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ARTICLE · 06 FEBRUARY 2025

Understanding U.S. Deemed Export Rules: A Guide For Businesses

Honigman LLP
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In this issue of Global Trade Navigator, we are providing an overview regarding deemed export control requirements.

United StatesInternational Law
Angela Gamalski
Angela Gamalski

In this issue of Global Trade Navigator, we are providing an overview regarding deemed export control requirements. For companies employing foreign nationals, understanding the intersection of immigration status and export control regulations is crucial. Such business collaboration fosters innovation and growth, but also brings regulatory challenges, particularly concerning deemed exports. This article explores the basis of U.S. deemed export rules, how these rules vary between the different regulations controlling dual-use and military-grade technologies and outlines basic steps businesses should take to ensure compliance.

What Are Deemed Exports?

To start, a "deemed export" refers to the release or transfer of controlled technology or source code to a foreign person within the U.S.. This is considered an export to the person's home country, even if the technology never leaves U.S. soil.

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