BIS Deemed Exports Advisory Opinion

Posted 8/17/23

The Bureau of Industry & Security published an advisory opinion on the release of licensed technology to employees of the foreign subsidiary while on temporary work assignment at the home office. 

No additional deemed export license is required for these employees,

while any new “technology” or “software” that is either “released” to those employees in the United States or created in the United States that is not authorized by the existing BIS license would require a new export license or other authorization from BIS.

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