In his letter, Hauser specifically raised the alarm that a purchase by Nvidia would put Arm and its customers under the control of "US OFAC," or the Office of Foreign Assets Control, a branch of the US Treasury Department. Trade experts said he's not wrong.OFAC is one of two agencies through which the US government imposes trade restrictions and export controls, said Larry Ward, a partner at law firm Dorsey & Whitney and a member of its national security law practice group.
The prohibition on the sale of certain technology products to Huawei is being overseen by BIS. Unlike OFAC sanctions, BIS export restrictions don't automatically cover products or technologies developed by the foreign subsidiaries of US companies, Ward said. Instead, there's a calculation done about whether something is a US product or not based on the amount of contribution to it by US individuals or the work that's done on it on US soil, he said.
As a practical matter, though, being subject to OFAC sanctions isn't likely to affect Arm's business very much, other experts said. Those trade restrictions generally are focused on countries that have long been subject to US sanctions and don't do a whole lot of international trade in technology products, such as Cuba or North Korea.
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