Corpus v4· 4,812 policies· 28 jurisdictions· Last revision 22 Aug 2026: Affiliates Rule reimposed

Arqis/Solutions/Data centres & infrastructure

Every rack you fill is a cross-border decision.

Hyperscale and sovereign-backed builds source chips from one regime, capital from another, and lease capacity to tenants under all of them. Arqis determines what BIS, CFIUS, outbound investment, MOFCOM and SEC rules require for a single deal, and keeps that answer live for the life of the lease.

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TA-2026-0489
Decided 3 Aug 2026 · corpus v1
Monitored
Conditional

Lease 6MW of AI accelerator capacity to a regional cloud operator whose Series C included a Gulf sovereign LP.

Technology classification3A090.a
Tenant ownership trace31 CFR 850
Destination rules15 CFR 748
Subtenant screening15 CFR 744
Reopened by corpus v4
  • Verdict Conditional → Restricted
  • Ownership threshold 60% → 50%
  • Sovereign LP designated; 60% direct interest now carries restriction

The exposure

One build, six ways to be exposed.

A single facility can carry all of these at once: the chips you sourced, the capital that built it, and every tenant you lease to.

Sourcing15 CFR 748 / 764Accelerator classification, licence conditions, voluntary self-disclosure
Capital stack31 CFR 800CFIUS exposure from foreign LPs and sovereign co-investment
Outbound31 CFR 850AI training compute thresholds where US-affiliated capital funds the build
Hosting15 CFR 744End-use and end-user screening for every tenant, and every subtenant
Bulk dataEO 14117 · 28 CFR 202Bulk personal or government-related data hosted or processed for a country of concern
DisclosureReg S-K · Item 103Materiality and MNPI at signing, and again at every renewal

Continuous monitoring

Capacity moves faster than the paperwork.

A lease is signed once. The tenant behind it, and the tenants they sublease to, keep changing for the life of the contract.

First

The rule changes

A threshold moves, an entity is designated, a suspended rule reimposes. Every lease determination that cited the affected policy re-runs and reopens if it no longer clears.

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Second

The tenant changes

A cap table shifts, a restricted identity authenticates against the cluster, capacity is subleased to an operator who was never in the original assessment. The conditions your lease depends on become monitored controls.

Verify

We don't decide who should get capacity.

Arqis determines what each applicable regulatory regime requires for the deal in front of you. A US-anchored operator, a European colocation provider, a Gulf-backed developer and a Southeast Asian data centre can all rely on the same determination.

Decide

Cited, test by test

Every test on a lease or a sale names the rule it applied, the effective date, and the confidence. The reasoning is exposed rather than asserted.

Verify

Tenants become monitored controls

Ownership, designation status and end-use conditions are watched for the life of the lease, not assumed at signing and forgotten.

Escalate

Arqis computes, counsel judges

A contested tenant or a disputed classification goes to your own counsel, carrying the full trace, so they start from our work rather than from zero.

Who it's for

Built for the teams who sign the lease.

Arqis sits wherever a data centre or infrastructure decision has to be defended later, not just cleared once.

Site & infrastructure leadership

Know before you commit the rack

Screen a sourcing or hosting decision against all six regimes before capacity is allocated, not after a tenant is already live.

Legal & trade compliance

One file per facility, not per memo

Every lease and sourcing decision cited to the rule that produced it, consolidated into a single record that stays current.

Capital markets & investor relations

Answer the LP question before it's asked

Show a lender, a co-investor or a rating agency a determination that is monitored, not a memo that is already stale.

Commercial & leasing teams

Close without the six-week legal loop

Give sales a cleared position on a prospective tenant in hours, with the trace attached if counsel needs to weigh in.

Working session

Bring us one lease you're unsure about.

Ninety minutes. We run it against all six regimes on your own tenants and show you the trace. No slides.

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Tell us roughly what the transaction involves

We reply within one business day. Or email team@arqis.ai directly.

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