All parties to transactions subject to the EAR must comply; delegating tasks to forwarders or other agents does not by itself relieve anyone of responsibility. The U.S. principal party in interest is the exporter and must determine the licence authority and obtain any licence, except in routed transactions where the foreign principal expressly assumes that responsibility in writing, making its U.S. agent the exporter; in that case the U.S. principal must on request give the foreign principal and its agent the ECCN or enough technical information to classify, plus any information it knows affects licensing; agents representing foreign principals need a power of attorney or written authorisation.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.