Extract to table

If such an export would require a license from the Bureau of Industry and Security ("BIS") under the EAR, then OWS must obtain that license before providing the access, or alternatively must restrict the employee's access to only those technologies for which no license is required

Complete export control files for these employees must be maintained or reconstructed, including any assessments performed during the staffing period

Ridgeline personnel must not be provided with access to controlled technology during the relocation process and must receive appropriate briefing regarding facility access restrictions

Both candidates are transitioning from academic/research environments where the Fundamental Research Exclusion ("FRE") may have applied to their work, and careful analysis is required to delineate FRE-eligible knowledge from OWS proprietary technology

OWS must screen all foreign national employees and candidates against OFAC lists as part of its comprehensive compliance program

ITAR-Adjacent Technology Characterization While OWS's products are developed and marketed primarily for commercial data center applications, certain elements of OWS's photonic technology portfolio have potential defense and military applications that must be considered in the export control classification analysis