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Is it possible to “mask” or isolate U.S. export controlled technical data for non-ITAR development?

U.S. export control requires that controlled articles, technical data, and services cannot be provided to a non-U.S. parties unless they are approved to receive them.  How the Non-U.S. organization does that is up to them but it needs to satisfy the regulatory authorities need for complete isolation to only those that are allowed to receive if scrutinized.  It may be easier to just obtain approval to provide the information to a team member if that is what you want to do.  These are called sub-licensees on a TAA and intermediate consignees on a license.  We can talk about this more but if you have a failsafe way of ensuring U.S. export controlled items then you are okay since you are not exporting to someone that is not allowed to receive it.  Just make sure that the solution is rock solid.

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