BIS Updates Deemed Export Licensing Guidance

The Bureau of Industry and Security this week updated its guidance on applying for deemed export licenses, which people or companies must obtain before sharing a controlled item, software or technology with a foreign person on U.S. soil if a license would normally be required for that person's most recent country of citizenship or permanent residence. The guidance outlines the type of information applicants must submit, the information BIS takes into account when reviewing those licenses, and the set of conditions that the agency said are “standard” for approved licenses. A list of license condition best practices includes a reminder that approved applicants must annually verify to BIS that the foreign person has a “required work authorization” or that the foreign person has left the country.