Chip Governance Hardware Could Allow for ‘Flexible’ BIS Licensing Policies, Think Tank Says
Physical mechanisms built into AI hardware could represent a “promising new tool” to help the U.S. better control exports of sensitive technologies, including to China, the Center for a New American Security said in a new report this month.
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These “hardware-enabled mechanisms,” or HEMs, “could help detect and deter AI chip smuggling into China” and allow for “more surgical applications of export restrictions, reducing the risk of a de-Americanization of chip supply chains,” CNAS said.
The think tank added that HEM variants are “widely used” in certain defense and commercial products, including in iPhones, which help ensure unauthorized applications can’t be installed. By embedding “secure components” into AI chips or their related hardware, the U.S. could better place restrictions on their uses and verify compliance with export controls, CNAS said. That echoes some of the group’s findings from earlier this year, when it said the mechanisms could help the Bureau of Industry and Security automatically bar AI chips from being used in ways that violate U.S. export restrictions (see 2401080060).
The new CNAS report further examines the AI-related export control challenges facing the U.S. government and analyzes how HEMs could help export controls be more effective. HEMs that enable location verification, for example, could show whether a chip is being smuggled into China.
Other HEM features could help enforce limits on “particular use cases, like large-scale training,” CNAS said, or enable reporting on the “quantity of compute consumed or the type of training data used.” This would allow AI developers and users to “rapidly and securely verify compliance with regulations without needing to directly reveal sensitive code or data or spend large amounts of time on manual reporting and verification requirements.”
The report offers several recommendations for policymakers, including one that says BIS should consider new “flexible export licensing regimes” that would grant licenses to companies that use effective HEMs in their chips. BIS could put in place a presumption of approval license review policy for chips exported to the United Arab Emirates, Vietnam and other similar countries of concern as long as they have HEMs with “secure location verification,” CNAS said, while the agency could impose a more restrictive presumption of denial license review policy for chips that don’t have those “verification capabilities.”
But CNAS said industry and government need to do more work to develop those HEMs for sensitive chips before BIS can think about putting in place a new licensing regime. It called on the National Semiconductor Technology Center, the National Institute of Standards and Technology and other government-run organizations to act as “key funders and facilitators of public-private coordination to advance HEM development,” which would help support HEM research “until they are reliable and viable enough to be taken up” by industry. The government would also need to create technical standards for HEMs, CNAS said.
It also stressed that well-designed HEMs won’t allow the government or others to secretly monitor users of AI chips -- they would allow “an external party to verify how the chip is being used without enabling secret surveillance or intellectual property (IP) theft.” CNAS also said some features to “support privacy-preserving HEMs [are] already widely deployed on existing AI chips,” adding that this technology could be developed further to create the type of hardware that can be used for export compliance.
Senior BIS officials earlier this year suggested the government was far-off from relying on HEMs for export compliance and enforcement purposes (see 2403270047).