However, China has not remained passive. It has imposed its own restrictions on critical minerals used in semiconductor production and has been stockpiling older chips and manufacturing equipment it can still access. A robust black market for banned chips has emerged, and some Chinese companies have found ways to evade the restrictions.

For the White House, keeping pace with these workarounds has been a constant challenge. The administration has already updated its export controls multiple times, with allies following suit. This cat-and-mouse game is likely to continue well beyond Sullivan's time in office.