> As described in court filings, from at least December 2022 through December 2024, Mazulina conspired with Russian freight forwarding companies and others to unlawfully ship controlled items, including industrial oil and gas equipment, from the United States to Russia, through intermediary countries. At one point, in June 2023, Mazulina told colleagues that her clients were paying through bank accounts in third party countries because “[m]ost of [her] clients [were] currently sanctioned with USA.” Mazulina attempted to conceal the unlawful scheme by submitting and causing the submission of false export documents to the U.S. government, which omitted the information that the goods were destined for Russia.

That feels materially different than a software program released in the open domestic market.

And while it feels different, the government would apparently disagree: https://exportcontrol.lbl.gov/training/export-control-overvi...

Distribution of software to a foreign national within the US is an explicit proviso of the law. That is a wild law and I am surprised it stands.