Comments on: More Deemed Export Red Tape Courtesy of BCIS

By: TH

TH — Wed, 24 Feb 2010 14:09:59 +0000

It’s bad enough having to wait when applying for a Visa, on top of that now having to wait for a response from BIS after submission of the deemed export license. How much more difficult can this get?

By: Clif Burns

Clif Burns — Wed, 24 Feb 2010 14:06:31 +0000

@David: Yes, I should have mentioned that the deemed export questions have to be answered whether or not a deemed export license is needed. Additionally, as I said in the post, I never would have found the proposed changes if you hadn’t run them down. OMB ought to insist that these FR notices clearly disclose what is proposed or provide a specific link.

By: David Brady

David Brady — Wed, 24 Feb 2010 14:01:25 +0000

Cliff, the docs are found in case USCIS 2005-0030 to which they were posted on 2/16 and 2/18. Oddly, the FR entry is in USCIS 2006-0028, go figure. An important note to employers however, this form has to be filled out regardless of whether a deemed export license is required. Apparently you have to disclose any technology to which the foreign employee will have access- whether or not an export license is required. See page 7 of the Table of changes in USCIS 2005-0030-0193.