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on existing customers as well as when entering new cus-
tomers. Many such programs also contain other compli-
ance features within the software program.
DEEMED EXPORTS
Companies that allow foreign nationals into their plants,
share technology with them, or transfer to them as employ-
ees or partners or in a third party relationship are subject to
deemed export regulations.
BIS TRANSSHIPMENT COUNTRY
EXPORT CONTROL INITIATIVE
The government defines exports to in-
clude transfer of wherewithal, technology,
and capability. Technology is an export when it has been
“deemed” to take place when released to a foreign ...