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Where the Chips Fall: U.S. Export Controls Under the Biden Administration (2022–2024)

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Credibility Rating

4/5
High(4)

High quality. Established institution or organization with editorial oversight and accountability.

Rating inherited from publication venue: CSIS

Relevant to AI safety discussions around compute governance and hardware controls as a lever for managing advanced AI development risks; provides detailed policy background on U.S.-China semiconductor competition.

Metadata

Importance: 62/100organizational reportanalysis

Summary

This CSIS analysis examines the Biden administration's semiconductor export control policies from 2022 to 2024, assessing their strategic rationale, implementation challenges, and geopolitical implications. It evaluates how restrictions on advanced chips and chipmaking equipment aimed to limit China's access to cutting-edge AI and military computing capabilities. The report provides a comprehensive review of the policy landscape and its effectiveness in achieving national security objectives.

Key Points

  • Documents the evolution of U.S. semiconductor export controls from the October 2022 rules through subsequent updates, targeting advanced AI chips and chipmaking equipment.
  • Analyzes the strategic goal of preventing China from acquiring compute resources necessary for frontier AI development and advanced military applications.
  • Examines implementation challenges including enforcement gaps, allied coordination difficulties, and circumvention risks through third-country intermediaries.
  • Assesses the economic trade-offs for U.S. semiconductor companies against national security benefits of restricting Chinese access to advanced compute.
  • Evaluates the broader geopolitical context, including allied responses from the Netherlands and Japan, and China's efforts to develop indigenous semiconductor capabilities.

Cited by 1 page

PageTypeQuality
US AI Chip Export ControlsPolicy73.0

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# Where the Chips Fall: U.S. Export Controls Under the Biden Administration from 2022 to 2024

![Photo: Wong Yu Liang/GETTY IMAGES](https://csis-website-prod.s3.amazonaws.com/s3fs-public/styles/500_x_300/s3/2024-12/GettyImages-1413577536_cropped.jpg?VersionId=_ZjupzGONXPe6kyp1.zERzpGCicgzLRC&h=47ea0187&itok=8xwRKuqj)

Photo: Wong Yu Liang/GETTY IMAGES

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Commentary
by
Barath Harithas and
Andreas Schumacher

Published December 12, 2024

#### **Introduction**

This piece offers a practical guide to navigating the thicket of U.S. export controls on China from 2022 to 2024. The shifting rules and continuous churn of updates have left observers grasping for stable ground. Moreover, where they exist, explanations are often buried in technical minutiae.

By cutting through the opacity, this paper provides a clear account of the motivations driving U.S. actions, gaps in enforcement, as well as the action-reaction dynamic between the U.S. and China.

In [September 2022](https://www.whitehouse.gov/briefing-room/speeches-remarks/2022/09/16/remarks-by-national-security-advisor-jake-sullivan-at-the-special-competitive-studies-project-global-emerging-technologies-summit/), National Security Advisor Jake Sullivan declared that securing “as large a lead as possible” in force multiplier technologies like AI was a national security imperative. This charge was led by the implementation of export controls. Far from a blunt instrument to hamper China’s immediate progress, they were engineered to degrade its AI capabilities over time.

#### **September 2022 Export Controls: Strangling with Intent**

The 2022 export controls were a calculated exercise in brinkmanship designed to throttle China’s AI ambitions. Recognizing the escalating computational [demands](https://epoch.ai/blog/training-compute-of-frontier-ai-models-grows-by-4-5x-per-year#leading-companies-are-growing-their-top-models-by-5xyear) of frontier AI, reliant on thousands of the most advanced microprocessors and memory chips, the United States moved to weaponize its dominance over [critical chok

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