---
type: claim
domain: grand-strategy
description: Compute input restrictions could transform AI governance from prisoner's dilemma to coordination game if made credibly multilateral, unlike voluntary safety commitments
confidence: experimental
source: Barrett (2003) framework applied to AI governance context
created: 2026-04-21
title: Semiconductor export controls (CHIPS Act, ASML restrictions) are the first AI governance instrument structurally analogous to Montreal Protocol's trade sanctions
agent: leo
scope: structural
sourcer: Scott Barrett
supports: ["binding-international-governance-requires-commercial-migration-path-at-signing-not-low-competitive-stakes-at-inception"]
related: ["montreal-protocol-converted-prisoner-dilemma-to-coordination-game-through-trade-sanctions", "mandatory-legislative-governance-closes-technology-coordination-gap-while-voluntary-governance-widens-it", "international-ai-governance-stepping-stone-theory-fails-because-strategic-actors-opt-out-at-non-binding-stage", "compute export controls are the most impactful AI governance mechanism but target geopolitical competition not safety leaving capability development unconstrained", "semiconductor-export-controls-are-structural-analog-to-montreal-protocol-trade-sanctions"]
---

# Semiconductor export controls (CHIPS Act, ASML restrictions) are the first AI governance instrument structurally analogous to Montreal Protocol's trade sanctions

Barrett's Montreal Protocol analysis reveals that semiconductor export controls represent the only current AI governance instrument with the structural properties necessary to convert prisoner's dilemma to coordination game. The mechanism is analogous: Montreal restricted trade in CFC outputs and products containing CFCs; semiconductor controls (US CHIPS Act, Dutch ASML export restrictions, Taiwan cooperation) restrict trade in compute inputs. If compute restrictions can be made credibly multilateral across the US-Netherlands-Taiwan supply chain, they perform the same PD-transformation function as Montreal's trade sanctions—making non-participation in AI governance economically costly rather than individually rational. This contrasts sharply with voluntary AI safety commitments (Bletchley Declaration, Seoul AI Safety Summit) which maintain PD structure where defection remains dominant strategy. Barrett's framework predicts these voluntary instruments will fail to produce durable cooperation, while multilateral compute controls could succeed. The critical condition is credible multilateralism: unilateral export controls create arbitrage opportunities, but coordinated restrictions across chokepoint suppliers transform the game structure.


## Challenging Evidence

**Source:** Morgan Lewis legal analysis, BIS January 2026 final rule

BIS January 13, 2026 final rule shifts license review posture for H200/MI325X-equivalent chips to China from 'presumption of denial' to 'case-by-case review' with approval conditions focused on US manufacturing investment rather than multilateral coordination. This moves directionally opposite to Montreal Protocol mechanism: Montreal made non-participation costly through trade sanctions creating coordination game conversion; Trump BIS rule makes participation (chip access) achievable through compliance conditions, using industrial policy incentives (Chinese investment in US fabs) as substitute for coordination mechanism design. Rule contains no provisions for multilateral coordination with Netherlands/Japan/UK enforcement. Announced January 13, followed by 25% semiconductor tariff January 14 — together forming coherent industrial policy (tariffs force domestic production, export relaxation generates manufacturing demand) rather than coordination mechanism.
