In addition to physical shipments or transmissions from the U.S., “Export” also means releasing or otherwise transferring technology (or software source code) to a foreign person in the United States or abroad (a “Deemed Export”).

The following types of individuals are NOT foreign persons:

1. U.S. citizens
2. U.S. permanent residents (Green Card holders)
3. Certain protected individuals who've been granted asylum in the U.S.