According to Jin10, China’s Ministry of Commerce said whether an overseas AI deployment falls under technology export controls depends on whether restricted technology is transferred from China to another country. Most AI technologies can still be exported freely. Overseas localization of restricted AI technology is subject to export controls, though deployments on a company’s own overseas cloud may qualify for facilitation measures such as automatic licensing. Providing access to restricted large models through APIs, apps, web interfaces, SaaS applications, or lightweight on-device deployments is outside the scope of large-model technology export controls.