Chip designers cannot determine if their IP ends up in controlled end-uses after three distribution hops

A US chip design company licenses IP blocks to a Taiwanese fab, which sells chips to a Japanese distributor, which sells to a Shenzhen systems integrator, which builds boards for a company that may or may not be on the Entity List. The US design company has no visibility into where its IP physically ends up after the third distribution hop. BIS holds the US company liable for 'knowledge' of end-use, but supply chain opacity makes genuine knowledge impossible beyond the first customer. This persists because semiconductor supply chains are globally distributed with 5-8 intermediaries between design and end-use, and no tracking system exists that follows individual chips from fabrication to installation.