Fragmented Procurement Networks Bypassing H100 Export Controls

The U.S. government has arrested Greg Lui, 38, the CEO of Earthmade Computer Inc., for allegedly smuggling approximately $300 million worth of Nvidia hardware into China between October 2023 and August 12, 2026. According to reporting from The Register and Ars Technica, Lui utilized a fragmented procurement network to bypass U.S. export licenses, shipping servers equipped with H100, A100, GeForce RTX 5090, and PNY GE Force RTX 4090 GPUs via Singapore and Malaysia.

Prosecutors allege Lui used Earthmade Computer to order the hardware in the U.S. before shipping it to Southeast Asian firms that forwarded the kit to China. The Register reports that court documents tie the export of 92 servers from San Francisco International Airport to Kuala Lumpur, with the final consignee listed as a Chinese customer in Hong Kong. Ars Technica notes the FBI further alleged that chips were delivered to a firm in Hangzhou. To mask these operations, Lui allegedly used fraudulent documentation, including a fake buyer led by a "Jackie Lui" and identity documents purchased illegally in 2021.

Financial records from Bank of America and JP Morgan, as cited by Ars Technica, show Lui's firm received over $176 million from two Malaysian transshipment companies. John A. Eisenberg, assistant attorney general for national security, stated that the National Security Division aims to protect the "American advantage" in chips powering "super intelligence (SI)."

While a spokesperson for Nvidia told Bloomberg that diverted products represent "less than one half of one percent" of its products, Bloomberg reporting suggests officials are concerned about gaps in Nvidia's due diligence regarding shipments to Thailand, Malaysia, and Singapore. Lui faces charges including money laundering, outbound smuggling, and violations of the Export Control Reform Act and Export Administration Regulations, carrying a maximum sentence of 50 years.