Summary of Key Points from the Industry Guidance on Advanced Computing Integrated Circuits Industry or Company Involved - The guidance pertains to the **advanced computing integrated circuits (ICs)** industry, specifically focusing on export controls and diversion schemes related to these ICs, particularly in the context of the **People's Republic of China (PRC)** and Macau [1][8]. Core Points and Arguments - **Export Restrictions**: The Bureau of Industry and Security (BIS) has implemented export restrictions on advanced computing ICs since October 2022 due to their potential military applications, including weapons of mass destruction (WMD) [1][8]. - **Military Modernization**: Advanced computing ICs are being utilized by China for military modernization, enhancing decision-making, planning, logistics, and autonomous military systems [1][2]. - **Diversion Schemes**: BIS has identified various diversion schemes where advanced computing ICs are acquired through transshipment and diversion, necessitating increased vigilance from companies [1][2]. - **Red Flags for Transactions**: A list of transactional and behavioral red flags has been provided to help companies identify potential export control evasion related to advanced computing ICs [2][5]. - **Due Diligence Actions**: Companies are advised to conduct due diligence on new customers and evaluate Infrastructure as a Service (IaaS) providers to ensure compliance with export regulations [6][12]. Important but Possibly Overlooked Content - **Catch-All Controls**: BIS is identifying catch-all controls that may apply to advanced computing ICs used for training AI models, emphasizing the need for companies to be aware of potential military-intelligence end uses [2][8]. - **Best Practices for Due Diligence**: Companies are encouraged to implement best practices for due diligence, including verifying customer information, assessing the end use of items, and ensuring compliance with the Export Administration Regulations (EAR) [12][13]. - **Infrastructure Requirements**: Data centers receiving advanced computing ICs must have the necessary infrastructure to operate these items, and companies should confirm this capability through written attestations [7][12]. - **Knowledge of Violations**: Exporters must not proceed with transactions if they have knowledge of potential violations of the EAR, which includes awareness of the end use of the items [10][11]. This summary encapsulates the critical aspects of the guidance provided by BIS regarding advanced computing ICs, highlighting the importance of compliance and vigilance in the face of potential diversion schemes and military applications.