BIS Opens Narrow Case-by-Case Path for Select AI Chips to China/Macau, While Tightening Verification and Remote-Access Controls
A BIS final rule effective January 15, 2026 creates a conditional case-by-case license review pathway for certain advanced computing semiconductors exported from the United States to end users in China and Macau, replacing a prior presumption of denial for this limited category. The rule pairs extensive certification, third-party U.S. testing, and remote-access safeguards with continued presumption-of-denial treatment for reexports and in-country transfers, alongside a same-day proclamation imposing a 25% duty on certain chips transiting the United States.