On May 31, 2026, BIS issued guidance clarifying that the November 2023 license requirement for advanced computing items (ECCNs 3A090, 4A090, and related items) destined for entities headquartered in Country Group D:5 or Macau, or whose ultimate parent is headquartered there, continues to apply regardless of where those entities are physically located. This requirement predates and is separate from the AI Diffusion Rule, meaning BIS's May 2025 non-enforcement policy on the Diffusion Rule's destination-based requirements does not extend to these entity-based controls. For financial institutions, this narrows a previously ambiguous gap: transactions involving D:5/Macau-parented entities operating through third-country subsidiaries or data centers remain subject to active license enforcement, a material compliance consideration for clients with global AI infrastructure supply chains.
285 other tracked developments touching the same claims.