Under the ITAR, "Foreign National" includes companies not incorporated in the U.S. Does that mean that foreign company employees (who are U.S citizens or permanent residents) are Foreign Nationals, and providing tech data to them would be an export?
The regulation has a clear definition of who is a us person and US cutizens as well as permanent residents are considered US persons.
Your question falls outside of the scope of US immigration law.
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No, it does not. Read those export regulations again.
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