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Records regarding all export transactions should be kept for a period of five years. The five year period begins with either the expiration of the license, if the shipment was made against a license, or the date of the transaction, if shipped against a license exception/exemption or NLR. Documents that should be maintained include the commercial invoice, packing slip, bill of lading (if applicable), and a record of the accepted AES filing (when required).


Companies should also keep a record of controlled technical data exports, retaining for 5 years under the same guidance outlined above. Information that should be retained includes: person/company the controlled technical data was sent to, means of transmission (email, phone call, etc.), date of transfer, technology that was transferred, and its classification.


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