Sanctions Evasion Reference

Deemed export

The release of controlled technology or source code to a foreign national inside the exporting country, treated in law as an export to that person's home country.

reviewed

2026-08-20

A deemed export involves no shipment. Showing controlled technical data to a foreign national employee, or giving them access to a controlled system, is treated as if the data had been sent to their country of nationality, and may require a licence.

It matters here because it closes a route that would otherwise be obvious: a restricted party does not need to import the technology if it can employ, second or contract with someone who already has lawful access to it.

Where this term is used

  • What is dual-use re-export diversion? — Buying controlled civil-use goods lawfully in an open market and re-exporting them to a restricted end user, exploiting the fact that the item itself looks entirely ordinary.
  • How are aircraft parts procured in breach of sanctions? — Buying airframe and engine components through intermediaries in unrestricted countries, so that parts for a restricted operator's Western-built fleet arrive with clean paperwork and no airworthiness trail.
  • What is a professional enabler? — A lawyer, accountant, formation agent or broker whose services are what makes a concealment structure work, and whose repeated involvement across unconnected clients is itself the evidence.

Related terms

  • Export control — A licensing regime that restricts the export, re-export or transfer of specified goods, software and technology by reference to the item, the destination and the end use.
  • Dual-use goods — Items with legitimate civil applications that can also contribute to military or weapons programmes, and which are therefore export-controlled.

Sources

  1. Entity List, Supplement No. 4 to Part 744 of the Export Administration Regulations. U.S. Bureau of Industry and Security, 2026.

All glossary terms