here since it's not smuggling. It also seems somewhat better than smuggling since, if the GPUs are in Malaysia, say, it should at least be possible for BIS to locate and confiscate those and maybe penalize the nominal owner/operator, which would not be the case if the GPUs were smuggled into China.
> Is there an estimate anywhere for the number of legit purchased H800s in China?
I'm unfortunately not aware of any such estimates, but would love to see them if you find any.
That makes sense, thanks. But ECOs are physically located in the assigned country—are there not also other officers supporting work in that country based in the US?
Ah, I don't know exactly where the threshold is for considering people responsible for a thing or to be assigned to that thing. But yes, ECOs definitely get some non-zero assistance from BIS colleagues in DC, and also from State Department employees located in the countries where they work. Still my impression is that that assistance is pretty limited and the ECO ends up needing to do a lot of stuff, e.g., I think all the in-person inspections in a region will be done by the responsible ECO.