Deemed Export

Questions and answers about Deemed Export

  • DEEMED EXPORT LICENSE

    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 […]

  • LOE FOR DEEMED EXPORT LICENSE

    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. ***********

  • DEEMED EXPORT REVIEW PROCESS

    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.  […]

  • Deemed export

      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 […]

  • DEEMED EXPORT RECORD KEEPING

    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 […]

  • DEEMED EXPORT SCREENING PROCESS

    Question:My company currently manufactures controlled product in the UK and had to obtain a license to release the controlled technology to personnel from our UK facility.  I am trying to put a process in place for the UK that would limit access to the controlled technical data to non UK personnel and visitors to our […]

  • DEEMED EXPORT SCENARIO

    Question: A student is looking to gain a 6 month co-op at our company.  Thisstudent is here in the US on a student VISA and is a citizen of China.Currently, all our parts are classified as EAR99.  In the past we didproduce some parts that fell in category 3 and 5 on the EAR, which […]

  • DEEMED EXPORTS AND VISITOR SCREENING

    We would like to know how other companies screen visitors for the purpose of controlling deemed exports? Is proof of citizenship required? or are visitors simply asked to please indicate their country of citizenship without demonstrating proof?    

  • Deemed Export Q&A 1

    How do you limit access to your foreign nationals (say in China) to controlled technology information that may be available on the internal company web site?

  • Deemed Export Q&A 2

    We are interested giving access to portions of our ERP system to a Foreign National Employee. I am suppose to review what we can and cannot release incase it would be controlled for export. Besides general government export controls on controlled technology the other thing I thought of is any of our defense contracts and […]