Useful detail on the registration part. We think this is the stack working in reverse: the control is written at the institution layer, but it takes effect at the infrastructure layer, where the models, agents, and compute clusters actually live. And because it applies to deals already underway, the friction lands immediately rather than at some future compliance date. We made a similar argument in our September essay, The AI Race Isn't Slowing Down. It's Becoming a Global Stack Race: the contest is over infrastructure and institutions, not just models.
This MOFCOM and MOST Announcement No. 48, was issued on OCT 16; but ChangXin Memory stock price (this is the new IPO'd Chinese memory competitor to Micron Hynix etc) collapsed starting Oct. 8! (overall down 25% over the week).
the registration is the part that bites now: it applies from today, including deals already underway, while the list itself is still a draft. moonshot and zhipu earn part of their money from foreign clouds hosting their models (kimi K3 is on amazon bedrock), so the first question for them is whether a hosting deal counts as a technology export. does the annex say anything about that?
Useful detail on the registration part. We think this is the stack working in reverse: the control is written at the institution layer, but it takes effect at the infrastructure layer, where the models, agents, and compute clusters actually live. And because it applies to deals already underway, the friction lands immediately rather than at some future compliance date. We made a similar argument in our September essay, The AI Race Isn't Slowing Down. It's Becoming a Global Stack Race: the contest is over infrastructure and institutions, not just models.
This MOFCOM and MOST Announcement No. 48, was issued on OCT 16; but ChangXin Memory stock price (this is the new IPO'd Chinese memory competitor to Micron Hynix etc) collapsed starting Oct. 8! (overall down 25% over the week).
the registration is the part that bites now: it applies from today, including deals already underway, while the list itself is still a draft. moonshot and zhipu earn part of their money from foreign clouds hosting their models (kimi K3 is on amazon bedrock), so the first question for them is whether a hosting deal counts as a technology export. does the annex say anything about that?