Policy desk

The designated entities have US assets frozen and are barred from any transactions with US persons, cutting off funding and partnership channels immediately

Models exceeding 2T parameters or 10^26 FLOPS training compute will require export approval, and public open-source releases could be restricted — release strategies must be re-evaluated

Transfers of AI technology, models or related technical materials abroad (including to ASEAN) will require prior export licences, raising deal timelines and compliance costs

Exporting non-public large model, agent, or computing cluster technologies via licensing, sale, or weight delivery requires interim registration with MOFCOM during the transition; in-flight transactions are also covered, with no grandfathering.

Export of large models, AI agents and computing cluster technologies would become restricted, so cross-border licensing, partnerships and deployments need export-control review

Export of model weights, source code, and training methods above the 10^26 FLOPs or 2 trillion parameter thresholds will require approval before release, delaying or blocking cross-border collaborations

Cross-border export or transfer of AI, biopharma or solar technology will require approval, so companies must plan licensing ahead

Chinese companies transferring AI models, algorithms or related technology abroad will face new export licensing requirements.

Companies exporting large model, agent, or computing cluster technologies must complete export licensing or pre-export registration for the 23 AI items

Overseas localised deployment of restricted large models falls under export control and requires a licence (automatic licence available for deployment on overseas self-owned cloud); API calls, SaaS apps and lightweight on-device deployment are outside scope.

Obligations: Companies deploying or selling smart glasses with camera capabilities must ensure compliance with GDPR and local privacy laws, particularly regarding consent and transparency. • Opportunities: There may be increased demand for privacy-enhancing technologies or solutions that address the concerns raised by the investigation. • Deadlines: Companies must ensure their products do not facilitate illegal activities such as unauthorized filming, as enforcement actions can result in significant penalties.

Obligations: AI companies operating in California may be subject to new regulatory requirements, including potential mandatory security audits by independent third parties. • Opportunities: Companies may gain clarity in the regulatory framework for AI safety, potentially reducing uncertainty. • Deadlines: Companies should prepare for the upcoming two-month timeline for the expert panel to submit its recommendations and the subsequent legislative process.

Companies need to assess potential tax obligations for their automation projects.

Obligations: Companies in the electronics manufacturing sector must align their R&D and production strategies with the plan's goals, particularly in developing advanced chips and promoting domestic operating systems.

Tech companies must take higher responsibility, needing to strengthen content moderation and risk control to avoid child harm from negligence• Violations will face high fines, increasing compliance costs and risks• Companies must immediately assess existing systems to ensure compliance with the new regulations after the law takes effect

Obligations: Companies operating AI data centers in Indonesia may be required to contribute to rising electricity tariff costs, potentially increasing operational expenses.