ITAR Technical Data Gate
13 of 17 transfers need action before release: 2 prohibited under 126.1, 3 need a license, 6 exemption candidates to confirm, 2 data issues or claims to review; 4 can proceed.
us_person is Y and employee_of_exporter is Y, and the data goes to United Arab Emirates, not a 126.1 country: USML Category VIII(h) to a U.S. person employee abroad is a 125.4(b)(9) candidate, not yet applied.
Method1Public domain (22 CFR 120.34) and fundamental research at accredited U.S. institutions of higher learning (120.34(a)(8)) are not ITAR-controlled; basic marketing information and general system descriptions are not technical data (120.33(b)).
2A transfer to a U.S. person in the United States is not an export; sending technical data abroad, or releasing it to a foreign person in the United States, is an export (120.50).
| Document | Recipient | Location |
|---|---|---|
| TD-1002 | Rachel Kim | AE |
| TD-1005 | Marek Kowalski | PL |
| TD-1006 | Aarav Mehta | PL |
Planned technical data transfers (document, USML category, recipient, country)
License or exemption determination per transfer (Determination log (CSV), 123.26 exemption record log (CSV), Determinations (JSON))
$3,500 / month, 30% to the referring partner
Read in memory for the session, never stored, never used to train a model.
Screening is not clearance. Classification and sanctions decisions remain yours and your licensed trade counsel's or customs broker's.