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U.S. providers of specialized AI training data and reinforcement-learning environments are reportedly supplying services to Chinese AI laboratories, contributing to frontier models including Moonshot AI's Kimi and Z.ai's GLM. The activity exposes a gap in U.S. controls: export restrictions have focused heavily on advanced semiconductors, while high-quality data, expert labeling, and training environments remain available as commercially delivered services.
A proposed response would expand the Justice Department's Data Security Program beyond bulk Americans' personal data to cover tailored AI-development data services provided to Chinese entities. The approach would use International Emergency Economic Powers Act authorities to bar direct sales to designated Chinese AI developers and require providers to perform know-your-customer checks on other customers, treating scarce U.S. training-data expertise as a strategic asset alongside advanced compute.
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The Department of Justice National Security Division issued the implementing regulation for the Data Security Program, which prohibits or restricts specified transactions involving bulk U.S. personal data and covered foreign entities.
President Biden signed Executive Order 14117, declaring that acquisition of Americans' bulk sensitive personal data by countries of concern posed a national-security threat under IEEPA.
SemiAnalysis reported that Surge AI sells AI training environments to Chinese laboratories, including Moonshot AI and Z.ai, and assessed that the environments materially aided Kimi K2 Thinking and GLM-4.6 capabilities.
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