Following this announcement, the new controls aim to simultaneously restrict exports to certain countries while also establishing a framework to support the diffusion and supply of certain AI model weights and advanced computing ICs to allied countries. The IFR was developed in order to enhance the US government’s visibility into the targeted transactions, including through the modification of earlier rules introduced to control exports of and investments abroad in AI technology and advanced computing ICs.
In the process of issuing the IFR, BIS explained that the controls are necessary in order to offer secure ecosystems for the responsible diffusion and use of artificial intelligence and advanced computing ICs, while protecting US national security as well.
The IFR became effective January 13, 2025, though a couple of provisions have a delayed compliance date of up to a year, and it includes a savings clause that allows exports, re-exports, and transfers (in-country) of hardware, software, or technology subject to a license requirement or restriction under the IFR. This process has already been en route on board a carrier under a pre-existing license exception on May 15, 2025, and completed by June 16, 2025. The IFR also expands existing controls on advanced computing ICs maintained under Export Control Classification Numbers 3A090.a and 4A090.a, while also corresponding .z items and introducing a more stringent review policy for license applications to authorise exports of such items.
The IFR is set to expand the advanced computing foreign direct product rule for articles classified under ECCN 3A090.a and 4A090.a and corresponding .z items to apply to exports around the world. This change will remove the exception for this foreign direct product rule for exports, re-exports, and transfers (in-country) from or in regions in Country Groups A:5 and A:6.
In addition to License Exception AIA, the IFR will introduce two new license exceptions in order to facilitate the new framework for exports, re-exports, and transfers (in-country) of advanced computing ICs, as well as to expand the scope of existing License Exception Advanced Computing Authorized (ACA), and to update the information required to qualify for License Exception Notified Advanced Compute (NAC).
Furthermore, the IFR is expected to introduce new export controls that impose a global license requirement on certain unpublished model weights of the most advanced AI models, the diffusion of which could present national security concerns to the US.
The IFR will also amend the Data Center Validated End User (VEU) authorisation created in October 2024 by creating two types of validated end-user authorisations: Universal VEUs (companies that are relying on the Universal VEU will be subject to restrictions on where the AI computing power may be allocated) and National VEUs (companies that are relying on the National VEU authorisation would likewise be subject to several limitations on the installed base allocation of computing power).
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