QUESTION: I would like to know whether we need to report a change in status of the FN holding the Deemed Export License when their VISA status changes, or that the FN is now a permanent residents of the United States, or is now a U.S. Citizen while their deemed export license is still active […]
QUESTION: I would like to get the membership’s feedback on how to handle Deemed Exports for Foreign Nationals. We have over 1,000 contract workers working on IT projects at our Corporate HQ. I believe some of these are Foreign Nationals who are releasing technology and source code. Since I have a possible Deemed Export, what […]
Question: I have a concern a about a possible Deemed Export situation. We recently had a foreign national visit . He was trained to operate a medical equipment system that contained a software function. When the foreign national returns to his country he will train others and show them how to use the equipment. Would […]
Question: Under the deemed export rule for the EAR, does anyone believe it would be possible to license the physical drawing to our division in China, and avoid having to license 50+ engineers? My gut tells me “no”, that the whole spirit of the rule is to restrict access to foreign nationals in controlled countries or […]
Question: We expect to receive a license to export (to a wholly-owned sub in a CB2-controlled country) all development, production and use technology for a certain product. After we get the license and export this technology to the foreign sub, we expect that employees of this foreign sub, who are citizens of that local country, […]
Question: I need a clarification on the Deemed Export Regulation. We are a distributor of medical products and our Distribution Centers are used for storing products and not manufacturing them. When foreign nationals visit our DC’s for a tour or for a sales meeting, are we required to report these visits ? *************** ANSWERS: First […]
Question: Preparing my first Deemed Export License application to BIS and wondering if anyone has any tips or lessons learned they’d like to share in what should be done to make the application a success. With this being my first, I’d like to avoid the back and forth with BIS and get them all the […]
Question: It’s my first time preparing an LOE for a deemed export license. Would anyone in the membership have a template that they have used that you wouldn’t mind sharing. Sort of urgent, a quick reply would be appreciated. ***********
Question: It’s my first time preparing an LOE for a deemed export license. Would anyone in the membership have a template that they have used that you wouldn’t mind sharing. Sort of urgent, a quick reply would be appreciated. ***********
Question: Has anyone in the membership developed a checklist for reviewing your facilities’ equipment for deemed export / technology transfer concerns they would be willing to share? We have both manufacturing and lab areas (we are an HVAC manufacturer) that have the potential to include some sensitive and possibly export controlled items. […]
Question: We have engineers – Japanese citizens – working in the USA to develop technology and equipment that may result in U.S. patent applications. The technology and equipment is under the EAR, not for military use, and my best understanding is that there is no license required. If the development results in patented […]
Question: Can anyone advise the recordkeeping requirements for a deemed export? Iunderstand the requirements for an item controlled by a license. Am moreinterested in a non-controlled EAR99 or something under a license exception. Are exporters required to keep records of e-mails, drawing transfers,downloads of source code, etc. for any deemed export which is not acontrolled […]
