The Paperwork Loophole: How Malaysia and Singapore Became a Detour for Nvidia Chips
U.S. export rules do not let Nvidia's data-center-class A100 and H100 GPUs ship directly to China without a Commerce Department license. Prosecutors allege Lui and his co-conspirators worked around that chokepoint by telling U.S. server manufacturers the equipment was bound for buyers in Malaysia and Singapore, obtaining the hardware under that pretense, then re-exporting it to China once it had already cleared the first border [1]. The indictment's own paper trail documents this pattern at more than one scale. A January 2024 purchase order for 27 servers loaded with Nvidia H100 GPUs, worth roughly $7.6 million, moved from Los Angeles to Kuala Lumpur before being transshipped on to a buyer in China [2]. Separately, video coverage of the case describes a shipment of 92 servers flown from San Francisco International Airport to Kuala Lumpur and then re-exported to Hong Kong - a second, larger instance of the same false-paperwork-plus-third-country pattern. What the available reporting does not establish is exactly how Malaysian or Singaporean export rules differ from the U.S. license requirement for these chips - only that routing through those two countries, paired with false paperwork, let the shipments avoid the scrutiny a direct U.S.-to-China shipment would have drawn.


