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.

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