Deemed Exports: The Hidden Export-Control Risk Inside Your Walls

Think exports only happen when something ships in a box? Deemed export compliance says otherwise. Under U.S. export controls, providing a foreign person in the United States with access to controlled technology or information can be treated as an export. That includes employees and visitors. If a foreign national can view, handle, or learn about controlled technical data, your company may face significant risk under U.S. export regulations and sanctions rules.In this video, Vigilant Global Trade Services explains how deemed exports work and why front-end planning is critical. We share a real-world scenario where a tech company hired a highly qualified engineer educated in the UK but a national of a heavily sanctioned country. A compliance review triggered the need to apply for a federal license before granting access to certain projects. While the license was pending, the company had to restrict access so strictly that the new hire was assigned non-technical tasks—illustrating the stakes and the importance of pre-hire and pre-visit reviews, role-based access controls, and careful handling of high-risk country considerations.If your teams host visitors or hire foreign nationals, build a documented review process to assess roles, access to controlled technology, and whether a government license is required—before access is granted. Not sure where to start? Contact Vigilant Global Trade Services. We can help you evaluate risk, structure effective reviews, and connect you with the right experts, including legal counsel, so you can move forward confidently. Visit our website to learn more.