Export Control Notice

⚠️ EXPORT CONTROLLED INFORMATION

This website may contain technical data and information subject to U.S. export control laws, including the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR). Access to and dissemination of this information may be restricted to U.S. persons only.

1. Export Control Overview

Forge & Flight Holdings, Inc. and its operating companies develop, manufacture, and support unmanned aircraft systems, avionics, and related technologies that may be subject to U.S. export control regulations. These regulations are designed to protect national security and foreign policy interests by controlling the export of sensitive technologies, technical data, and defense articles.

2. Applicable Regulations

2.1 International Traffic in Arms Regulations (ITAR)

ITAR (22 CFR 120-130) controls the export and temporary import of defense articles and defense services on the United States Munitions List (USML). Our unmanned aircraft systems and related technologies may be classified under USML Category VIII (Aircraft, Associated Equipment, and Related Technical Data).

• ITAR restricts access to defense articles and technical data to U.S. persons only, unless an export license or exemption applies
• "U.S. Person" includes U.S. citizens, lawful permanent residents, protected persons, and U.S. corporations
• Violations of ITAR can result in severe civil and criminal penalties

2.2 Export Administration Regulations (EAR)

EAR (15 CFR 730-774) controls the export of dual-use items (items with both commercial and military applications) listed on the Commerce Control List (CCL). Certain components, technologies, and software used in our systems may be subject to EAR controls under Export Control Classification Numbers (ECCNs) related to aerospace, electronics, and navigation equipment.

3. Access Restrictions

3.1 Technical Data

Technical data related to our unmanned systems, including design specifications, performance characteristics, manufacturing processes, and operational capabilities, may be export-controlled. Disclosure, transfer, or dissemination of such technical data to foreign persons (including foreign nationals in the United States) is prohibited without proper authorization.

3.2 Physical Access

Access to our facilities, test ranges, and manufacturing operations may be restricted to U.S. persons only to prevent unauthorized exposure to export-controlled hardware and technical data. Foreign persons seeking facility access must obtain advance approval and appropriate export licenses.

4. "Deemed Export" Rules

Under both ITAR and EAR, the disclosure of export-controlled technical data to foreign persons within the United States is considered a "deemed export" and requires an export license. This includes:

• Visual inspection of controlled hardware or systems
• Oral or written disclosure of technical data
• Providing access to controlled software or technology
• Employment situations where foreign nationals may gain access to controlled information

5. Foreign Person Definition

A "foreign person" includes:

• Any individual who is not a U.S. citizen or lawful permanent resident
• Any individual who is not a protected person under 8 U.S.C. 1324b(a)(3)
• Any foreign corporation, business association, partnership, trust, society, or other entity
• Any foreign government, foreign government agency, or representative thereof

6. Prohibited Destinations and Entities

Forge & Flight Holdings complies with U.S. government restrictions on exports to certain countries, entities, and individuals, including:

• Countries subject to U.S. embargoes or comprehensive sanctions
• Entities and individuals on the Denied Persons List, Entity List, Unverified List, and Specially Designated Nationals List
• End-users engaged in activities contrary to U.S. national security or foreign policy interests

7. NDAA Section 848 Compliance

In addition to export control compliance, our platforms comply with the National Defense Authorization Act (NDAA) Section 848, which prohibits DoD procurement of certain foreign-manufactured unmanned aircraft systems and components. Our vertically integrated domestic supply chain ensures full NDAA compliance and eliminates foreign dependencies in critical defense systems.

8. Technology Transfer and Collaboration

Organizations and individuals seeking to collaborate with Forge & Flight Holdings on projects involving export-controlled technologies must:

• Verify U.S. person status of all personnel with access to controlled information
• Obtain appropriate export licenses or Technical Assistance Agreements (TAAs) prior to collaboration
• Implement appropriate physical and technical security measures
• Comply with all recordkeeping and reporting requirements

9. Export License Applications

Entities seeking to export or re-export our technologies must obtain appropriate export licenses from the U.S. Department of State (for ITAR-controlled items) or U.S. Department of Commerce (for EAR-controlled items). Forge & Flight Holdings will cooperate with legitimate export license applications consistent with U.S. national security and foreign policy interests.

10. Penalties for Violations

Violations of U.S. export control laws can result in severe consequences, including:

• Criminal penalties: up to $1 million per violation and 20 years imprisonment
• Civil penalties: up to $1.3 million per violation (ITAR) or the greater of $300,000 or twice the transaction value (EAR)
• Debarment from government contracting
• Denial of export privileges
• Seizure and forfeiture of controlled items

11. Reporting Requirements

If you become aware of any actual or suspected violations of export control regulations related to our technologies or products, you must immediately report such violations to us and to appropriate U.S. government authorities. We maintain internal compliance programs and encourage reporting through our compliance channels.

12. Website Content Disclaimer

While we make efforts to provide publicly releasable information on this website, some content may be subject to export controls. By accessing this website, you acknowledge that you are responsible for ensuring compliance with all applicable export control regulations. If you are a foreign person or accessing this website from outside the United States, you should not access or download any technical data without first consulting with legal counsel regarding export control compliance.

13. Contact for Export Control Matters

For questions regarding export control compliance, license applications, or to report suspected violations, please contact:

14. Additional Resources

• Directorate of Defense Trade Controls (DDTC): www.pmddtc.state.gov
• Bureau of Industry and Security (BIS): www.bis.doc.gov
• Office of Foreign Assets Control (OFAC): www.treasury.gov/ofac