Summary of Key Points from the BIS Policy Statement on Advanced Computing Integrated Circuits Industry and Company Involvement - The document pertains to the **Bureau of Industry and Security (BIS)** and its regulations regarding **advanced computing integrated circuits (ICs)** and their use in training **AI models** [1][2]. Core Points and Arguments - **Export Authorization Requirement**: Activities involving advanced computing ICs and commodities for training AI models may require export authorization under the **Export Administration Regulations (EAR)**, particularly for end uses related to military-intelligence and weapons of mass destruction (WMD) in **Country Group D:5** countries, including **China** and **Macau** [1]. - **License Triggers**: A license may be required if there is "knowledge" that the AI model will be used for WMD or military-intelligence purposes [2]. - **Definition of Training**: Training AI models involves feeding large data quantities into the model and using optimization algorithms to enhance performance [3]. - **Knowledge Requirement**: Exporters must be aware that their products will be used for training AI models for parties in D:5 countries, which includes restrictions on transactions with **Infrastructure as a Service (IaaS)** providers [4]. - **Consequences of Non-compliance**: Parties failing to obtain prior BIS authorization may face civil or criminal enforcement actions. Additionally, foreign entities that contravene U.S. national security interests may be added to the **Entity List** [5]. - **Prohibition on Transactions**: Transactions cannot proceed if there is knowledge of a potential violation of the EAR. Companies must conduct due diligence to evaluate potential risks associated with their transactions [6]. Other Important Considerations - **Red Flags and Due Diligence**: BIS has provided guidance on identifying transactional and behavioral red flags, emphasizing the importance of due diligence in assessing whether a party may be involved in activities that could trigger a BIS license requirement [6].