Yup ITAR/EAR follows the specific item/technology. You can get in major trouble even if you never interacted with a US counterpart at any point in the supply chain in this way.
It might seem draconic, but it's to plug a very easy loophole that can be exploited, and people actually do try to exploit when they don't understand exactly to what the regulations apply to.
It might seem draconic, but it's to plug a very easy loophole that can be exploited, and people actually do try to exploit when they don't understand exactly to what the regulations apply to.