To the extent an authorization would be required to transfer "technology" or "software," a comparable authorization is required to transfer access information if done with "knowledge" that such transfer would result in the release of such "technology" or "software" without a required authorization.
15 C.F.R. §734.19
Note 1 to § 734.19 : For purposes of this section, a release of "software" includes source code and object code.