Export Controls State of Play: January 2026

Trump, Strategic Competition and AI

Export controls are once again at the centre of international security and economic policy. Over the past three months, developments in the United States, Europe, China, and allied countries have underscored how export controls are now being used not only to address traditional nonproliferation concerns, but also to shape technological competition, industrial policy, and geopolitical alignment.

This Export Controls State of Play briefing is the first edition of a new quarterly series designed to help export compliance professionals, security decision-makers, and policy practitioners make sense of these shifts.

Rather than cataloguing every regulatory change, the focus is on prioritisation and interpretation: what has changed, why it matters, and how export controls are being used in practice in an era of strategic competition.

What this briefing covers

The January 2026 edition focuses on five core themes.

First, it examines how the second Trump administration is approaching export controls, particularly in relation to China. Recent decisions on advanced semiconductors and compute capacity suggest a move away from blanket restriction toward more selective, managed trade—paired with continued emphasis on enforcement and end-user controls.

Second, it situates export controls within the broader international security environment. Developments involving China, Iran, Russia, and North Korea illustrate how export controls are increasingly intertwined with sanctions policy, defence cooperation, and alliance management.

Third, it reviews key regulatory developments across major jurisdictions, including the United States, the European Union, the United Kingdom, and Japan. Particular attention is paid to unilateral controls on emerging technologies and what these measures imply for the future of the multilateral export control regimes.

Fourth, it highlights recent enforcement trends, especially those related to advanced computing and diversion risks. Even where policy signals appear to soften, enforcement activity continues to provide important insight into regulatory priorities.

Finally, the briefing looks ahead to the coming quarter, identifying areas where further tightening, relaxation, or strategic bargaining over export controls may occur.

AI, compute, and the limits of export controls

A central case study in this edition is compute capacity and artificial intelligence.

While AI is often discussed as a novel export control challenge, the reality is more complex. Current export controls have largely focused on hardware—advanced semiconductors and computing systems—rather than models, data, or software. At the same time, uncertainty remains about the precise national security risks posed by current and near-term AI systems.

This briefing explores where export controls may be effective, where they are poorly suited, and why other policy tools—such as research security, cybersecurity, and investment controls—are increasingly being used alongside traditional export controls.

Who this briefing is for

This series is intended for:

Export compliance officers and legal teams in industry
Government officials involved in export control and sanctions policy
Security and risk professionals assessing technology exposure
Analysts and researchers working on international security and strategic competition

It is written to support internal briefings, compliance discussions, and strategic planning, rather than to serve as a technical licensing manual.

About this series

The Export Controls State of Play is produced on a quarterly basis by Dr Ian J Stewart, based on ongoing research into export controls, sanctions, and research security.

This inaugural edition is being made available openly. Future quarterly editions—including expanded analysis, case studies, and additional content—will be available to subscribers.

Subscribers will receive: