Providing controlled technology* to a foreign national* in the United States* or abroad is considered an export to the country of residence of the foreign national*. For example, an export of night vision googles to a foreign country would be the same as sharing design information on night vision googles to a foreign national* of that country.
Other ways to export data without actually sending the information abroad are:
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Sharing controlled data at a conference anywhere in the world with foreign nationals present
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Allowing a foreign national* to observe how controlled goods are developed and/or produced
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Providing instruction to a foreign national* on how a controlled good is “used” (operation, installation, maintenance, and repair)
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E-mailing controlled data to a foreign national* located in the United States* or abroad
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Providing information to another person with the intention that the data or technology will be shared abroad or with a foreign national* whether in the United States* or not.
An export occurs with "the release*" of controlled technology* to a foreign national*. "'Release' is defined as:
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Visual inspection by foreign nationals
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Oral exchanges of information in the United States* or abroad
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Applying personal knowledge or technical experience acquired in the United States* while abroad
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Technology is defined as specific information necessary for the ‘development’, ‘production’, or ‘use’ of a product. The information takes the form of “technical data” or “technical assistance.”