Compliance
The perimeter, measured rather than asserted
Cross-border personal information · 2026
PIPL transfer is a metered threshold, not a ban — so it is metered
80,000block
95,000exemption ends
100,000
Under 《促进和规范数据跨境流动规定》 (2024), a non-CIIO transferring fewer than 100,000 individuals’ non-sensitive personal information in a calendar year is exempt from the standard contract, certification and security assessment alike. Above 1,000,000 a CAC security assessment is required. The counter resets on 1 January and is incremented on first offshore persistence of a natural-person identifier, inside the same transaction as the write.
Sanctions & forced-labour screening
Run before any introduction, re-run while a deal is open
- Inspur Electronic Informationneeds review
Name match against Inspur Electronic Information Industry Co., Ltd.
Matched on "Inspur". Federal Register 2025-05427 names SIX Inspur entities including SZSE 000977 — the operating company that actually sells the servers — all with Footnote 4 and a policy of denial. Footnote 4 reaches foreign-produced items through the FDP rule, so Inspur cannot readily obtain US-derived technology. Buying a finished Inspur server is not itself prohibited, but the vendor’s own supply chain and support are impaired, and defence-adjacent end customers will usually refuse it.
valid to 08 Oct 2026 · pending a human - Cambricon Technologies Corporation Limitedneeds review
Name match against Cambricon Technologies Corporation Limited
Matched on "Cambricon Technologies Corporation Limited". AI accelerator vendor. Listed, and its products are separately caught by the advanced-computing ECCNs, so a corporate clearance would still not make them routable.
valid to 08 Oct 2026 · pending a human - ZTE Corporationneeds review
Name match against ZTE Corporation
Matched on "ZTE Corporation". SZSE 000063 / HKEX 0763, a real rack-server and storage manufacturer at volume. Named in Section 889 and on the FCC Covered List but NOT on the BIS Entity List — its 2016-2018 restrictions were resolved by settlement. The cleanest illustration of why a single sanctioned/not-sanctioned field cannot represent a vendor.
valid to 08 Oct 2026 · pending a human - Huawei Digital Powerneeds review
Name match against Huawei Technologies Co., Ltd.
Matched on "Huawei Technologies Co., Ltd.". Entity Listed with footnote 1, and separately named in Section 889 and on the FCC Covered List. The 889 designation is what bites commercially: US federal agencies and their contractors may not procure or use the equipment, and no supplier documentation cures it. EU and UK public-sector procurement restrictions apply separately.
valid to 08 Oct 2026 · pending a human - Sugon Data Energy (subsidiary of Dawning/Sugon)needs review
Name match against Dawning Information Industry Co., Ltd.
Matched on "Sugon". On the Entity List since June 2019, on the OFAC non-SDN CMIC list (a SECURITIES restriction on US persons — it bars investing, not buying hardware), on the DoD Chinese military companies list, and excluded in SAM for US federal award. Buyers routinely read "OFAC" as an import ban and abandon lawful transactions; the hardware is lawful to buy and unacceptable to a US federal customer.
valid to 08 Oct 2026 · pending a human - Inspurneeds review
Name match against Inspur Electronic Information Industry Co., Ltd.
Matched on "Inspur". Federal Register 2025-05427 names SIX Inspur entities including SZSE 000977 — the operating company that actually sells the servers — all with Footnote 4 and a policy of denial. Footnote 4 reaches foreign-produced items through the FDP rule, so Inspur cannot readily obtain US-derived technology. Buying a finished Inspur server is not itself prohibited, but the vendor’s own supply chain and support are impaired, and defence-adjacent end customers will usually refuse it.
valid to 08 Oct 2026 · pending a human - Sugon DCScience (Dawning Data Infrastructure Innovation Tech)needs review
Name match against Dawning Information Industry Co., Ltd.
Matched on "Sugon". On the Entity List since June 2019, on the OFAC non-SDN CMIC list (a SECURITIES restriction on US persons — it bars investing, not buying hardware), on the DoD Chinese military companies list, and excluded in SAM for US federal award. Buyers routinely read "OFAC" as an import ban and abandon lawful transactions; the hardware is lawful to buy and unacceptable to a US federal customer.
valid to 08 Oct 2026 · pending a human - Huawei Technologiesneeds review
Name match against Huawei Technologies Co., Ltd.
Matched on "Huawei Technologies Co., Ltd.". Entity Listed with footnote 1, and separately named in Section 889 and on the FCC Covered List. The 889 designation is what bites commercially: US federal agencies and their contractors may not procure or use the equipment, and no supplier documentation cures it. EU and UK public-sector procurement restrictions apply separately.
valid to 08 Oct 2026 · pending a human - Inspur Electronic Information Industryneeds review
Name match against Inspur Electronic Information Industry Co., Ltd.
Matched on "Inspur Electronic Information Industry Co., Ltd.". Federal Register 2025-05427 names SIX Inspur entities including SZSE 000977 — the operating company that actually sells the servers — all with Footnote 4 and a policy of denial. Footnote 4 reaches foreign-produced items through the FDP rule, so Inspur cannot readily obtain US-derived technology. Buying a finished Inspur server is not itself prohibited, but the vendor’s own supply chain and support are impaired, and defence-adjacent end customers will usually refuse it.
valid to 08 Oct 2026 · pending a human - Shanghai Biren Technology Co., Ltd.needs review
Name match against Beijing Biren Technology Development Co., Ltd.
Matched on "Biren". AI accelerator vendor.
valid to 08 Oct 2026 · pending a human
Refused by policy
Not what the agent did — what it tried to do and was stopped from doing
- acceptQuotenegotiation.mandateBreachBlocked08 Sep 2026 10:00
Drafted an acceptance of $1,690 at 30 days.
claude-opus-5 · negotiate/2026-09-02
Audit trail
Append-only. Every entry names the actor, and for an agent, its model and prompt version.
| When | Action | Actor | Detail |
|---|---|---|---|
| 08 Sep 2026 10:00 | negotiation.mandateBreachBlocked | claude-opus-5 | Drafted an acceptance of $1,690 at 30 days. |
| 07 Sep 2026 01:00 | quote.extracted | claude-sonnet-5 | Extracted from a 47-second voice note. Held out of ranking pending human confirmation. |
| 05 Sep 2026 12:00 | rfq.created | human | {} |
| 05 Sep 2026 12:00 | rfq.shortlistBuilt | claude-opus-5 | Filtered on HS 8438.10 capability, CE on file, customs registration, and export history ≥ 3 years. |