The AI Compute Race Glossary Entity List

Entity List

What does “Entity List” mean?

Entity List

An American export list. A sale to a firm on it requires a license, and the affiliates rule extended that requirement to any company the listed firms own half of or more. Chapter 7.

From The AI Compute Race. Read the book

Defined in Chapter 7 — The Double Blockade.

Where the book uses it

  • Chapter 7 — The Double Blockade

    Two governments deciding one trade: Washington’s export rules and Beijing’s instructions at the border, and what each did to the chip business it meant to shape.

Sources that use it

  • Henry Farrell and Abraham Newman, Underground Empire: How America Weaponized the World Economy (Henry Holt, 2023) (the authors’ own interview with Kevin Wolf, assistant secretary of Commerce for export administration 2010–2017, on the 2020 foreign-direct-product rule: it reached “trillions of dollars of transactions, trillions with a ‘T’,” “buried in 9 point font in a footnote at the bottom of a 320 page Entity List,” pp. 99–101 and the note at p. 236; the authors’ own reading of the rule as turning American intellectual property into “a global equivalent of the dollar clearing system”; the book is the primary for Wolf’s words and for the authors’ analogy, and for nothing else this book cites) In the Sources
  • Bureau of Industry and Security, “Addition of Entities to the Entity List, Revision of Entry on the Entity List, and Removal of Entities From the Entity List,” 85 Fed. Reg. 83416, 22 December 2020 (SMIC added to the Entity List: “Items uniquely required to produce semiconductors at advanced technology nodes 10 nanometers or below will be subject to a presumption of denial”; the first rule written against the node, two years before the rules of October 2022; the rule is dated effective 18 December 2020 (FR Doc. 2020-28031, filed that day); 22 December is its publication in the Federal Register). In the Sources
  • Bureau of Industry and Security, Department of Commerce, "Addition of Huawei Non-U.S. Affiliates to the Entity List, the Removal of Temporary General License, and Amendments to General Prohibition Three (Foreign-Produced Direct Product Rule)," final rule, 85 FR 51596–51629, Federal Register of 20 August 2020, FR Doc 2020-18213, effective 17 August 2020 (the widening of the May 15 rule, p. 51600: a license requirement on foreign-produced items that are the direct product of certain U.S. technology or software, or made by a plant that is, when "Huawei or its listed non-U.S. affiliates is a party to any transaction involving the foreign-produced item, e.g., as a ``purchaser,'' ``intermediate consignee,'' ``ultimate consignee,'' or ``end-user.''"). In the Sources
  • Bureau of Industry and Security, Department of Commerce, "Export Administration Regulations: Amendments to General Prohibition Three (Foreign-Produced Direct Product Rule) and the Entity List," interim final rule, 85 FR 29849–29863, Federal Register of 19 May 2020, FR Doc 2020-10856, effective 15 May 2020 (the control reaches a foreign-produced item made to a design produced or developed by an entity with a footnote 1 designation on the Entity List, applied to Huawei and its listed non-U.S. affiliates, p. 29850: an integrated circuit made abroad with equipment that is itself a direct product of listed U.S. technology or software, where "the design for the integrated circuit was produced or developed from ``software'' or ``technology'' by an entity specified in footnote 1 to the Entity List", "is subject to the EAR"). In the Sources
  • Bureau of Industry and Security, Department of Commerce, “Implementation of Additional Export Controls: Certain Advanced Computing and Semiconductor Manufacturing Items; Supercomputer and Semiconductor End Use; Entity List Modification,” interim final rule, 87 FR 62186, 13 October 2022 (new ECCN 3A090, effective 7 October 2022, at 87 FR 62211: integrated circuits with “an aggregate bidirectional transfer rate over all inputs and outputs of 600 Gbyte/s or more to or from integrated circuits other than volatile memories, and any of the following”, the first being processor units “having a bit length per operation multiplied by processing performance measured in TOPS, aggregated over all processor units, of 4800 or more”; both tests had to be met). In the Sources

And 6 more: search the Sources.

Related terms

From the glossary of The AI Compute Race.

How to cite this page

Dryburgh, Lee S. “Entity List.” In The AI Compute Race. DRYBURGH. https://dryburgh.com/vol1/glossary/entity-list (accessed 2026-11-01).

BibTeX

@misc{dryburgh-entity-list-2026,
  author = {Dryburgh, Lee S.},
  title = {{Entity List}},
  howpublished = {In \emph{The AI Compute Race}, DRYBURGH},
  year = {2026},
  url = {https://dryburgh.com/vol1/glossary/entity-list},
  note = {Accessed 2026-11-01}
}

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