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Deemed Exports/Technical Data Transfers

The definition of an export is not limited to the physical shipment of commodities from one country to another. Rather, export also encompasses the release of controlled technology/technical data or software to foreign persons in the United States or abroad. Such transfers are “deemed” to be an export to the home country of the foreign person in question. In some cases, companies may be required to obtain prior authorization from government agencies before access to controlled technology/technical data or controlled software is provided to foreign persons—including their own employees.

ST&R and STTAS assist companies in identifying controlled information or software received, developed or utilized by the company through internal reviews. Our team works with companies to design and implement the necessary physical and IT security controls to prevent unauthorized access by non-US persons. This includes the drafting, implementation and rollout of Technology Control Plans and Technology Transfer Control Plans. We also work with companies to obtain any necessary licenses that may be required in order to allow non-U.S. persons to have access to controlled information/software.

T: 312.279.2832
Member
  • ST&R
T: 415.490.1430
Export Controls Practice Leader
  • ST&R
T: 619.471.1415
Senior Export Controls Advisor
  • ST&R
T: 202.730.4966
Of Counsel
  • ST&R
T: 248.474.7200
President & Chief Operating Officer
  • STTAS
T: 202.730.4975
Member
  • ST&R
T: 202.730.4967
Member
  • ST&R

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