Steven Brotherton, Todd Willis, Elizabeth Shingler, and Matthew Lombardo, KPMG LLP Introduction In export compliance, the term “technology” is discussed as though if it were something shipped in a box. In reality, however, many of the most consequential exports occur without a physical shipment at all. Under the U.S.’s approach across the Export Administration Regulations (“EAR”) and International Traffic in Arms Regulations (“ITAR”) – technology can be exported both through tangible and intangi...
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