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U.S. items overseas, and items produced overseas using U.S.-origin components or made using U.S. technology, may still be subject to the Export Administration Regulations. Certain activities of U.S. persons overseas may also be subject to these regulations.

What changes did the August 2020 FDP rule (85 Fed. Reg. 51596, effective Aug. 17, 2020) and the February 2022 rule (87 Fed. Reg. 6022, Feb. 3, 2022) make to EAR § 736.2(b)(3) regarding General Prohibition Three license requirements?

The license requirement referenced in footnote 1 to Supplement No. 4 to part 744 of the EAR was added in the August 2020 FDP rule. The subsequent February 2022 rule moved the license requirement to § 744.11(a)(2) and consolidated the provisions for Foreign Direct Product in §734.9 (Foreign-Direct Product (FDP) Rules.
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