Context: Forward-looking enforceability claim tied to the January 2026 rule; still open, but this cycle added the first on-the-record challenge to the “implementable, enforceable” half. On 2026-07-23 Senator Elizabeth Warren, ranking member of Senate Banking, invoked the Export Control Reform Act to compel BIS to document what she calls a foundry loophole: the January 2025 Foundry Due Diligence rule presumes advanced chips need licences, but rests on the AI Diffusion Rule’s worldwide licence requirement, and she argues the May 2025 rescission removed that predicate — citing reporting that it “may be allowing an unknown number of high-end semiconductors to reach Beijing.” That is an allegation from a minority-party document, not a finding; BIS’s response is due 2026-08-07 and is the next checkable milestone. Not resolvable before the 2027-12-31 horizon.