GAO

United States General Accounting Office

Report to the Chairman, Committee on 

Armed Services, U.S. Senate

December 2000 EXPORT CONTROLS

System for Controlling 

Exports of High 

Performance 

Computing Is 

Ineffective

GAO-01-10

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Contents

Letter 3

Appendixes Appendix I: Possible Ways of Safeguarding U.S. National Security 

Interests Related to Computer Exports 28

Appendix II: Additional Information on Computer Clustering

Technology and MTOPS 38

Appendix III: Identified Applications of National Security Importance 42

Appendix IV: Comments From the Department of Commerce 53

Abbreviations

DOD Department of Defense

ISTAC Information Systems Technical Advisory Committee

MTOPS millions of theoretical operations per second
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United States General Accounting Office

Washington, D.C. 20548 Letr

December 18, 2000

The Honorable John Warner

Chairman, Committee on Armed Services

United States Senate

Dear Mr. Chairman:

Because high performance computing is an important enabling technology 

for military purposes, the U.S. government controls the export of high 

performance computers to sensitive destinations, such as Russia and 

China, based on foreign policy and national security concerns. A high 

performance computer1

 has both civilian and military applications,2

operates at or above a defined performance threshold, and requires an 

export license to particular destinations, according to the Commerce 

Department, the agency responsible for licensing dual-use items. U.S. 

policy with respect to the export of sensitive technology, including 

computers, is to seek a balance between the U.S. economic interest in 

promoting exports and its national security interests in both maintaining a 

military advantage over potential adversaries and denying the spread of 

technologies used in developing weapons of mass destruction. 

The President has periodically changed the performance thresholds above 

which licenses are required based on technological advances. The National 

Defense Authorization Act of 1998 requires the President to provide a 

report to Congress justifying each change for exports of high performance 

computers to certain sensitive countries. It requires the report, at a 

minimum, to (1) address the extent to which high performance computers 

with capabilities between the established level and the new proposed level 

of performance are available from other countries, (2) address all potential 

uses of military significance to which high performance computers at the 

1

 High performance computers are regulated based on their composite theoretical 

performance as measured in millions of theoretical operations per second (MTOPS). 

2

 An application is a program or group of programs designed for end users. Software can be 

divided into two general classes: systems software and applications software. Systems 

software consists of low-level programs that interact with the computer at a very basic level, 

including operating systems, compilers, and utilities for managing computer resources. In 

contrast, applications software (also called end-user programs) includes database 

programs, word processors, and spreadsheets. Figuratively speaking, applications software 

sits on top of systems software because it is unable to run without the operating system and 

system utilities. 
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new levels could be applied, and (3) assess the impact of such uses on U.S. 

national security interests. The President announced in August 2000 that 

the control threshold above which computers exported to countries like 

Russia and China would need a license would be 28,000 millions of 

theoretical operations per second (MTOPS) effective immediately.

Rapid technological advances in computing power have fueled concerns 

over the continued effectiveness of current computer export controls. You 

raised concerns about whether the computer export licensing process 

continues to protect U.S. national security interests. As agreed with your 

office, this report discusses (1) the effectiveness of current export controls 

in preventing countries of concern from obtaining high performance 

computing capabilities that can be used for military applications and

(2) our evaluation of the President’s justifications for changing the 

computer control thresholds. You also asked us to identify possible ways of 

protecting U.S. national security interests related to exports of high 

performance computers. We obtained the views of government and private 

experts on this matter, and they are presented in appendix I of this report. 
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Results in Brief The current export control system for high performance computers, which 

focuses on controlling individual machines, is ineffective because it cannot 

prevent countries of concern from linking or clustering many lower 

performance uncontrolled computers to collectively perform at higher 

levels than current export controls allow. The Department of Commerce 

controls the export of individual high performance computers using 

MTOPS as its control measure. It currently requires licenses for export of 

computers with performance levels above 28,000 MTOPS for countries of 

concern, but lower performance uncontrolled computers have been 

clustered together from readily available components to obtain computing 

capabilities up to 70,000 MTOPS. However, even if control thresholds were 

raised to reflect this performance level, U.S. government computer experts 

and computer industry representatives agreed that using MTOPS to 

calculate computer performance and set control thresholds is an outdated 

and invalid means for determining whether individual high performance 

computers should be licensed for export. They said that the measure does 

not account for new designs of individual processors or for clustering 

computers together to achieve high performance computing levels. A 

Commerce Department technical advisory committee3

 has examined three 

alternatives to the current measure for establishing the licensing threshold, 

but none of the alternatives would solve the problems posed by clustering 

uncontrolled computer components to achieve higher computing levels. In 

addition, the Commerce Department has not assessed the implications of 

these technological advances on the effectiveness of the current licensing 

process to limit the access of countries of concern to high performance 

computing.

3

 Technical advisory committees, such as the committee on Information Systems Technical 

Advisory Committee, advise the Department of Commerce on the technical parameters for 

export controls applicable to dual-use commodities and technology and on the 

administration of those controls. The committees comprise representatives from industry 

and government who represent diverse points of view on the concerns of the exporting 

community. Industry representatives are selected from firms producing a broad range of 

goods, technologies, and software presently controlled for national security, foreign policy, 

nonproliferation, and short supply reasons; or that are proposed for such controls, and are 

balanced to the extent possible among large and small firms. 
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The justifications to change computer export controls in February and 

August 2000, which the President provided in two reports to the Congress, 

are inadequate for several reasons. First, the reports address the 

availability of individual computers to other countries, but they do not 

address the fact that the performance capabilities of clustered systems that 

can be acquired by other countries have exceeded the new control 

thresholds. Second, the reports address only selected computer uses of 

military significance to which high performance computers could be 

applied instead of all such uses at the new control thresholds, as required 

by the 1998 National Defense Authorization Act. Finally, the President’s 

reports make no reference to how specific identified uses at the new 

control threshold would affect U.S. national security. Instead, the 

President’s reports state that (1) pursuit of particular national security 

applications would require more than computer hardware; (2) there is little 

danger of most countries usefully employing high performance computers 

for military uses; and (3) it is important for the United States to retain a 

technological advantage in the design, development, and production of 

microprocessors and computers. The reports’ sections dealing with 

military uses of high performance computers and how such uses could 

effect U.S. national security were based on information from a 1998 study4

used by the Defense Department about military computer uses. The study’s 

authors concluded that neither they, nor the U.S. government, had 

sufficient information to assess which countries could productively use 

high performance computers to pursue particular applications.

Appendix I discusses the three alternative measures of individual computer 

performance that the Department of Commerce’s Technical Advisory 

Committee has examined. The appendix also discusses nine other ideas 

that have been raised at different times by various computer experts as 

possible alternatives to either the current MTOPS measure or the overall 

control system. However, neither Commerce nor others have fully assessed 

the feasibility of these ideas. We did not assess the feasibility of 

implementing any of the ideas but describe their characteristics and 

limitations when identified by the experts that we consulted. As 

technological advances in high performance computing make it more 

difficult to maintain the U.S. lead in military capabilities by denying 

4

 Seymour E. Goodman, Peter Wolcott, and Patrick Homer, High-performance Computing, 

National Security Applications, and Export Control Policy at the Close of the 20th Century

(Palo Alto, CA: Stanford University, Center for International Security and Arms Control, 

1998). 
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advanced technology transfers to countries of concern, it may become 

necessary to explore other options to maintain the U.S. lead in military 

technology. As a step in this direction, the National Defense Authorization 

Act for fiscal year 2000 requires (1) an annual report on transfers of 

militarily sensitive technology to countries and entities of concern and

(2) an assessment by the Secretary of Defense on the cumulative impact of 

U.S.-granted licenses for exports of technologies and technical 

information. The report prepared under the act must include information 

on countermeasures that may be necessary to overcome the use of such 

technologies and technical information. It is not required, however, to 

assess the cumulative impact of exports of nonlicensed computers, such as 

those that can be clustered. The report is scheduled for completion in late 

2000.

We are recommending that the Secretary of Commerce, in consultation 

with the Secretaries of Defense, Energy, and State, convene a panel of 

experts to conduct a comprehensive assessment and report to the 

Congress on ways of addressing the shortcomings of computer export 

controls, including, but not limited to, the ideas noted in this report. We are 

also recommending that the Secretary of Defense determine what U.S. 

countermeasures are necessary, if any, to respond to enhancements of the 

military or proliferation capabilities of countries of concern derived from 

both licensed and nonlicensed high performance computing.

Agencies commenting on a draft of this report generally agreed with our 

findings and conclusions, and the Department of Energy agreed with our 

recommendation to convene a panel of experts to conduct a 

comprehensive assessment and report to the Congress on ways of 

addressing the shortcomings of computer export controls. The 

Departments of Commerce and Defense disagreed with the need to 

implement our recommendations because they said they are already 

engaged in interagency reviews of similar issues. When asked for 

documentation on how interagency mechanisms are pursuing the points 

covered in our recommendations, the agencies provided none. As a result, 

we believe our recommendations are still valid and necessary to protect 

U.S. national security interests. Since Commerce and Defense disagreed 

with our recommendations, we have added two Matters for Congressional 

Consideration. The Congress may wish to institute a requirement that the 

Secretary of Commerce, in consultation with the Secretaries of Defense, 

Energy, and State, convene a panel of experts to conduct a comprehensive 

assessment of and report to the Congress on possible ways of addressing 

the shortcomings associated with controlling individual high performance 
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computers, including, but not limited to, the ideas noted in this report. The 

Congress may also wish to consider instituting a requirement that the 

Secretary of Defense determine and report on what U.S. countermeasures 

are necessary, if any, to respond to computing-related enhancements of the 

military or proliferation capabilities of countries of concern, as we have 

recommended in this report.

Background The use of high performance computing technology is reducing the costs 

and time required for systems analysis, design, development, test, and 

deployment of military systems and is improving the integration and 

effectiveness of complex weapons systems, according to the Department 

of Defense (DOD). As DOD continues to reform and reengineer its 

acquisition processes, high performance computing assets are being used 

to reduce the number and cost of building expensive prototypes. High 

performance computing, a critical enabling technology, is now a key 

ingredient to the successful implementation of many major DOD 

acquisition programs, according to DOD. It is for these reasons that the 

United States attempts to limit the extent of high performance computing 

capabilities obtainable by countries of concern. 

High performance computers and related components (for example, 

processors) are controlled under the Export Administration Act and the 

implementing Export Administration Regulations.5

 The act authorizes the 

Commerce Department to require firms to obtain licenses for the export of 

sensitive items that may pose a national security or foreign policy concern. 

The Departments of State, Energy, and Defense assist Commerce, which 

administers the act, by reviewing export applications and supporting 

Commerce in its reviews of export control policy. 

Since 1993, the President has revised U.S. export control requirements for 

high performance computers five times, including the revisions announced 

in August 2000. The export control policy revision implemented in January 

1996 removed license requirements for most exports of computers that 

could perform at or below a level of 2,000 MTOPS—an increase from 1,500 

MTOPS.6

 The 1996 policy revision also organized countries into four 

5

 50 U.S.C. App. section 2401 and following and 15 C.F.R. section 730 and following.

6 Export Controls: Information on the Decision to Revise High Performance Computer 

Controls (GAO/NSIAD-98-196, Sept. 16, 1998).
Page 9 GAO-01-10 Export Controls

computer “tiers,” with each tier after tier 1 representing a successively 

higher level of concern related to U.S. national security interests. 

• Tier 1. The policy placed no license requirements on tier 1 countries, 

primarily those in Western Europe and Japan. 

• Tier 2. Exports of computers above 10,000 MTOPS to tier 2 countries in 

Asia, Africa, Latin America, and Central and Eastern Europe continued 

to require licenses. 

• Tier 3. A dual-control system was established for tier 3 countries. 

• Tier 4. Exports of high performance computers to tier 4 countries were 

essentially prohibited.

In 1996 there were 50 tier 3 countries, including China, Russia, India, and 

Israel. Since then, the number of tier 3 countries has increased to 52. In 

January 1996, the threshold for exporting high performance computers 

without a license to tier 3 countries was set at 7,000 MTOPS for civilian end 

users, while exports of computers for potential military end users at and 

above 2,000 MTOPS required a license. Exports of high performance 

computers with performance capabilities above 7,000 MTOPS to civilian 

end users in all tier 3 countries required a license. High performance 

computer exports to countries in tier 4 (for example, Iran, Iraq, and Libya) 

were essentially prohibited because of national security and foreign policy 

concerns about these countries. 

The Fiscal Year 1998 National Defense Authorization Act7

 requires the 

President to report to the Congress justifications for changes in controls 

for computer exports to certain sensitive countries. The act further 

requires exporters to notify the Commerce Department of any proposed 

high performance computer exports to countries that pose a concern for 

military or proliferation reasons to determine if these exports need a 

license. 8

 The act also provides that if any designated agency9 raises a 

written objection to the proposed export within 10 days after Commerce 

receives the notification of the export, the export will require a license.

7

 P.L. 105-85 sec. 1211, Nov. 1997.

8

 Advance notification to Commerce of exporter’s intent to export high performance 

computers will rise to 28,000 MTOPS, effective in February 2001, from the current threshold 

of 12,500 MTOPS.

9

 Designated agencies for this purpose are the Departments of Defense, Energy, and State.
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On July 27, 1999, February 15, 2000, and August 30, 2000,10 following 

announced changes to the export control levels for high performance 

computers, the President submitted a report to the Congress, as required. 

According to the President’s announcements, these changes were needed 

because of the extraordinarily rapid rate of technological change in the 

computer industry. 

In the August 2000 announcement, the President described plans to change 

the controls on the exports of high performance computers by increasing 

the computing performance level at which export licenses would be 

required.11 These changes were as follows: 

• Tier 1. No changes.

• Tier 2. The licensing level was raised to 45,000 MTOPS, effective 

immediately.

• Tier 3. The two-level system for tier 3 countries was eliminated, and the 

licensing level for the tier was raised to 28,000 MTOPS, effective 

immediately. 

• Tier 4. No changes.

Export Control System 

for High Performance 

Computers Is Not 

Effective

The current system of controlling the export of individual machines is 

ineffective in limiting countries of concern from obtaining high 

performance computing capabilities for military applications. In addition, 

information obtained from the Departments of Commerce, Defense, and 

Energy and computer industry representatives shows that, given advances 

in technology, using MTOPS to establish export control thresholds is 

outdated and no longer a valid means for controlling computing 

capabilities and that an alternative is needed to replace it. MTOPS is an 

outdated measure because of its limited ability to estimate the performance 

of new designs of processors and to account for clustering of individual 

computers to achieve high performance computing capability. 

10 Summary of Findings With Respect to Criteria Set Forth in Subsection 1211 (d) of the 

National Defense Authorization Act for Fiscal Year 1998, attachment to letter sent to 

Congress (Washington, D.C.: The White House, July 27, 1999, Feb. 15, 2000, and Aug. 30, 

2000).

11 Executive branch agencies involved with reviewing and recommending changes to 

computer export controls are the Departments of Commerce, Defense, State, and Energy 

and the National Security Council.
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Computer Advances in 

Clustered Systems 

Compromise the 

Effectiveness of Current 

Controls

Over the past several years, technological advances in the ability to cluster 

lower performance computers have resulted in an increasing capability 

worldwide to achieve high performance computer levels. As a result, 

current U.S. export controls cannot prevent countries of concern from 

obtaining computing capabilities that can be used for military applications 

at levels much higher than those at which computers are currently 

controlled by the U.S. government. 

Commerce’s Information Systems Technology Advisory Committee, which 

advises and assists the Secretary of Commerce, reported in May 1999—and 

the Lawrence Livermore National Laboratory confirmed in February 

2000—that clustered computer systems composed of readily available 

components have been built with a performance level up to about 70,000 

MTOPS. As a result, the known performance levels of clustered systems 

exceed even the latest export control thresholds set by the U.S. 

government in August 2000. Figures 1 and 2 show examples of clustered 

computer systems composed of readily available components, such as 

personal computers and monitors, located at Clemson University and the 

Nehru Centre for Advanced Scientific Research, respectively.
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Figure 1: A Clustered Computer System

Source: Grendel Beowulf Workstation, Clemson University. 
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Figure 2: A Clustered Computer System in a Tier 3 Country

Source: Jawaharlal Nehru Centre for Advanced Scientific Research, India.

According to a February 2000 analysis prepared by the Lawrence 

Livermore National Laboratory, “Ignoring the fact that low-performance 

computers can be clustered to achieve a higher level of processing leads to 

a false sense of security.” The analysis said that it is inconsistent to control 

the export of individual high performance computers when the 

performance capabilities of clustered computers exceed the current and 

proposed control levels.12 Officials of the Los Alamos National Laboratory 

said that expertise necessary to build clustered systems is available 

worldwide, including in countries such as China and India, and that 

laboratory officials communicate with people building these systems and 

solving the same types of technical computing problems as the national 

laboratories. While discussing the relatively lower level of expertise 

necessary to put a clustered computer system together, the officials 

stressed that it is more difficult to operate clustered systems than to build 

12 The National Security Implications of Decontrolling Export to Tier III Countries of High 

Performance Computers between 2,000 and 40,000 MTOPS. (February 2000)
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them. For example, support for computer functions requires having an 

efficient schedule for running hundreds of separate problems and the input 

and output of data among a computer, its local disks, networks, and 

archival storage. Without vendor-supplied software to automate these 

functions on a system clustered together from readily available 

components, everything must be done manually, making computing a

labor-intensive operation.

One computer facility in India advertises that it has developed a new 

computer system architecture with clusters of workstations with 

commercially available interconnect technologies. The facility is on the 

Commerce Department’s “Entities List,” which identifies foreign end users 

that have been determined to present an unacceptable risk of diversion to 

developing weapons of mass destruction or the missiles used to deliver 

those weapons. Publishing this list puts exporters on notice that any 

products sold to these end users may present concerns and will require a 

license from Commerce.

MTOPS Is No Longer 

Adequate as a Measure of 

Performance

Analyses and information from U.S. government officials13 and computer 

industry representatives show that MTOPS is no longer a valid measure of 

individual computer performance and needs to be replaced. During the 

course of our review, these officials and representatives said that MTOPS is 

outdated and can no longer adequately account for the performance 

capabilities available from today’s computers. As a result, the continued 

use of the MTOPS measure would cause systems with the same 

performance capabilities to be treated differently under export control 

regulations, according to Commerce’s Information Systems Technical 

Advisory Committee. 

The MTOPS measure is unreliable today because it is heavily, if not 

exclusively, dependent on the clock rate of a microprocessor, measured in 

megahertz, when several other factors should be considered. It does not 

account for certain factors, such as memory retrieval times, 

interconnection methods, and internal bus speeds. (A bus is a collection of 

wires through which data is transmitted from one part of a computer to 

another.) An internal bus connects all the internal computer components to 

the central processing unit and main memory. The size of a bus is important 

13 U.S. government officials include the Deputy Under Secretary of Defense (Science and 

Technology) and officials of the Commerce and Energy Departments.
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because it determines how much data can be transmitted at one time. A 

fast bus allows data to be transferred faster, which makes applications run 

faster. In networking, a bus is a central cable that connects all devices on a 

local area network. In addition, MTOPS is inaccurate if incorrectly applied 

to computing elements organized in certain ways, such as computer 

clusters. Under DOD auspices, U.S. government officials, computer 

industry representatives, and academics met in December 1997 to 

determine whether the use of MTOPS is sufficient to rate the relative 

performance of current and future computer systems. The group 

determined that there were variances of a factor of 2 in the performance of 

delivered systems relative to the MTOPS-calculated performance because 

of the wide range of architectures in use, but it concluded that continuing 

rapid changes in technology might result in yet larger variances in the near 

future.

President’s 

Justification for 

Changing Computer 

Export Control 

Thresholds Was 

Inadequate 

The National Defense Authorization Act of 1998 requires the President to 

provide a report to the Congress on three factors when proposing a 

modification of the export control thresholds for high performance 

computers. First, the report is to address the availability of high 

performance computers from other countries. Second, it is to address all 

potential computer uses of military significance at the new control 

thresholds. Third, the report is to assess the impact of such uses on U.S. 

national security interests. In response to the act’s requirements, the 

February and August 2000 reports presented information on the availability 

of individual computers from other countries but did not recognize such 

countries’ capabilities to cluster computers to obtain computing 

performance beyond the new thresholds. Furthermore, the August report 

addressed only 22 of 172 known military uses of high performance 

computers up to the new control threshold. Finally, the report made no 

reference to the national security impact of specific identified uses at the 

new control thresholds. Instead, the report stated that (1) pursuit of 

particular national security applications would require more than computer 

hardware; (2) there was little danger of most tier 2 and 3 countries 

diverting high performance computers from other purposes and usefully 

employing them for military uses; and (3) it was important for the United 

States to retain a technological advantage in the design, development, and 

production of microprocessors and computers. The reports relied for their 

information about national security impacts of military computer uses on a 

study that stated that it could not assess which countries of concern could 

use computers for particular military applications because the U.S. 

government did not have information to make such an assessment.
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Clustering Not Factored 

Into New Thresholds in 

Considering Computing 

Performance Availability in 

Other Countries

The President’s reports were required to address the extent to which high 

performance computers with capabilities between the established level and 

the new proposed level of performance are available from other countries. 

In response to the requirement, the reports to the Congress justified the 

new control thresholds based on industry-provided information indicating 

the MTOPS performance of mass market processors that the industry 

expected would be produced within the next 6 months. The reports stated 

that such processors would be uncontrollable worldwide. While the 

administration discussed computer clustering as contributing to such 

availability, it did not factor computer clustering into its control threshold 

changes made during 2000, nor did it indicate that with clustered systems 

other countries could obtain performance capabilities that exceed the new 

control thresholds. If they had presented this fact in the reports, it would 

have revealed that the computer control system was ineffective.

Although the President’s February and August 2000 reports discussed 

advances in clustering, they did not indicate that performance capabilities 

of clustered systems have exceeded the new control thresholds. The 

President’s reports noted that advanced network technologies, particularly 

in parallel processing known as “distributed computing,” are freely 

available. Cost considerations and advances in computer technology in 

both the United States and overseas have created a favorable environment 

for high performance distributed computing using readily available 

hardware and software, according to the reports. The reports added that 

relatively low-cost high performance computer systems typically consist of 

large clusters of commercially available workstations or personal 

computers that are linked by interconnection hardware and high-speed 

communication software. As a result, the affordability and widespread 

availability of these computer products permit foreign end users to 

configure these commercially available products into high performance 

computer systems. The President’s reports did not state that high 

performance computing up to about 70,000 MTOPS is attainable.

While computer clustering was not factored into the control threshold 

changes made during 2000, the President’s August 2000 report justified the 

new control thresholds based on industry information indicating the 

MTOPS performance of mass market processors to be produced within the 

next 6 months that Commerce officials believed would be uncontrollable. 

As of August 2000, the fastest mass-marketed microprocessor had a peak 

performance measure between 3,000 and 4,000 MTOPS. By the fall 2000, a 

new 6,100 MTOPS microprocessor was expected to be available, and a 

four-microprocessor computer based on this new microprocessor was 
Page 17 GAO-01-10 Export Controls

expected to have a performance level of about 24,000 MTOPS. The August 

report further stated that the next generation of computers with eight 

microprocessors and a performance of 26,000 MTOPS, is expected to be 

widely available in early 2001. Consequently, for end users in tier 3 

countries, thresholds were set at 28,000 MTOPS, slightly higher than the 

expected availability of the 26,000 MTOPS machine. The report stated that 

computer manufacturers in the United States and in foreign countries 

continue to produce computers that are smaller, cheaper, and easier to 

install and maintain but are more powerful than ever before. This trend is 

due in large part to rapid advances in microprocessor technology, 

according to the report. Computer companies projected that their chips 

and systems would be produced in the tens of thousands per month, 

depending on the specific processor.

All Potential Computer Uses 

Not Addressed 

The National Defense Authorization Act of 1998 requires that the 

President’s report to the Congress address all potential uses of military 

significance to which high performance computers at the new levels could 

be applied. However, the President’s reports to the Congress during 2000 

did not address all such computer applications, even though this 

information was available from the 1998 Department of Defense- and 

Commerce-sponsored study that was used as the basis for these sections of 

the reports. DOD officials from the Defense Threat Reduction Agency, 

which is responsible for sections of the reports on military uses of high 

performance computers, told us that they took their information from the 

1998 study because the agency did not have the resources to initiate an 

independent review of this and related issues. The officials chose to report 

on 3 of 10 categories of applications identified by the 1998 study.
Page 18 GAO-01-10 Export Controls

We identified a total of 22 computer applications mentioned in the 

President’s report: 17 applications that can be operated up to a 

performance level of 21,000 MTOPS and 5 applications that can be 

operated at nonspecified levels between 1,000 and 115,000 MTOPS.14 The 

1998 Defense- and Commerce-sponsored study, however, specifically 

identified 172 military applications that were run on computers up to 

28,000 MTOPS.15 Of these military applications, 47 were run on computers 

between 20,000 and 28,000 MTOPS (the previous tier 3 computer control 

thresholds for civilian end users and newly announced tier 3 computer 

control thresholds for all end users). Appendix IV lists the applications of 

national security importance identified for the 1998 Defense- and 

Commerce-sponsored study.

Information Provided on 

National Security Impacts 

Was Inadequate

The National Defense Authorization Act of 1998 requires that the 

President’s report to the Congress assess the impact on U.S. national 

security interests of potential uses of military significance to which high 

performance computers at the new levels could be applied. The President’s 

reports, however, did not specifically discuss the impacts on U.S. national 

security interests for any of the national security applications that the 

report identified, as required by the 1998 National Defense Authorization 

Act. The reports made general statements that most countries cannot 

effectively use high performance computers and that there are therefore no 

national security impacts on the United States. This 1998 study, however, 

stated that the U.S. government provided insufficient information to assess 

this issue. 

Although the President’s August report identified only 22 of the 172 military 

applications that were run on computers up to 28,000 MTOPS, the report 

did not discuss the national security impacts on the United States of 

Russia, China, or other countries obtaining high performance computing up 

14 The President’s reports do not clearly distinguish computer applications by name and 

performance levels. As a result, it is impossible in all cases to determine from the reports 

whether mentioned applications are distinct or identical.

15 According to the 1998 Department of Defense- and Commerce-sponsored study, the 

absence of a particular type of problem at some performance level should not be interpreted 

as a statement that no version of that application can be solved at that performance level. 

MTOPS are only rough indicators of the performance level required for a particular kind of 

application. That a given problem was run on a machine with a particular MTOPS level does 

not mean that all systems with a greater MTOPS level can solve the problem or that all 

systems with a lower MTOPS level cannot.
Page 19 GAO-01-10 Export Controls

to the new control thresholds, even for those applications identified. The 

President’s reports also did not identify which countries of concern could 

gain the hardware capability to conduct militarily useful applications at the 

new control thresholds. For example, the reports stated that Russia and 

China have demonstrated that they have the expertise necessary to use 

high performance computers for particular national security applications, 

such as developing submarines, advanced aircraft, composite materials, or 

a variety of other devices. The reports also did not discuss other countries 

that can use high performance computing for military applications. India, 

for example, which has organizations that we identified as both using high 

performance computing for military purposes and being listed on the 

Commerce Department’s “Entities List” of end users of proliferation 

concern, was not mentioned in the President’s reports. 

The reports stated that most tier 2 and 3 countries have little or no 

experience in a host of national security applications and there is little 

danger of these countries diverting high performance computers from 

other pressing needs and usefully employing them to develop military 

items. According to DOD officials responsible for the sections of the report 

on military uses of high performance computers, the 1998 Defense- and 

Commerce-sponsored study was the basis for these statements. The 1998 

study, however, indicated that it did not have sufficient information to 

assess the impact of militarily significant applications on U.S. national 

security interests. The study stated that

“A critical question, which we have been unable to pursue satisfactorily in this study, is 

which countries are able to productively use [high performance computing] to pursue which 

applications? We have requested such information from the U.S. national security 

community, but have received few answers. It does not appear that the U.S. government is 

effectively gathering such intelligence in a systematic fashion. More specifically, the U.S. 

government does not appear to have as good an understanding of individual end use 

organizations of concern as is needed by the export control regime.”

The President’s reports did not state which countries can use high 

performance computers for particular military applications or which 

countries cannot, and the analysis that was absent in the 1998 Defense- and 

Commerce-sponsored study and an earlier 1995 study has not been done. 

As we reported in 1998,16 the principal author of the Defense- and 

Commerce-sponsored study and DOD officials told us that no assessment 

had been done in 1995 to determine how national security would be 

16 Export Controls (GAO/NSIAD-98-196, Sept. 16, 1998).
Page 20 GAO-01-10 Export Controls

impacted if high performance computers were exported to particular 

countries of concern and what military advantages such countries could 

achieve. The 1998 study reiterated this position. We recommended in 1998 

that the Secretary of Defense do such an evaluation, specifically addressing 

(1) how and at what performance levels countries of concern use high 

performance computers for military modernization and proliferation 

activities, (2) the threat of such uses to U.S. national security interests, and 

(3) the extent to which such high performance computers are controllable. 

This recommendation has not been implemented. Although DOD stated 

that the interagency process had considered these factors in the 1995 

review of computer export controls and would consider them in any future 

review, it provided no evidence that this has occurred. 

An annual report on transfers of militarily sensitive technology to countries 

and entities of concern, required under section 1402 of the National 

Defense Authorization Act for fiscal year 2000, might partially address the 

question of the national security impact of high performance computer 

uses of military significance. It is to include an assessment by the Secretary 

of Defense, in consultation with the Joint Chiefs of Staff and the Director of 

Central Intelligence, on the cumulative impact of U.S.-granted licenses for 

exports of technologies and technical information to these countries and 

entities. Thus, the study would be expected to include licensed high 

performance computers as part of the assessment. This report is also 

required to include information on countermeasures that may be necessary 

to overcome the use of such technologies and technical information. 

However, it is not required to include an assessment of the cumulative 

impact of nonlicensed computer exports, such as those that could be 

clustered. The report is scheduled for completion by the end of 2000.

Conclusions The current export control system for computers, as implemented by the 

Department of Commerce and which focuses on controlling the export of 

individual computers, is not effective in limiting countries of concern from 

obtaining high performance computing capabilities. As a result of advances 

in clustering technology, countries of concern can obtain computing 

capabilities above current U.S. export control levels necessary for military 

applications. It is also now widely recognized within the Departments of 

Commerce, Defense, and Energy and the computer industry that the use of 

MTOPS as the means of determining export control thresholds is outdated, 

no longer a valid means for controlling computing capabilities, and needs 

to be replaced. In light of these now well established developments, the 

process needs to be reexamined, and potential alternative ways to 
Page 21 GAO-01-10 Export Controls

safeguard U.S. national security interests related to high performance 

computer exports need to be explored. 

In addition, the President’s reports justifying computer control changes 

continue to be inadequate. It is a particularly important omission for the 

U.S. government to not assess the national security impacts of how 

countries of concern can use high performance computers at successively 

higher performance levels for military purposes. Although we have 

highlighted this issue in the past, the administration has presented no 

further assessment. As advances in high performance computing make it 

more difficult to maintain the U.S. technological lead in military 

capabilities by denying advanced technology transfers to countries of 

concern, it may become necessary to explore other options to maintain the 

U.S. military technology lead. For example, the National Defense 

Authorization Act for fiscal year 2000 required the Secretary of Defense to 

assess the cumulative impact of U.S. export licenses—including high 

performance computing licenses—and possible countermeasures that may 

be necessary to overcome the use of such technologies and technical 

information. However, it did not require an assessment of the cumulative 

impact of exporting nonlicensed computers that could be clustered, or of 

potential countermeasures to such an impact.

Recommendations for 

Executive Action

Since the current export control system for high performance computers 

cannot prevent countries of concern from obtaining high performance 

computing capabilities, we recommend that the Secretary of Commerce, in 

consultation with the Secretaries of Defense, Energy, and State, convene a 

panel of experts to comprehensively assess and report to the Congress on 

possible ways of addressing the shortcomings of computer export controls, 

including, but not limited to the ideas noted in this report. For example, the 

Commerce Department’s National Institute of Standards and Technology, 

which researches computer systems’ performance and promotes the 

effective evaluation and efficient use of advanced computers, might 

participate in the panel because it designs evaluations that economically 

and reliably characterize high performance computer designs. This 

assessment should report on the costs and benefits of each proposed idea, 

including its technical feasibility. 

In addition, the report required by the National Defense Authorization Act 

of 2000 concerning countermeasures that may be necessary to overcome 

the use of sensitive technologies and technical information exported to 

countries of concern is not required to include an assessment of the 
Page 22 GAO-01-10 Export Controls

cumulative impact of exports of nonlicensed computers, such as those that 

could be clustered. Therefore, we recommend that the Secretary of 

Defense determine what U.S. countermeasures are necessary, if any, to 

respond to computing-related enhancements of the military or proliferation 

capabilities of countries of concern.

Agency Comments and 

Our Evaluation

The Department of Commerce provided written comments (see app. IV) on 

a draft of this report. The Department of Energy’s Acting Chief Operating 

Officer for the National Nuclear Security Administration and the Principal 

Deputy Under Secretary of Defense for Policy provided oral comments. 

The Department of Energy concurred with the report’s findings and 

conclusions and our recommendation concerning the convening of a panel 

of experts and said that the Department looks forward to participating with 

the Secretaries of Commerce, Defense, and State in such a panel to conduct 

a comprehensive assessment of possible ways of addressing the 

shortcomings of computer export controls. The Departments of Commerce 

and Defense generally agreed with the report’s findings and conclusions 

relating to the problems we identified with clustering technology and the 

continuing use of MTOPS as a measure for controlling individual high 

performance computers. However, they disagreed with the need to 

convene an expert panel or to determine what countermeasures are 

necessary to respond to enhancements of military capabilities of countries 

of concern which such countries may have gained through the use of high 

performance computing. 

The Departments of Commerce and Defense said that they disagreed with 

the need to implement our recommendation that the Secretary of 

Commerce and other secretaries convene a panel of experts to 

comprehensively assess possible ways of addressing the shortcomings of 

computer export controls because they said the administration and experts 

are already studying similar issues. Commerce stated that it would be 

counterproductive and unnecessary to convene a panel of experts, since 

the administration was already examining this issue through existing 

interagency mechanisms involving DOD, Energy, and State. Commerce also 

said that the Center for Strategic and International Studies has a broad 

group of experts currently studying the same issues as encompassed in the 

recommendation. DOD said that the administration has been consulting 

with experts to formulate an approach for controlling computing 

capabilities and is assessing various alternatives—including “some” 

identified in our draft report. Subsequent to receiving these comments, we 

asked both Departments to describe in more detail and document what 
Page 23 GAO-01-10 Export Controls

comprehensive study was being conducted. Neither Department provided 

any additional information to show that there was an interagency study 

being conducted as we are recommending. Although we sought 

information on steps being taken that would address the issues covered by 

our recommendations, neither the Commerce Department nor Department 

of Defense provided any evidence that an interagency mechanism is 

systematically examining alternative ways to protect U.S. national security 

interests related to the shortcomings of computer export controls—beyond 

the narrowly focused effort to seek alternatives to the MTOPS measure for 

controlling individual machines. 

Regarding the study by the Center for Strategic and International Studies, 

we note that it is tasked to “develop the framework for a new effective . . . 

agreement that would regulate certain militarily useful goods and 

technologies on a multilateral basis,” not to examine the costs, benefits, 

and technical feasibility of each possible way identified in this report of 

addressing the shortcomings associated with controlling individual high 

performance computers. 

The Departments of Commerce and Defense also disagreed with the need 

to implement our recommendation that the Secretary of Defense determine 

what U.S. countermeasures are necessary to respond to enhancements of 

the military capabilities of countries of concern from both licensed and 

nonlicensed high performance computing. Commerce stated that the best 

countermeasure is to ensure that the U.S. military and defense industries 

continue to have access to the computer technology needed to maintain the 

U.S. military advantage. DOD stated that the Department continuously 

assesses the military capabilities of potential adversaries and countries of 

concern to identify threats to U.S. forces and described the assessment 

process. While we agree that maintaining the U.S. technological advantage 

in computing is important, we note that neither Commerce nor Defense 

specified how or whether DOD (1) has assessed and identified any threats 

posed by high performance computing to U.S. national security interests or 

(2) identified and implemented countermeasures to such threats. 

Furthermore, ongoing studies tasked to assess the need for 

countermeasures related to U.S. exports of sensitive technologies are not 

reviewing threats posed by nonlicensed clustered computer systems, a 

factor that we believe is critical to assess. 

DOD disagreed with our conclusion that the President’s February and 

August 2000 reports to the Congress were inadequate with regard to 

required national security assessments accompanying changes to computer 
Page 24 GAO-01-10 Export Controls

control levels. DOD stated that the President’s reports have consistently 

noted that most activities associated with various aspects of military 

capabilities benefit from some computing capabilities. It further stated that 

the President’s reports to the Congress have provided examples of national 

security applications to illustrate that the range of military applications that 

(1) benefit from high performance computing is “almost ubiquitous” and 

(2) can be performed on almost any computer is extensive. Nonetheless, as 

this report and our prior reports have pointed out, we continue to believe 

that the President’s reports did not adequately provide the information that 

the law requires. The President’s reports did not address all potential uses 

of military significance to which high performance computers at the new 

levels could be applied—even though the administration possessed 

information on such uses in the 1998 Defense- and Commerce-sponsored 

study (part of which we have reprinted in app. III)—and did not assess the 

impact of such uses on U.S. national security interests. 

Matters for 

Congressional 

Consideration

Since the Departments of Commerce and Defense disagreed with 

recommendations which we believe are still valid and needed, the 

Congress may wish to institute a requirement that the Secretary of 

Commerce, in consultation with the Secretaries of Defense, Energy, and 

State, convene a panel of experts to conduct a comprehensive assessment 

of and report to the Congress on possible ways of addressing the 

shortcomings associated with controlling individual high performance 

computers, including, but not limited to, the ideas noted in this report. 

In addition, to address the issue of countermeasures that may be necessary 

to overcome the use of sensitive technologies and technical information 

exported to countries of concern, the Congress may also wish to consider 

instituting a requirement that the Secretary of Defense determine and 

report on what U.S. countermeasures are necessary, if any, to respond to 

computing-related enhancements of the military or proliferation 

capabilities of countries of concern, as we have recommended in this 

report.

Scope and 

Methodology

To assess the effectiveness of current export controls in preventing 

countries of concern from obtaining high performance computing 

capabilities that can be used for military applications, we reviewed studies 

and briefing slides by U.S. government agencies and computer industry 

technical specialists that described technological computing advances and 
Page 25 GAO-01-10 Export Controls

assessed the MTOPS measure. Such studies included assessments by the 

Lawrence Livermore and Sandia National Laboratories on possible 

alternatives to current computer controls. We interviewed officials from 

the Departments of Defense, Commerce, State, and Energy; the Central 

Intelligence Agency; and the three major national weapons laboratories, 

Lawrence Livermore, Los Alamos, and Sandia. We interviewed officials 

from major computer manufacturers, Compaq, Hewlett Packard, IBM, and 

SUN Microsystems, as well as the computer scientist responsible for the 

Top 500 List of the most advanced high performance computers in the 

world. In addition, we observed meetings of Commerce Department’s 

Information Systems Technology Advisory Committee.

To evaluate the President’s justifications for changing the computer control 

thresholds, we reviewed the President’s February 2000 and August 2000 

reports to the Congress justifying changes to computer control thresholds 

and a White House fact sheet detailing the changes made in August 2000. 

We reviewed Commerce Department analyses and computer industry 

information regarding projected production schedules and technical 

performance ratings for processors scheduled to be marketed in the next 

6 to 12 months. In addition, we reviewed studies and briefing slides by U.S. 

government agencies and computer industry technical specialists that 

described technological computing advances and assessed the MTOPS 

measure. We interviewed officials from the Departments of Defense, 

Commerce, State, and Energy; the Central Intelligence Agency; and the 

three major national weapons laboratories, Lawrence Livermore, Los 

Alamos, and Sandia. We interviewed officials from major computer 

manufacturers, Compaq, Hewlett Packard, IBM, and SUN Microsystems, as 

well as the computer scientist responsible for the Top 500 List of the most 

advanced high performance computers in the world. In addition, we 

observed meetings of the Commerce Department’s Information Systems 

Technology Advisory Committee.

We conducted our review from February through November 2000 in 

accordance with generally accepted government auditing standards.

Unless you publicly announce the contents of this report earlier, we plan no 

further distribution of this report until 15 days from its issue date. At that 

time, we will send copies of this report to other appropriate congressional 

committees; the Honorable William S. Cohen, Secretary of Defense; the 

Honorable Madeleine K. Albright, Secretary of State; the Honorable 

Norman T. Mineta, Secretary of Commerce; and the Honorable William 
Page 26 GAO-01-10 Export Controls

Richardson, Secretary of Energy. Copies will also be made available to 

others upon request.

If you or your staff have any questions concerning this report, please call 

me at (202) 512-4128 or Mr. Rhodes at (202) 512-6412. Key contributors to 

this assignment were Claude Adrien, Jeffrey D. Phillips, F. James Shafer, 

and Hai Tran.

Harold J. Johnson

Director, International Affairs

 and Trade 

Keith A. Rhodes

Chief Technologist
Page 27 GAO-01-10 Export Controls
Page 28 GAO-01-10 Export Controls

Appendix I

Possible Ways of Safeguarding U.S. National Apendxies

Security Interests Related to Computer 

Exports ApendxiI

To identify possible alternative ways to safeguard U.S. national security 

interests related to computer exports, we reviewed analyses and other 

documentation prepared by the two Department of Energy national 

laboratories addressing this question, Lawrence Livermore and Sandia. We 

also interviewed officials from the Departments of Defense, Commerce, 

State, and Energy—including Los Alamos, Lawrence Livermore, and Sandia 

National Laboratories; the Central Intelligence Agency; and officials from 

major computer manufacturers, Compaq, Hewlett Packard, IBM, and SUN 

Microsystems.

We identified 12 ideas for addressing shortcomings to the current export 

control system. These ideas have not been comprehensively evaluated by 

the U.S. government. The Department of Commerce has considered the 

first three ideas we describe in this appendix, but none of the three 

addresses the export control problem created by clustering technology. We 

also present nine additional ideas identified through our research and 

discussions with experts. We did not assess the feasibility of implementing 

any of the ideas but rather describe their characteristics and limitations 

when identified by the experts. It is important to note that these ideas have 

not been assessed for their feasibility to replace the current export control 

mechanism; moreover, most of them do not address the challenge created 

by advances in clustering technology.

Alternatives to Using 

MTOPS Considered by 

the CommerceSponsored Technical 

Advisory Committee

The three ideas that the Commerce-sponsored Information Systems 

Technical Advisory Committee (ISTAC) reviewed are (1) counting 

processors, (2) measuring power dissipation, and (3) indexing control 

thresholds to a common benchmark. 

Counting Processors 

Instead of Using MTOPS

Using this approach, computers would be controlled by counting the 

number of processors in each computing system. For example, a license 

might be required if a computer to be exported to tier 3 countries contained 

eight or more processors, while computers with fewer processors could be 

exported without a license. Presumably, the precise number of processors 

for each tier would be determined as the details of such a proposal were 

finalized.
Appendix I

Possible Ways of Safeguarding U.S. National 

Security Interests Related to Computer 

Exports

Page 29 GAO-01-10 Export Controls

Computer industry representatives and ISTAC members stated that 

counting processors would be simpler than using the MTOPS measure. 

Under current controls, computer chip manufacturers must calculate the 

MTOPS rating for each processor they manufacture, and computer 

companies must calculate the MTOPS rating for each of the computer 

systems they produce. Department of Energy and ISTAC officials also 

noted that by counting processors, they could better adapt to changes in 

computer technology because advances in processors used in a system 

would not result in the need to change the export controls. On the other 

hand, ISTAC members said that counting processors is no more accurate 

an indicator than MTOPS for indicating a level of computer performance. 

Furthermore, despite the intended simplicity of the approach, the 

Committee members noted that there is no consensus within the computer 

community on the definition of a processor. They also said that exceptions 

to the counting procedure would need to be determined for high 

performance single processors and for processors and computers with 

unique designs. For example, some processors today include advanced 

graphics or memory capabilities, but others do not and therefore have 

different performance capabilities. 

Measuring Power 

Dissipation

Power dissipation is a measure of watts per MTOPS that is currently used 

in Japan to determine the environmental effects of computers. The 

measure produces a ratio of the watts per MTOPS to the size of the box 

housing the microprocessor. The May 2000 ISTAC paper stated that this 

alternative was briefly studied but rejected because of its inability to 

accurately measure the performance capabilities of a system. Two systems 

with the same performance capability might have different ratios because 

each is housed in a different sized box with different power supplies and 

different disk drives, according to the Committee paper. As a result, the 

system measured to have a lower ratio would be controlled less stringently 

than the smaller system.

Indexing Control 

Thresholds to a Common 

Benchmark

Computer export control levels could be set by using a common 

performance benchmark. The May 2000 ISTAC paper on alternative control 

measures1

 also identified one benchmark, Linpack, that it called an 

accepted industry standard for performance measurements. The paper 

1

 Alternative Control Parameter for High Performance Computers.
Appendix I

Possible Ways of Safeguarding U.S. National 

Security Interests Related to Computer 

Exports

Page 30 GAO-01-10 Export Controls

noted, however, that changing the operating system on a computer would 

change the measure and that unless the exporter knows what operating 

system the end user has, the measure would be impossible to accurately 

gauge. Nonetheless, the paper suggested continued study of the 

benchmark, which might have more relevance to higher performance 

computers (at 100,000 MTOPS) in the future. We observed that the 

Commerce Department’s National Institute of Standards and Technology 

does research in the area of computer systems performance, promotes the 

effective evaluation and efficient use of advanced computers, and designs 

coherent evaluations that economically and reliably characterize high 

performance computer designs.

Some computer industry representatives said that the industry would never 

achieve consensus on which benchmarks to use. Furthermore, they said 

that once any specific benchmark was established, computer designers 

could circumvent the intent of the benchmark. 

Other Alternatives to 

Replace MTOPS Drawn 

From Studies and 

Discussions With 

Computer Experts

In addition to the three alternatives to replace MTOPS considered by the 

Commerce-sponsored advisory committee, the following two were 

identified from studies and discussions with government and industry 

experts.
Appendix I

Possible Ways of Safeguarding U.S. National 

Security Interests Related to Computer 

Exports

Page 31 GAO-01-10 Export Controls

Indexing Control 

Thresholds 

Sandia National Laboratory, computer industry representatives, and a 

computer expert from academia have presented the idea of indexing the 

control thresholds through the use of various criteria, including (1) actual 

sales or market data or (2) a list of the 500 most powerful computers, 

which is maintained by the University of Tennessee and the University of 

Mannheim.2

Actual Sales According to an analysis prepared by Sandia National Laboratory, one way 

of implementing a sales-based index would be for the Secretary of 

Commerce, in consultation with other agencies, to determine every 

6 months or after a petition by industry, which U.S.-origin microprocessors 

have entered into mass production during the preceding 180 days. The 

Secretary would then have 30 days to make the determination. Computers 

incorporating such microprocessors could then be controlled by requiring 

export licenses based on a multiple of the performance of a single 

mass-produced microprocessor. Under this indexing option, U.S. computer 

companies would have to first establish a threshold level of sales within the 

United States before they are exported, according to Sandia National 

Laboratory. The threshold might initially be 100, 500, or more commercial 

sales within the United States and maybe tier 1 countries to establish that 

the product is indeed a broadly applicable, commercial product. Once the 

company demonstrates that it has reached the threshold through actual 

sales, it would no longer be prohibited from exporting such computers to 

tier 2 and tier 3 countries, although documentation of end use and controls 

could be maintained for tier 3 countries, according to Sandia National 

Laboratory.

Experts we consulted raised concerns about whether the sales or 

market-based data would be reliable and a U.S. government official told us 

that this option was flawed because it would not be based on national 

security interests. Finally, some computer industry representatives 

questioned whether this control could be effectively implemented because 

2

To provide a better basis for statistics on high performance computers, the University of 

Tennessee and the University of Mannheim maintain a list of sites that have the 500 most 

powerful computer systems installed in the world. The Top 500 List has been updated twice 

a year since June 1993 with the help of high performance computer experts, computational 

scientists, manufacturers, and the Internet community who responded to a questionnaire. 

The producers of the Top 500 List have also used parts of statistical lists published by others 

for different purposes.
Appendix I

Possible Ways of Safeguarding U.S. National 

Security Interests Related to Computer 

Exports

Page 32 GAO-01-10 Export Controls

of a perceived government inability to keep up with market and/or 

technological changes. 

Top 500 List Another proposal suggested by some experts we consulted was to apply 

export controls to computers based on the list of the world’s top 500 most 

powerful computers maintained by the University of Tennessee and the 

University of Mannheim. For example, licenses could be required for 

computers whose capabilities qualified them for inclusion on the list, at 

least at the 500th rank. Alternatively, the threshold could be set for 

computers surpassing the 250th, 100th, or any other ranking on the list.

Proponents of this idea point out that the list is based on a transparent 

measure: a publicly available, testable benchmark. Unlike the current 

control system, this list would not be subject to sudden and significant 

changes in license thresholds due to marketplace changes in just one or 

two chips. The controls would therefore be tied much more closely to 

technological realities. 

Other Ideas for 

Safeguarding U.S. 

National Security 

Interests

In addition to ideas to replace MTOPS discussed above, the following seven 

ideas were identified from studies and discussions with government and 

industry experts as other ways to protect U.S. national security interests 

relative to high performance computer exports.

Tagging and Remote 

Monitoring

Tagging and remote monitoring is an idea that has been discussed in export 

control literature for several years. It is achieved by attaching a monitoring 

system to the item that is to be exported. The active system would both 

monitor the object tagged and communicate that information to the United 

States. Elements of a remote monitoring system are data acquisition, 

communications, and a command center.

U.S. government officials3

 and computer industry representatives pointed 

out several limitations of tagging and remote monitoring. Both procedures 

require the cooperation of the end user of the computer system. In 

addition, the American computer industry may resist having its products 

3

 These officials were from the Lawrence Livermore, Los Alamos , and Sandia National 

Laboratories and the Department of Energy.
Appendix I

Possible Ways of Safeguarding U.S. National 

Security Interests Related to Computer 

Exports

Page 33 GAO-01-10 Export Controls

tagged, given that this practice might discourage legitimate foreign 

customers from buying American computers because of privacy concerns, 

according to the officials. They also noted that a remote monitoring system 

for exported computers might not be feasible because of the resources that 

might be required to monitor computer operations and send data to the 

United States. Also, even remote monitoring of computer operations 

cannot distinguish how the computer is being used and for what 

applications, according to the officials. Some officials cautioned that any 

type of tagging or remote monitoring to which the end user has 

unsupervised access could be tampered with without the U.S. government’s 

knowledge. 

Assessing End-User 

Attainable Performance

This idea is simply a modification of the current licensing process for 

determining when export control thresholds apply. Under this approach, 

the licensing threshold would be applied according to the potential 

capabilities of a computer system, rather than the actual performance level 

at the time of sale, as under the current system. One option would be to 

retain the MTOPS measure and adjust the control level to account for the 

maximum processing capability of the system instead of setting the 

threshold based on the capabilities of the system as configured at the time 

of shipment. For example, under the current system, a computer that had 

four microprocessor slots but was shipped with only one microprocessor 

would likely be exported without a license. However, the end user could 

buy three additional uncontrolled microprocessors and increase the rated 

performance. Considering the end user’s attainable performance, the 

system would be rated at its full four-processor potential and likely require 

a license to better reflect the true capabilities acquired in the purchase. 

This standard could be applied in any performance-based system, whether 

using MTOPS or another measure. 

Proponents of end-user attainable performance as a measure argue that 

controls based on maximum capabilities prohibit the buyer from increasing 

the capabilities of the purchased system without the U.S. government’s 

knowledge. One criticism of this approach is that clustering can still 

obviate the control because users can link computers together after 

delivery without detection by the U.S. government. This control could also 

be rendered less effective or ineffective by advancing technology that 

allows users to upgrade their computers with next generation chips, 

making the capabilities of the systems shipped difficult or impossible to 

track. In addition, some critics stated that this control is not replicable in a 

consistent fashion and raised questions about how to choose the control 
Appendix I

Possible Ways of Safeguarding U.S. National 

Security Interests Related to Computer 

Exports

Page 34 GAO-01-10 Export Controls

levels and use them. Finally, some doubted the acceptability of this option 

within the computer community.

Raising Export Control 

Thresholds to the Level 

Obtained by Clustering

Under this option, the government could set the control levels to match the 

computational power that can be effectively provided by computer clusters 

composed of readily available components. This approach to setting export 

control levels is based on the notion that effective parallel computers can 

today be built using readily available commercial computers and 

networking technology with performance between 50,000 to 70,000 

MTOPS. Periodic revision of the export control levels could reflect the 

combined effects of advances in central processor unit technology and the 

increasing capabilities of adjunct technologies in communications and 

networking to achieve very high levels of computing power by linking 

together larger numbers of computers.

Using this approach, today’s large inconsistency between the levels at 

which high performance computers are controlled and the performance 

levels achievable by commercially available parallel clusters would be 

eliminated, according to the Lawrence Livermore National Laboratory 

analysis.4

 The analysis stated that the true state of U.S. exposure to 

changing national security threats would be acknowledged and addressed. 

Appropriately responding to the implications of the actual availability of 

high performance computing would require extensive review and 

discussion in the national security community. Some critics of this 

approach stated that this control is not replicable in a consistent fashion 

and raised questions about how to choose the control levels and use them. 

4

 The National Security Implications of Decontrolling Export to Tier III Countries of High 

Performance Computers between 2,000 and 40,000 MTOPS (Feb. 2000).
Appendix I

Possible Ways of Safeguarding U.S. National 

Security Interests Related to Computer 

Exports

Page 35 GAO-01-10 Export Controls

Controlling Software 

Applications

This option involves denying countries of concern key software 

applications used in high performance computing through the use of 

security classifications and/or export controls. According to the Director of 

DOD’s High Performance Computing Modernization Program,5

 one concept 

under discussion is the development of approaches to ensure that software 

is used as intended and authorized. He said that research would be needed 

to develop encryption technology to restrict access for source and 

executable applications. The intent of this concept is to develop means that 

will prevent militarily relevant applications from operating on unauthorized 

machines. The official stated that technology advances can provide 

improved protections for militarily relevant applications. According to the 

DOD Deputy Under Secretary (Science & Technology), militarily significant 

software might be made more tamper-proof, that is, able to operate on only 

one type of machine or to self-destruct if tampered with. The official said 

that DOD is just beginning to examine this option. 

The prevalent view among government and computer industry officials 

with whom we spoke is that the applications software that can be 

controlled is already protected by security classification, export controls, 

and proprietary rights and that commercial dual-use software cannot be 

controlled. A Lawrence Livermore National Laboratory analysis pointed 

out that some software used in clusters is freely available on the Internet. 

Operating systems such as Linux can also be downloaded free from the 

Web. Even operating systems like Windows NT or Windows 2000 are sold in 

such quantities that controls are viewed as impractical and unenforceable. 

Research and academic institutions whose culture is characterized by the 

free exchange of information and software are notable users and 

developers of high performance computing technology. Thus, it is difficult 

to find any part of the software application market that lends itself to 

controls because distribution is easy and applications of national interest 

are already tightly held by their owners, either through security 

classification or efforts to protect a commercial interest. In contrast, the 

Director of DOD’s High Performance Computing Modernization Program 

stated that dual-use applications are being controlled to a limited extent. 

5

 The DOD High Performance Computing Modernization Program provides advanced 

hardware, computing tools, and training to DOD researchers utilizing the latest technology 

to aid their mission in support of the warfighter. The program seeks to modernize the total 

high performance computational capability of DOD Science and Technology, Development 

Test and Evaluation, and Ballistic Missile Defense Organization to a level comparable to that 

available in the foremost civilian and other government agency research and development 

environments.
Appendix I

Possible Ways of Safeguarding U.S. National 

Security Interests Related to Computer 

Exports

Page 36 GAO-01-10 Export Controls

He noted that several commercially available applications cannot be run 

without receiving an annually provided key from the vendor.

Controlling Technology 

Used for Interconnection

The idea of controlling technology used to link computers together is based 

on the control of the number and capability of commercial readily available 

parallel clusters that can be created by controlling networking hardware 

such as switches, interface cards, and related equipment. 

However, the hardware used in high-speed, commercial, ready-made 

networking is already widely available and relatively inexpensive 

throughout the world, according to U.S. government officials6

 and 

computer industry representatives. They believe that establishing controls 

at this point would be extremely difficult, if not impossible. To be effective, 

this approach would depend on networking technology originating solely in 

the United States or countries with binding agreements to enforce U.S. 

export control objectives, according to U.S. government officials and 

computer industry representatives. However, manufacturing capability for 

interconnecting technology is available worldwide, and with the growth in 

the cluster market, it will be considerably more difficult to restrict supply. 

Industry representatives consider only some of the equipment related to 

this technology controllable at the higher end of the market because of its 

proprietary nature and the continued importance of vendor support.

Controlling Computer 

Systems Based on 

Bandwidth 

According to the Director of DOD’s High Performance Computing 

Modernization Program, a concept under discussion would develop a 

methodology to control computer systems by some measure of processorto-main-memory bandwidth7

 and potentially the number of processors in 

each system. The methodology would need to distinguish between 

commodity systems and the traditional class of supercomputers 

characterized by specialized processors. Such computer systems typically 

have a single processor and require a high level of bandwidth, such as those 

manufactured by Cray, NEC, and Fujitsu. Another official from DOD’s High 

Performance Computing Modernization Program said that these computers 

still possess capabilities, capacities, and characteristics that should be 

6

 Officials were from the Lawrence Livermore, Los Alamos, and Sandia National 

Laboratories and the Departments of Commerce, Defense, and Energy.

7

Bandwidth is the amount of data that can be transmitted in a fixed amount of time.
Appendix I

Possible Ways of Safeguarding U.S. National 

Security Interests Related to Computer 

Exports

Page 37 GAO-01-10 Export Controls

denied to countries of concern. The DOD official identified as a concern 

those computers that can solve militarily significant problems that cannot 

be broken down and operated on clustered systems. Computer industry 

experts placed the total market for these computers in the range of 300 per 

year. The Department did not provide any additional information about this 

option because it was still under review.

Implementing 

Countermeasures to 

Military Advantages Gained 

by Countries of Concern 

From More Advanced 

Computer Exports 

Using this option, DOD would design countermeasures to deal with the 

implications of wider computer availability. One purpose of export controls 

is to maintain the U.S. technological lead in military capabilities by denying 

transfers of advanced technology to countries of concern. As technological 

advances in high performance computing make this purpose more difficult 

for export controls to achieve, it may become necessary to explore other 

options to maintain the U.S. technology lead. As a step in this direction, 

section 1402 of the National Defense Authorization Act for Fiscal Year 2000 

requires an annual report on transfers of militarily sensitive technology to 

countries and entities of concern. It is to include an assessment by the 

Secretary of Defense, in consultation with the Joint Chiefs of Staff and the 

Director of Central Intelligence, on the cumulative impact of U.S.-granted 

licenses for exports of technologies and technical information. This report 

is required to include information on countermeasures that may be 

necessary to overcome the use of such technologies and technical 

information. It is not required to include an assessment of the cumulative 

impact of nonlicensed computers, such as those that could be clustered. 

The report is scheduled for completion in late 2000.
Page 38 GAO-01-10 Export Controls

Appendix II

Additional Information on Computer 

Clustering Technology and MTOPS ApendxiI

In the past few years, broadly recognized technological advances in the 

ability to cluster together low performance computers have resulted in an 

increasing capability worldwide to achieve high performance computer 

levels. As a result, the known performance levels of clustered systems 

exceed the export control thresholds set by the U.S. government. In 

addition, U.S. government officials1

 and computer industry representatives 

have discussed the shortcomings of the MTOPS measure for export control 

purposes and now agree that MTOPS is no longer a valid measure of 

computer performance and needs to be replaced. 

Computer Advances in 

Clustered Systems 

Technological advances in computing that would threaten the effectiveness 

of export controls have been expected for several years. For example, a 

1994 U.S. government study2

 warned that technological computing 

advances would seriously impair the ability of U.S. export controls to 

protect computer technology by the turn of the century. A Defense- and 

Commerce-commissioned team in 19953

 reviewed the computer industry’s 

technological advances in parallel processing and concluded that advances 

in clustering contribute to the uncontrollability of high performance 

computing worldwide and inevitably reduce the effectiveness of U.S. 

export controls. One of the technology trends of concern at that time 

included other countries’ ability to link individual computers to achieve 

higher performance levels. We reported 2 years ago that trends in high 

performance computing technology development might pose security and 

export control challenges and recommended further study to determine 

their implications for national security and export controls.4

According to a Lawrence Livermore National Laboratory analysis dated 

February 2000, in determining the usefulness of clusters made with readily 

available commercial components, the following four aspects of computing 

must be considered:

1

 U.S. government officials include the Deputy Under Secretary of Defense (Science and 

Technology) and officials of the Commerce and Energy Departments.

2

 The unclassified title of this classified report is High Performance Computing Technology: 

Implications for Development of Weapons of Mass Destruction.

3 High-Performance Computing Export Control Policy in the 1990s (Palo Alto, CA: Stanford 

University, Center for International Security and Arms Control, 1995).

4 Export Controls (GAO/NSIAD-98-196, Sept. 16, 1998).
Appendix II

Additional Information on Computer 

Clustering Technology and MTOPS

Page 39 GAO-01-10 Export Controls

• Performance, flexibility, low cost, and the ease of integration, taken 

together, make the development of effective parallel computers using 

commercial readily available networking hardware dramatically easier 

than it was just 3 years ago, according to Lawrence Livermore National 

Laboratory officials. Commercial clusters of readily available 

components perform up to about a third as well as today’s best 

distributed memory parallel computers (stand-alone high performance 

computers), while the cost of clustering adds only 10 to 30 percent to 

the cost of the computers that are clustered. 

• The system software necessary to integrate a cluster of computers into 

an effective computing system with a correspondingly higher capability 

than its individual constituent processors is now widely available. 

• Programming a commercial cluster of readily available components is 

no different from programming most other commercial parallel 

processing computers because the system software is the same on both. 

Computer science departments in universities worldwide teach 

concepts to support the development of parallel applications for 

commercial, readily available clusters. Other U.S. government and 

computer industry specialists, however, stated that there might be some 

number of computer applications that cannot be adapted for clustered 

parallel processing. To the extent that such applications are militarily 

significant and must be operated on individual computers, maintaining 

threshold controls on these machines could still be effective. 

• Support for computer functions means having an efficient schedule for 

running hundreds of separate problems and the input and output of data 

among a computer, its local disks, networks, and archival storage. 

Without vendor-supplied software to automate these functions, 

everything must be done manually, making production computing a 

labor-intensive operation. While U.S. practice is to pay computer 

vendors to supply this support, foreign countries such as India and 

China, where skilled labor is plentiful and low cost, may find providing 

this support much less of a problem.

Other U.S. government and computer industry specialists also stated that 

there might be some computer applications that cannot be adapted for 

clustered parallel processing. The President’s August 30, 2000, report 

indicated that some small number of computer applications still requires 

traditional computer systems and that the lack of hardware may be a 

barrier to solving certain kinds of problems. The President’s report did not 

identify these applications. However, computer applications that have 

problems which cannot be broken up to be solved in parallel and 

applications associated with battlefield operations that rely on rapid 
Appendix II

Additional Information on Computer 

Clustering Technology and MTOPS

Page 40 GAO-01-10 Export Controls

solutions might not practically be run on clustered computer systems, 

according to ISTAC members and a DOD official.

Shortcomings of 

MTOPS as a Measure 

of Performance

U.S. government officials5 and computer industry representatives agreed 

that MTOPS is no longer a valid measure of computer performance and 

needs to be replaced. In 1991, the Commerce Department began using 

MTOPS as a measure to decide when an export license would be required 

for high performance computers. But because of the diverse computer 

designs that have evolved since then, the increasing performance level of 

commercial microprocessors, and the capability to connect local and wide 

area networks, it became prudent to reexamine the suitability of MTOPS as 

a measure, according to the Institute for Defense Analyses. As a result, 

under DOD auspices, U.S. government officials, computer industry 

representatives, and academics met in December 1997 to determine 

whether the use of MTOPS is sufficient to rate the relative performance of 

current and future computer systems. They determined the following:

• The use of MTOPS was still an effective means at that time for 

determining export controls for a single computing element. The 

attendees stated that modest refinements could be made to the MTOPS 

measure for systems comprising aggregate computing elements.

• There could be variances up to a factor of 2 in the actual performance of 

delivered systems relative to the MTOPS-calculated performance 

because of the wide range of designs in use. Continuing rapid changes in 

technology might result in yet larger variances in the near future.

• Any export control measure should be reevaluated every 2 years 

because of the rapid changes in computer designs.

By 2000, however, it had become clear to both government and industry 

computer experts that MTOPS does not account for new processor 

designs, particularly those dependent on the capability to exchange 

information internally at high speeds. Representatives of three computer 

companies said that MTOPS was an archaic measure not designed with 

new chip designs in mind and should be replaced. The MTOPS measure 

today is unreliable because it does not account for certain factors, such as 

memory access times, interconnection methods, and internal bus speeds. 

As a result, two microprocessors with the same megahertz could have 

5

 U.S. government officials include the Deputy Under Secretary of Defense (Science and 

Technology) and officials of the Commerce and Energy Departments.
Appendix II

Additional Information on Computer 

Clustering Technology and MTOPS

Page 41 GAO-01-10 Export Controls

different MTOPS ratings if the additional factors were considered. The 

MTOPS indicator also would be inaccurate if it were applied incorrectly for 

computing elements organized in certain ways, such as in clusters of 

individual computers. It is not accurate to take the MTOPS measure of one 

clustered machine and multiply it by the total number of computing 

processors of the cluster because key characteristics, such as the time 

taken to distribute tasks and exchange intermediate results, have not been 

taken into account. 
Page 42 GAO-01-10 Export Controls

Appendix III

Identified Applications of National Security 

Importance ApendxiI

This appendix lists the applications of national security importance 

identified for the 1998 Defense- and Commerce-sponsored study, which 

was the basis for information on computer applications in the President’s 

reports in February and August 2000. The list is reprinted in its entirety as it 

appeared in the 1998 study.
Appendix III

Identified Applications of National Security 

Importance

Page 43 GAO-01-10 Export Controls
Appendix III

Identified Applications of National Security 

Importance

Page 44 GAO-01-10 Export Controls
Appendix III

Identified Applications of National Security 

Importance

Page 45 GAO-01-10 Export Controls
Appendix III

Identified Applications of National Security 

Importance

Page 46 GAO-01-10 Export Controls
Appendix III

Identified Applications of National Security 

Importance

Page 47 GAO-01-10 Export Controls
Appendix III

Identified Applications of National Security 

Importance

Page 48 GAO-01-10 Export Controls
Appendix III

Identified Applications of National Security 

Importance

Page 49 GAO-01-10 Export Controls
Appendix III

Identified Applications of National Security 

Importance

Page 50 GAO-01-10 Export Controls
Appendix III

Identified Applications of National Security 

Importance

Page 51 GAO-01-10 Export Controls
Appendix III

Identified Applications of National Security 

Importance

Page 52 GAO-01-10 Export Controls

Source: High-Performance Computing, National Security Applications, and Export Control Policy at the 

Close of the 20th Century, Seymour E. Goodman, Peter Wolcott, and Patrick Homer, (Palo Alto, CA: 

Stanford University, Center for International Security and Arms Control, 1998).
Page 53 GAO-01-10 Export Controls

Appendix IV

Comments From the Department of 

Commerce ApendxiIV

Note: GAO comments 

supplementing those in the 

report text appear at the end 

of this appendix.

See comment 1.

See comment 2.
Appendix IV

Comments From the Department of 

Commerce

Page 54 GAO-01-10 Export Controls
Appendix IV

Comments From the Department of 

Commerce

Page 55 GAO-01-10 Export Controls

The following are GAO’s comments on the Department of Commerce’s 

letter dated November 16, 2000.

GAO Comments 1. Our report stated that the computer licensing level for tier 3 countries 

was raised to 28,000 MTOPS, effective immediately. Commerce’s letter 

refers to the 28,000 MTOPS threshold at which advanced notifications 

to Commerce of computer exports would be required. According to the 

President’s August 30, 2000, letter transmitting his report justifying 

changes to computer export control thresholds, “the new level above 

which an individual license will be required for exports to tier 3 

countries is 28,000 MTOPS. The aforementioned licensing adjustments 

will take place immediately.” Furthermore, an October 13, 2000, rule 

amending the Export Administration Regulations stated that the upper 

licensing level for computer tier 3 countries was raised from 20,000 to 

28,000 MTOPS. In comparison, the President reported in the same 

August 30, 2000, letter transmitting his report that he was establishing a 

new notification level of 28,000 MTOPS which cannot take effect until 

180 days after the Congress receives the President’s Report, that is, 

February 2001. Section 1211 (a) of the National Defense Authorization 

Act for Fiscal Year 1998 (P. L. 105-85) requires exporters to notify the 

Commerce Department of any proposed high performance computer 

exports to countries that pose a concern for military or proliferation 

reasons to determine if these exports need a license. Also, the 

October 13, 2000, rule amending the Export Administration Regulations 

stated that the level for advance notification of high performance 

computer exports to tier 3 countries was raised from 12,500 MTOPS to 

28,000 MTOPS, effective on February 26, 2001. 

2. We have clarified the sentences related to the 1998 Defense- and 

Commerce-sponsored study in response to Commerce’s suggestions by 

adding language to stress that “DOD officials responsible for the 

sections of the report on military uses of high performance computers 

told us that they relied on the 1998 Department of Defense- and 

Commerce-sponsored study for support in the President’s reports.” 

(711480) Letr
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