AMD lists mystery MI388X AI GPU in official docs, says it's barred from China sales due to US sanctions

AMD has listed an unannounced AI chip, the MI388X, in its 10K filing with the SEC, noting that it cannot be sold to Chinese customers due to US sanctions. Companies like AMD and Intel have a plethora of products that can cater to almost any need, and both companies often have so-called 'off-roadmap' products that are not openly listed on their websites - especially if they are custom designs for customers or military applications. However, sometimes, these companies are compelled by law to disclose them elsewhere, which is apparently what has happened with this unannounced AMD Instinct MI300-series product. 

The officially listed MI300 series products consist of multiple configurations with varying distributions of CPU and GPU cores. AMD listed its unannounced Instinct MI388X product in its regulatory 10K filing along with the Instinct MI250, MI300X, and MI300A chips, noting that none of the chips can be shipped to China due to US sanctions on AI processors:

"In October 2023, BIS [U.S. govt. Bureau of Industry and Security] issued new requirements for certain advanced computing items that apply to the export of products classified ECCN 3A090 or 4A090 to a party headquartered in, or with an ultimate parent headquartered in, any of Country Groups D1, D4 or D5, including China," he statement from AMD reads."These controls prevent us from shipping our AMD Instinct MI250, MI300X, MI300A, MI388X integrated circuits and our Versal VC2802, VE2802 FPGAs to China, or to customers outside of the United States whose ultimate parent is headquartered in a D5 country (including China), without a license." [emphasis added]

For now, the only thing clear about the Instinct MI388X is that this is indeed a processor for AI and HPC (as it is marked with the X). We are likely dealing with a semi-custom product, but it is unclear if the processor is tailored for higher performance, lower power, or simply has some custom features for a specific customer. Because this device is listed with the SEC, it can likely be theoretically made available to more than one customer -- as long as they don't reside in China. 

The AMD filing was submitted on January 31, 2024, so the company didn't list the China-oriented Instinct MI309 product that was discovered through a leak in early March. It's also unclear whether the Instinct MI309 is an APU, a GPU, or a product series containing the MI309A APU and the MI309X GPU accelerator. 

The Instinct MI309 also did not meet the U.S. government's export rules as it was too powerful to be shipped to China, so it's possible that the product has been scrapped in its original form. Then again, AMD could further neuter it to reduce its performance and ask the U.S. government whether it can ship it to Chinese entities without an export license.