New U.S. restrictions on exports of advanced AI technologies

On 13 January 2025, the U.S. administration announced a significant update of export control regulations for advanced artificial intelligence (AI) technologies, intensifying restrictions on products of high strategic value. The measure aims to limit the ability of adversary countries, such as China and Russia, to access advanced chips that could enhance military, surveillance, and large-scale data processing capabilities.

Details of the new control regime

The new U.S. regulatory framework aims to drastically limit the transfer of critical technologies to countries considered risky for national security, particularly China. The new regulations consist of six main points, each with a significant impact on global technology companies:

• Restrictions on advanced semiconductors: the new rules prohibit the export of chips with high data processing capabilities intended for training artificial intelligence models and advanced applications, such as deep learning. These semiconductors, crucial for the development of supercomputers and AI infrastructures, represent a strategic sector in which the US intends to maintain a leading position.
• Control over chip design software: in addition to semiconductors, control extends to the specialised software needed to design and manufacture advanced chips. These tools are essential for making next-generation integrated circuits and their access by third countries will be restricted through a strict authorisation system.
• Export Restrictions on Semiconductor Manufacturing Equipment: American companies producing advanced chip-making machinery will not be able to sell this equipment to companies located in countries subject to the restrictions unless specific authorisation is granted. This intervention is intended to hinder the independent development of advanced technologies in countries such as China.
• Indirect export control: the rules include a clause to prevent the circumvention of restrictions through third countries. In particular, any export of critical technologies to countries considered to be partners of restricted nations will be subject to careful evaluation, reducing the risk of trade triangulations.
• Obligation of prior notifications: U.S. companies will be required to notify in advance any transaction involving products or technologies subject to the new rules. This obligation allows the Department of Commerce to monitor trade in sensitive technologies in real time and intervene in the event of potential violations.
• Extension of the control regime to specific entities: finally, the updated regulations include new Chinese entities on the export control list. The listed companies will be subject to additional restrictions, preventing them from accessing US technology products and services without express prior authorisation.