A new CSIS analysis examines the legal authority U.S. allies currently hold to implement export controls on artificial intelligence and semiconductors. The Center for Strategic and International Studies, a Washington-based think tank, published the report as Washington pushes partners to align their national rules with American restrictions on advanced chips and chipmaking tools.

The report addresses a structural problem in U.S. export control policy. The United States can restrict exports of American-made technology directly. It cannot, however, order allied governments to restrict sales by their own domestic firms. That authority rests with each national government and depends on each country's own legal framework.

Why does allied legal authority matter?

Advanced semiconductor supply chains span several jurisdictions. Leading chipmaking equipment comes from suppliers in the Netherlands, Japan and the United States. Lithography, deposition and etch tools from these three countries dominate the equipment market for advanced process nodes. Unilateral U.S. controls cover only the American share of that supply.

The effectiveness of any control regime therefore depends on whether allied governments adopt parallel restrictions under their own laws. CSIS sets out what authority those governments hold today and where gaps remain between American rules and allied statutes.

The analysis lands at a moment of sustained friction over China's access to advanced computing hardware. The United States has tightened restrictions on AI accelerators and semiconductor manufacturing equipment over successive rounds of rules. Each round has raised the same question abroad: can allies act quickly, and within their existing legal systems, to match the measures?

What does the report cover?

The CSIS publication examines the current legal basis for allied implementation of AI and semiconductor export controls. Its scope includes:

• The statutory and regulatory authority allied governments hold to impose export controls today
• The alignment, or misalignment, between U.S. control lists and allied national control regimes
• Constraints that allied legal frameworks place on rapid adoption of new restrictions
• Implications for the coherence of the broader multilateral control effort

The report's central concern is implementation rather than intent. Allied governments may share U.S. policy goals yet lack a ready legal pathway to enforce equivalent restrictions at the same speed.

What is the commercial picture?

For equipment makers and chip suppliers, the legal question is a market question. Firms headquartered in allied countries face different licensing regimes depending on how far their governments have gone in matching U.S. rules. Divergent rules create arbitrage risk and compliance cost. They also determine how tightly the combined restrictions bind China's access to advanced tools and AI hardware.

CSIS argues, in effect, that the control regime's strength equals its weakest national legal link. A gap in one ally's authority can leave a supply route open that U.S. rules aim to close.

The report is analytical rather than legislative. It does not itself change any rule. It gives policymakers and industry a map of where allied law already supports export controls and where new legislation or regulation would be required.

What comes next?

The findings suggest the pace of allied implementation will depend less on political agreement than on the mechanics of national legal systems. Companies exporting chipmaking equipment and AI accelerators should expect continued divergence between U.S. and allied control lists as each government works within its own statutory limits. CSIS's analysis implies that closing those gaps will require domestic legal action in allied capitals, not further directives from Washington.