Export-Control Reversal Disclosure Record

PROBLEM: U.S. AI-chip export controls have reversed direction repeatedly since they began in October 2022: a worldwide license requirement in January 2025, an H20 license requirement in April 2025, H20 licenses with a 15% revenue expectation in August 2025, an H200 announcement with a 25% term in December 2025, and a move to case-by-case review in January 2026. Each reversal changed what was legal to sell and on what terms. There is no disclosure record of the reversals themselves — what changed, when, and what it meant for licenses already granted.

SOLUTION: An export-control reversal disclosure record: every policy reversal logged with the prior rule, the new rule, the effective date, and the treatment of licenses granted under the old rule — so companies and reviewers can see the direction of travel, not just the rule of the day.

EVIDENCE BASIS: DOCUMENTED — the dated events: AI Diffusion rule Jan 15, 2025 (Nvidia 8-K); H20 license requirement Apr 2025; H20 licenses Aug 2025 with 15% expectation (Nvidia 10-Q, no regulation codified); Dec 8, 2025 H200 announcement with 25% term (Reuters); BIS FR Doc. 2026-00789, Jan 15, 2026 (case-by-case review).