April 19, 2011

U.S. Department of Commerce Advisory Opinion on Export Controls

On April 8, 2011, the U.S. Department of Commerce released an Advisory Opinion determining that a third-party client, rather than the staffing company employer of a foreign national, is required to obtain authorization for the deemed export that might occur when the third-party client provides the foreign national with access to technology or source code subject to the Export Administration Regulations (EAR).