Regulatory Basics

Persons and Entities
Dual National

 A Dual National is someone that holds citizenship in more than one country (e.g., a person with citizenship in France and in Canada). Many countries recognize the right of a person to maintain citizenship in more than one country. The United States does not recognize dual citizenship — you are either a U.S. citizen or not.

It is important to know if you are working with someone that claims dual citizenship as the Import and Export regulations consider any transfer of technical data or defense services a transfer to both countries an individual claims citizenship in. So in the example above it would be considered an export to France and Canada and the organization would have to have authorization to export to both countries prior to making the transaction.

The Department of State and the Department of Commerce treat dual nationals a little differently. The Department of State considers every country that a person claims citizenship in to be equal in terms of exports. This means that each country is considered a prime destination for export. The Department of Commerce is more interested in the country that is considered the primary residence when approving authorizations for exports.