C4ADS의 조사 결과, 중국 기업들이 트럼프 행정부 시절 수출 규제를 우회하여 수억 달러 규모의 제한된 엔비디아 AI 가속기를 확보하는 방식이 드러났다.
An American nonprofit monitoring organization funded primarily by the U.S. government, C4ADS, has released a report detailing the numerous channels through which American AI accelerators reach China. Paradoxically, while the United States prohibits the sale of advanced AI chips to China, the Chinese Communist Party simultaneously restricts their purchase. Despite these opposing policies, the hardware continues to arrive. The report identifies three primary smuggling avenues: direct acquisitions through research institutions, drop-shipping via other Southeast Asian nations, and purchases routed through nested shell-company structures. Authors note that only explicitly documented chips are counted, suggesting the actual volume of hardware moving across borders is likely far higher. Supporting this, an earlier Epoch AI estimate suggests that roughly a third—and possibly most—of China’s AI compute capacity consists of smuggled GPUs.
Understanding chip logistics requires noting that Nvidia manufactures and packages most of its accelerators at TSMC in Taiwan. Individual chips or complete accelerator units often undergo multiple rounds of testing, sometimes traveling back and forth before reaching a customer’s data center. On the regulatory front, the U.S. bans exports of H100, A100, and Blackwell-family chips to China. Lower-end models like the H20, alongside the higher-performance H200 and AMD’s MI325X, can be traded on a case-by-case basis, with the latter subject to a 25% tariff. Conversely, China officially discourages and restricts the purchase of American AI chips to accelerate domestic alternatives, currently led by Huawei. Nevertheless, multiple reports indicate authorities frequently overlook gray- and black-market imports, with official exceptions granted in 2026 to ByteDance, Alibaba, and Tencent.
The first channel for importing restricted chips quasi-legally involves Chinese universities and research institutions purchasing them directly. These entities reportedly acquire Nvidia GPUs within sprawling multi-vendor contracts, funneled through small regional Chinese integrators. The report notes that some purchasing institutions maintain ties to the CCP, as well as China’s defense and intelligence sectors. Between July 2025 and January 2026, C4ADS tracked 56 chips worth $1.7 million sold through this method. Additionally, a 2024 investigation spanning multiple years of government records revealed $6.48 million in silicon destined for China via academic channels.
The second route, technically legal, relies on drop-shipping potent silicon through Southeast Asian countries such as Vietnam, India, and Malaysia. Analyzing transactions from 2022 to 2025, C4ADS found $13.4 million worth of Nvidia A100, H100/GH100, and AD102-series GPUs routed through these nations in a consistent pattern. Some chips traveled from Taiwan to Vietnam, potentially leveraging Vietnam’s chip-testing facilities as a legitimate cover for transit. Investigators noted that the timing, volume, and destination of many shipments effectively obscure their true purpose. A portion of these purportedly tested chips subsequently moved to Hong Kong, where two firms dominate imports: Profit New Limited and ELB International Limited. In March 2025, Profit New Limited executed a single-day trade of $8.7 million in silicon, likely positioning itself ahead of April 2025’s tightened export controls. Several high-value shipments in the dataset lacked declared cost, insurance, weight, or freight values, and featured suspiciously round zeros in their import declarations, casting doubt on documentation accuracy.
The largest category involves opaque ownership structures centered on shell companies. According to C4ADS, this method facilitated the transfer of $4.6 billion worth of intelligent sand to China, attributed solely to one entity: Megaspeed International. Between 2023 and 2025, Megaspeed operated as the largest Southeast Asian importer of Nvidia hardware. Its ultimate ownership remains unresolved. The firm maintained subsidiaries across Singapore, Indonesia, and Malaysia before being acquired in 2023 by Swiftdata, another Singapore-based company. Prior to that acquisition, Megaspeed was owned by Chinese gaming firm 7Road Holdings. During the transition, major shareholder status temporarily passed to Chinese businesswoman Huang Le, who also serves as a director for a Hong Kong company that purchased transceivers from Megaspeed Indonesia. C4ADS suspects Le may still control Megaspeed, having been listed as its chairwoman at a conference as recently as 2025. The rapid succession of ownership changes, combined with unclear title to Swiftdata itself, raises further questions. Given that Megaspeed reportedly secured export-restricted Blackwell chips, its operations remain highly opaque.
To mitigate these loopholes, C4ADS recommends that the U.S. Bureau of Industry and Security receive additional staffing and resources to verify post-sale destinations and identify end users. Enforcement would likely require unprecedented international cooperation, which could prove difficult amid current geopolitical tensions. In the researchers’ own words, “U.S. and friend-shored semiconductor manufacturers, equipment makers, and distributors should invest in a robust end-user verification system that goes beyond standard restricted-party list screening, incorporating on-the-ground due diligence, corporate ownership tracing, and post-shipment verification.” For the private sector, C4ADS advises integrating geopolitical and risk analysis into corporate frameworks to evaluate whether direct or downstream customers might be reselling hardware to China’s military or intelligence apparatus.