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As Apple states here:
https://help.apple.com/app-store-connect/#/dev88f5c7bf9
Export compliance overview
Apps uploaded to App Store Connect are uploaded to an Apple server in the United States. When you submit your app with the intention of distributing your app on the App Store or to external testers through TestFlight outside of the U.S. or Canada, it is considered a U.S. export and is subject to U.S. export laws (regardless of where your legal entity is based).