Who qualifies as a “bona fide employee” for ITAR purposes?

Export control regulations exempt disclosures of unclassified technical data in the United States by U.S. universities to foreign nationals where:

(1) the foreign national is the University’s bona fide full-time regular employee;

(2) the employee’s permanent abode throughout the period of employment is in the United States;

(3) the employee is not a national of an embargoed country; and

(4) the University informs the employee in writing that information disclosed may not be disclosed to other foreign nationals without governmental approval.