The text of the law seems to disagree with you? § 120.62 U.S. person. U.S. person means a person who is a lawful permanent resident as defined by 8 U.S.C. 1

The text of the law seems to disagree with you? § 120.62 U.S. person. U.S. person means a person who is a lawful permanent resident as defined by 8 U.S.C. 1101(a)(20) or who is a protected individual as defined by 8 U.S.C. 1324b(a)(3). And this seems to be interpreted by people[1] that employing lawful permanent residents does not need export authorisation. 1: https://exportcompliancesolutions.com/blog/2018/09/20/u-s-persons-include-just-citizens/ https://exportcompliancesolutions.com/blog/2018/09/20/u-s-pe...