Hi Ben, *
Am 18.06.11 21:37, schrieb BRM:
AIUI it would be a good idea for the TDF to consult it's US legal team
about whether this is really the case...
Very much so, especially since from what Export Control training I have had,
even a patch from a developer in the US would be considered an export to TDF/LO
and thereby require an export license. IANAL, and that may fly under the radar
easily; but it is something to have the legal team consider.
"Firms exporting products that are subject to EAR must apply for an
export license, unless the transaction qualifies for a license exception
or “No License Required” (NLR) treatment. When a Shippers Export
Declaration (SED) is required for the export transaction (for shipments
over $2,500 value, those requiring an export license, or those going to
countries that have been designated as terrorist supporting countries),
the ECCN must be provided."
Obviously, LO is not a Firm nor does the value of the "exported product"
exceed 2.500$. So we need no SED and maybe that qualifies for an NLR
Mit freundlichen Grüßen
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