Q: What is the "deemed export" rule?
A:  An export of technology or source code (except encryption source code) is "deemed" to take place when it is released to a foreign national within the United States.

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Q: What is a "release" of technology?
A: Release of technology is defined as one of the following:
  1. The release or transfer of Technology through visual inspection (such as reading technical specifications, plans, blueprints, etc.).
  2. Oral exchange of technology including when Technology is made available by practice or application under the guidance of persons with knowledge of the Technology.
  3. Posting information on a website or FTP site for downloading.

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Q: What is "technology"?
A:  Technology is defined as:
  1. Specific information related to all stages prior to serial production, such as design, design research, design analyses, design concepts, assembly and testing of prototypes, pilot production schemes, design data, process of transforming design data into a product, configuration design, integration design, layouts.
  2. Specific information related to all production stages, such as product engineering, manufacture, integration, assembly (mounting), inspection, testing, quality assurance and
  3. Specific information related to an items operation, installation (including on-site installation), maintenance (checking), repair, overhaul and refurbishing.

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Q: What are Cisco's controlled technologies?
A: 
Technology Regulatory Definition Cisco Product Examples
Total Digital Transfer Rate Exceeding 120 Gbits/s - also known as high speed data transfer rates. Equipment designed to operate at a "total digital transfer rate" exceeding 120 Gbits/s. Interpreted as the speed of a single port that exceeds 120 Gbits/s.
This definition does not include aggregated transfer rate (4 OC-768 cards running at 40Gbbps would not be subject to this control).		 An optional CRS-1 line card, the 1-Port OC-768c/STN-256c POS Interface Card has a single port total digital transfer rate exceeding 40 Gbits/s.
Optical Switching. The routing of or switching of signals in optical form without conversion to electrical signals. The optional ROADM module associated with Cisco's ONS 15454 (MSTP) employs functionality meeting the regulatory definition of optical switching.

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Q: When do I need to apply for an export license for technology under the deemed export rule?
A:  Cisco must apply for an export license for a foreign national under the deemed export rule when both of the following conditions are met:
  1. Cisco intends to transfer controlled technologies to foreign nationals in the United States.
  2. Transfer of the same technology to the foreign national's home country would require an export license.

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Q: How do I know if a foreign national would be subject to the deemed export rule?
A:  Any foreign national is subject to the deemed export rule except a foreign national who is either
  1. granted permanent residence by a greencard,
  2. granted U.S. citizenship, or
  3. granted status as a "protected person" (political refugees and political asylum holders).

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Q: What are the designated countries?
A:  Foreign nationals from the following two country groups (D:1 and E:1) are subject to the deemed export rule.
D:1 County Group

Armenia Kazakhstan Russia
Azerbaijan Kyrgyzstan Tajikistan
Belarus Laos Turkmenistan
Burma Libya Ukraine
Cambodia Macau Uzbekistan
China Moldova Vietnam
Georgia Mongolia
Iraq * North Korea
* Is also an E:1 country

E:1 Country Group

Cuba
Iran
North Korea
Sudan
Syria

An individual from Cuba requires a license for employment even if restricted access is not required.

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Q: What is the Cisco Controlled Technology Transfer Assessment form?
A:  The Cisco Controlled Technology Transfer Assessment form is a series of questions regarding a new employee’s citizenship status. The form is included in all new hire packets. All new hires and employees retained from an acquisition must fill out the form. Forms filled out by foreign nationals from designated countries will be forwarded to Global Export Trade by Human Resources to assess whether a deemed export license will be required. Click here to access the Cisco Controlled Technology Transfer Assessment form.

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Q: Global Export Trade has determined that I need to obtain a deemed export license. What documents do I need to send to Global Export Trade?
A:  Please email the following five items as a PDF file attachment to foreign-national-license@cisco.com
  1. Detailed job description, preferably written by your manager, describing your major duties and responsibilities under your current role.
  2. A current resume. Please explain any "gaps" in your employment longer than 30 days.
  3. A complete copy of your current passport, including blank pages.
  4. A copy of your most current visa; I-94 and I-797 approval.
  5. A completed FBI questionnaire.

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Q: How long will it take for my license to be granted?
A:  The Foreign National Export License Application review process may take up to 90 days to complete after the documents are submitted to the Bureau of Industry and Security. During this time, the U.S. Department of Commerce may contact Global Export Trade for additional information regarding a foreign national. All license applicants must be prepared to readily provide what is required. Failure to provide complete and accurate information will cause the Foreign National Export License Application to be rejected. Approval is not guaranteed.

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Q: Whom do I need to contact if I have any questions?
A: 
General Inquiries: foreign-national-license@cisco.com

Jeno Racz: jenoracz@cisco.com