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Hello there,
If AWS services are being accessed in the cloud, the U.S. Department of Commerce has published several advisory opinions establishing that an export does not occur in the cloud and that cloud computing is not subject to the Export Administration Regulations (EAR).
The three Advisory Opinions related to cloud computing and the applicability of export controls are:
- Application of EAR to Grid and Cloud Computing Services - Dated 01/13/09 (This advisory opinion establishes that cloud computing is not subject to the EAR.)
- Cloud Computing and Deemed Exports - Dated 01/11/11
- Cloud-based Storefront - Dated 11/24/14
The advisory opinions can be found on BIS website: https://www.bis.doc.gov/index.php/policy-guidance/advisory-opinions
For further information kindly reach out to the AWS Export Compliance team via e-mail at aws-exportcompliance@amazon.com or by completing the form on the link below: https://aws.amazon.com/contact-us/compliance-support/
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