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Are there export controls on EAR items sent from a US company to its own subsidiary in a foreign country?

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Are there export controls on EAR items sent from a US company to its own subsidiary in a foreign country?

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Yes. For the most part, the same export controls apply when a company exports items from the United States to its foreign subsidiary as when it exports to other parties. There are a few limited exceptions here and there such as EAR encryption exports to affiliates and ITAR temporary exports to subsidiaries.

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