How to Secure Advanced U.S. Chips
A policy memo arguing the U.S. should close gaps in advanced chip export controls, covering remote cloud access, smuggling, H200 exports and chipmaking equipment, to limit China's frontier AI development.
Research / Sources
IAPS
Policy research on advanced AI security and governance. www.iaps.ai
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Topic Compute & hardware
Date Any time
Cloud Compute: A Policy Escalation Framework
Argues that Washington needs a strategy for Chinese developers renting frontier U.S. AI compute through overseas cloud providers, proposing a policy escalation framework to address national security risks.
Priorities for Frontier AI Policy
A policy agenda for frontier AI, proposing lifecycle oversight including internal models, American AI leadership measures, and national resilience against AI-enabled cyber, bio and distillation threats.
Near-Term Verification Methods for AI Chip Exports
Proposes near-term verification mechanisms, covering end-location, end-user and end-use checks, to help US policymakers enforce AI chip export controls within about a year.
Remote Access Security Act (RASA)
Proposes closing a gap in US export controls so advanced AI chips rented through cloud services remain covered, and recommends broadening the Senate bill's definition of cloud infrastructure.
Assessing Outcomes of H200 Exports to China
Analyses how allowing Nvidia H200 exports to China would boost Chinese frontier AI capabilities and likely military AI use, arguing that end use cannot be controlled.
Export Auditors as Market-Powered Export Enforcement
Proposes BIS-accredited, for-profit export auditors that inspect shipments to detect AI chip diversion, arguing this would scale US export enforcement beyond the agency's own capacity.
Issue Brief: The Stop Stealing Our Chips Act
Explains the Stop Stealing Our Chips Act, a bill that would create a whistleblower reward program to strengthen US enforcement of AI chip export controls against diversion to China.
New BIS Licensing Policy for H200s: Tough Guidelines, Weak Enforcement
Analyses the new BIS licensing policy allowing Nvidia H200 exports to China, arguing its certification limits are subjective, hard to enforce, and could substantially boost China's AI compute.
Accelerating AI Data Center Security
Report argues that AI data centers housing frontier compute are attractive targets for nation-state adversaries and recommends building security into them from the outset, especially for facilities outside the West.
Compute is a Strategic Resource
Argues that compute should be treated as a strategic resource like oil or steel, scarce, controllable and concentrated, with implications for AI governance and competition.
Verification for International AI Governance
Analyses how international AI agreements could be verified, finding data-center regulation verifiable within years using narrow hardware and privacy-preserving computation, while mobile weapons regulation faces severe barriers.
IAPS Researchers React: The US AI Action Plan
IAPS experts review the US AI Action Plan through a national security and AGI-risk lens, praising its goals and identifying gaps and implementation considerations.
A Whistleblower Incentive Program to Enforce U.S. Export Controls
Proposes a whistleblower incentive program modeled on the SEC's to improve enforcement of U.S. export controls on AI chips and other compute-related technology.
Countering AI Chip Smuggling Has Become a National Security Priority: An Updated Playbook for Preventing AI Chip Smuggling to the PRC
Catalogues evidence of large-scale AI chip smuggling into China and recommends policy measures, including a whistleblower program, notification rules, and location verification, to strengthen export-control enforcement.
Location Verification for AI Chips
Proposes adding location verification to AI chips so regulators can enforce export controls, deter smuggling, and verify chip locations after sale, as a compute governance mechanism.
Comment on the Bureau of Industry and Security’s Framework for Artificial Intelligence Diffusion
A policy comment to the US Bureau of Industry and Security recommending how to steer global AI compute and chip diffusion through export controls to preserve American AI leadership.
Response to OSTP RFI on AI Action Plan
IAPS's comment on the US AI Action Plan argues for building trust in American AI through security and reliability standards, securing supply chains, denying adversaries advanced compute, and adaptive frameworks.
AI Chip Smuggling is the Default, not the Exception
Argues that AI chip smuggling is widespread and that the US must strengthen its AI chip export controls, eliminating smuggling as a first step to outcompete China.
Technology to Secure the AI Chip Supply Chain: A Working Paper
Proposes technical mechanisms to track AI chips after export so that controls on dangerous AI capabilities can be targeted and enforced, rather than applied as blanket restrictions.
Response to BIS RFC on Establishment of Reporting Requirements for the Development of Advanced Artificial Intelligence Models and Computing Clusters
IAPS's response to a US BIS proposed rule recommends expanding reporting of frontier AI models and compute clusters to third-party evaluators, civil society, and public bodies, with ad hoc reporting and information sharing.
Are Consumer GPUs a Problem for US Export Controls?
Analyzes how high-end consumer GPUs could let Chinese actors circumvent US AI chip export controls, estimating they could acquire millions and reach significant AI capabilities, and recommends policy and GPU-maker measures.
Spreadsheets vs. Smugglers: Modernizing the BIS for an Era of Tech Rivalry
Argues that Congress should increase funding for the Bureau of Industry and Security so it can enforce export controls on weapons-of-mass-destruction and sensitive technologies amid US-China tech rivalry.
Highlights for Responsible AI from the Biden Administration's FY2025 Budget Proposal
An IAPS brief analyzing three US FY2025 budget allocations for AI, including Commerce, export-control and Energy cybersecurity funding, for their impact on responsible advanced AI development.
Secure, Governable Chips
Proposes on-chip governance: security features on AI chips to mitigate national security risks from dual-use AI while protecting privacy, with concrete U.S. policy recommendations.
Introduction to AI Chip Making in China
A primer on Chinese AI chip manufacturing, covering the semiconductor industry and US export controls, to help forecast China's indigenous AI compute progress under compute governance.
Preventing AI Chip Smuggling to China
Overview of AI chip smuggling into China, its current and future trajectories, and four recommendations for US policymakers to understand and mitigate large-scale smuggling of AI chips.
How Expertise in AI hardware Can Help with AI Governance
A career review arguing that building expertise in AI hardware can help reduce AI risks and improve governance decisions, drawing on compute governance work.
AI Chip Smuggling into China: Potential Paths, Quantities, and Countermeasures
Examines how AI chips could be smuggled into China at scale, estimates likely quantities, and proposes six countermeasures to reduce large-scale export-control evasion.