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Ethics, Compliance and Audit Services

KEY TAKE AWAY

Under revisions to federal export control laws a license may be required for activities involving advanced computing chips, semiconductors, integrated circuits or supercomputers. Contact your Export Control office for review of any:

  • Research, services (e.g. design, testing, analysis) and collaboration related to computing chips, semiconductors, integrated circuits, components (e.g. wafers, etc.) or technology (e.g. designs)
  • Research and services related to supercomputers and supercomputer technology

Background

The United States Department of Commerce published a new export control rule1 that covers advanced semiconductors, computing chips, items containing them, and transactions involving supercomputer and semiconductor end uses. The rule results in new restrictions on exports of items, technology and services. While the new export controls are largely targeted at the People’s Republic of China (“PRC”), the scope and likely impact extend beyond the PRC.

What does this mean?

All research, collaborations and services involving advanced computing chips, semiconductors, integrated circuits and supercomputers, where there is a potential connection in China relating to those subject areas, are likely to be impacted by license requirements or compliance measures under the comprehensive federal rule.

Who should be notified and how should they proceed?

Please distribute this communication to the following offices and individuals:

  • Campus clean room/nanotechnology fabrication facility managers
  • All offices responsible for reviewing agreements, including Procurement Sales and Service, Subawards, Industry Agreements, Contracts & Grants and appropriate Dean’s offices

These offices should identify for review by Export Control offices, any agreements or transactions involving:

  • Advanced computing chips, semiconductors, integrated circuits, supercomputers and technology or services involving those items (including procurement of items or services and exports of items or services), and membership agreements (such as affiliate or partner programs)
  • Activities that are conducted by University nanotechnology fabrication facilities

Please also distribute this communication to departments responsible for international mail and shipping, that may include these items, such as Engineering and Computer Science administrative offices and central shipping locations. International shipments involving these items must be coordinated with Export Control.

For help contact your local Export Control Officer or contact Marci Copeland, Associate Director Systemwide Export Control at marci.copeland@ucop.edu.



1 Bureau of Industry and Security, Dept. of Commerce Interim Final Rule “Implementation of Additional Export Controls: Certain Advanced Computing and Semiconductor Manufacturing Items; Supercomputer and Semiconductor End Use; Entity List Modification,” 87 Federal Register 62186 (10/13/2022)