Authority, evidence, and operating consequence across borders.
Source-backed reporting and analysis connected to the companies, capabilities, authorities, and operating domains it affects.
22 CFR Part 129 defines brokering through action on behalf of another that facilitates covered defense trade, including specified financing, transport, solicitation, negotiation, contracting, and arranging activities. The review must capture the actor, relationship, activity, article or service, parties, countries, exclusions, approval, and report even when the actor never ships or physically holds the item.
EAR Part 734 treats some releases of technology or source code to a foreign person as exports or reexports, while defining bounded activities that are not. The control record therefore needs the technology, person, place, method, access information, encryption state, authority analysis, and actual release event—not only a file location or account flag.
Calculate EAR de minimis from destination-controlled U.S. content over the foreign item's fair-market value. Check zero-threshold rules and FDP scope separately.
EAR Part 758 describes Electronic Export Information filed through the Automated Export System as a statement to the U.S. government about an export transaction, including item and authority fields when required. A filed or accepted EEI record needs to reconcile to the actual shipment and license basis; the filing itself does not grant export authority.
The agency's compliance framework gives buyers a broader test than list matching: risk assessment, controls, testing, training, and management commitment must work as one system.
The Commission updated implementation guidance on July 17. Buyers need systems that can use official guidance without presenting it as if it were the binding Council Regulation.
BIS says specified license requirements continue to turn on where an entity—or its ultimate parent—is headquartered, making hierarchy data part of export-release logic.
