On October 7, 2022, the Bureau of Industry and Security (BIS) announced a new policy that would continually escalate restrictions on entities that fail to comply with BIS’s end-use.
In plain English, anytime an aircraft departs the United States, this is an "export" and will fall in one of two "buckets": temporary exports – where the aircraft will fly under its own power.
Update: This Holland & Knight alert has been updated on Sept. 25, 2022, with additional information. In plain English, anytime an aircraft departs the United States, this is an "export".