US ITAR and EAR - Export Control and Data Security
Controlled technical data and technology: exports, releases and access – US ITAR and EAR - Export Control and Data Security

US ITAR and EAR - Export Control and Data Security ITAR 120.54(a)(2)-(3) and EAR 734.18(a)(2)-(3): Rely on the U.S.-person-only transfer carve-outs within their limits

Transmitting technical data or technology to a U.S. person in the United States from another person in the United States is not an export, and transferring it within the same foreign country among U.S. persons only (ITAR) or among persons who are not foreign persons (EAR) is not an export, reexport or transfer, so long as the transfer does not result in a release to a foreign person or a prohibited person (120.54(a)(2)-(3); 734.18(a)(2)-(3)). Internal data flows can be designed around these carve-outs, but they depend on knowing that every recipient, including IT and support staff with access to the channel, is a U.S. person.

Maintained by Gerard BlokdykVerified against the published standard Control text last updated

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  • 734.18 734.18 Activities that are not exports, reexports, or transfers

Every mapping shown was judged rather than inferred from wording similarity, and the ones that failed review are published too. See the coverage reports and what was rejected.

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