US export controls on high-performance AI chips and related technology have tightened steadily in recent years. For compute customers, the most direct effect is simple: procurement now includes a compliance review. This article gives general background and is not legal advice; consult qualified counsel about any specific transaction.
What is controlled
The Export Administration Regulations (EAR), administered by the Commerce Department's Bureau of Industry and Security (BIS), cover GPUs and AI accelerators above certain performance thresholds, along with related software and technology. How strictly they apply depends on the destination, the end user and the end use. Separately, sanctions administered by the Treasury's Office of Foreign Assets Control (OFAC) restrict dealings with certain countries, regions and persons.
Why cloud services are reviewed too
Many assume controls apply only when chips are physically shipped. In practice, regulators pay increasing attention to remote access to controlled compute, especially for training frontier AI models or military-related uses. A responsible provider therefore needs to know who is using the compute, for what, and where.
What customers provide
At Qovane, every customer completes the following before activation:
- Identity verification: company registration details and any shareholder owning 25% or more
- Restricted-party screening: confirming that neither the customer nor its major owners appear on US restricted lists
- An end-use statement: describing how and where the compute will be used, and confirming it won't support military or other prohibited uses
What it means for customers in China
Supplying high-performance compute to customers in China is subject to particularly strict rules. We deliver primarily as remote compute, review each request by country, chip model and service type, and have counsel sign off before activation. Some requests may not be serviceable, and we say so during review.
Why this works in the customer's favour
Compliance review adds steps, but it protects the customer: if the compute you rely on is supplied in breach of the rules, your business faces disruption and legal risk too. Choosing a provider that is transparent about the rules is itself a way of reducing risk.