All companies experience the effect of the global economy, but compliance managers have much more to worry about as they assess trade compliance risk rather than just traditional import and export activities. For example, it’s quite likely that your company has U.S.-based employees who are foreign nationals—and that raises the issue of the so-called “deemed export” rule of U.S. export controls laws.
The premise of deemed exports is that the release of sensitive information to a foreign national, wherever he or she is located, is “deemed” to be an export to that individual’s home country. For example, you might disclose details of a controlled technology to foreign nationals employed by your company in the United States. The same concern exists for non-employees, as well, of course; consultants, contractors, and visitors to your company must not be exposed to export-controlled information during the course of their work or visit to your company in any way. That could be anything from a meeting or other presentation to a tour of the facilities, or through other opportunities for visual inspection.
