Comment by Linda Moore

Countries such as Brazil, India, Israel, Iceland, Saudi Arabia, and the UAE — classified as middle-tier under the rule — have both the resources and the motivation to invest in computing ecosystems outside U.S. influence. As a result, China and other restricted nations could source these technologies from non-U.S. producers, diminishing the rule’s effectiveness. Instead, we encourage the administration to consider enhanced government-to-government security agreements that allow countries more compute access, keeping American companies competitive while ensuring security concerns are addressed. Export controls on semiconductors should not be a unilateral effort. The administration must work with a broader group of allies beyond the tier-one countries designated in the rule. A coordinated strategy for AI regulation and chip export controls is essential to securing semiconductor supply chains and maintaining national security. The challenges of compliance gaps between the U.S. and its allies during previous restrictions highlight the risks of acting alone.