Export Controls
Description of Export Control Regulations in the United States
Export controls are a set of U.S. laws and regulations governing the transfer of certain goods, materials, technologies, services, and information outside the country or to non-U.S. persons. 91暗网 is committed to ensuring compliance with federal export control laws and regulations.
Export controls need to be reviewed in any instance where specific information necessary for the 鈥渄evelopment,鈥� 鈥減roduction鈥� or 鈥渦se鈥� of a controlled product may be released either outside of the U.S. or to a foreign national. For example, the release of controlled information to a foreign national in your office on campus is as much an export as sending the information to an individual in a foreign country.
While most College and research activities do not require an export control license, there are times when a license or documentation of compliance with the regulations is required. All 91暗网 employees have the obligation to determine how export controls might apply to their activities, and to work cooperatively with the College to ensure export control compliance. Non-compliance can result in civil and criminal sanctions for both individuals and the institution.
Federal Regulations on Export Control
The primary regulations include:
- Export Administration Regulations (EAR): 15 CFR 搂 730-774: Administered by the Department of Commerce鈥檚 Bureau of Industry and Security (BIS), EAR controls the export of commercial and dual-use items listed on the Commerce Control List (CCL).
- International Traffic in Arms Regulations (ITAR): 22 CFR 搂 120-130: Administered by the Department of State鈥檚 Directorate of Defense Trade Controls (DDTC), ITAR controls the export of defense-related articles and services listed on the U.S. Munitions List (USML).
- Office of Foreign Assets Control (OFAC) Regulations: 31 CFR 搂 500-599: Administered by the Department of Treasury, OFAC regulations implement economic and trade sanctions against targeted foreign countries and regimes, terrorists, international narcotics traffickers, and those engaged in activities related to the proliferation of weapons of mass destruction.
Export Control Exclusions and Exceptions
Certain exclusions and exceptions allow for the transfer of controlled information and technologies without a license under specific conditions. The three types of activity generally not subject to export control regulations are:
- Fundamental Research: information resulting from fundamental research (basic and applied research in science and engineering) of which the results are published and shared broadly with no access restrictions is not subject to export control regulations (15 CFR搂734.8; as a public domain exception (22 CFR 搂125.1(a)) listed in 22 CFR 搂 120.34(a)(8)).
- Educational Information: general scientific, mathematical, or engineering principles released by instruction in a catalog course or associated teaching laboratory of an academic institution are not subject to export control regulations (15 CFR搂734.3(b)(3)(iii)).
- Public Domain Information: information which is published and which is generally accessible or available to the public is not subject to export control regulations (15 CFR搂734.7; 22 CFR 搂125.1(a)).
When to Seek Advice on Export Control
Researchers should seek advice on export control if their activities involve:
- Collaborations with foreign nationals or institutions, whether in the United States or overseas.
- International travel with research equipment or data.
- Shipping equipment, technology, or samples internationally.
- Research involving technologies or data listed on the Commerce Control List (CCL) or U.S. Munitions List (USML).
- Funding from sources that has an export control clause, publication restriction, or personnel restriction.
- Doing any work with a person, business, or organization that is a citizen of or headquartered in Iran, Syria, North Korea, Cuba, or the Crimea region.
Visas for International Faculty
Export control regulations control the transfer of certain information, technologies, and commodities to foreign nationals.
To ensure compliance with these regulations, hiring managers (Chair, Program Directors, PIs) or designees should fill out and submit the before a visa application can be submitted.
Hiring managers may need to request information from the visa beneficiary and other sources to complete this form, so they are encouraged to collect the necessary information promptly to ensure the timely completion of the visa application.
Research Projects
Most of the research at 91暗网 is considered fundamental research or in the public domain, not subjected to export control restrictions. However, some items/technologies fall under the reach of these U.S. export control restrictions. Research projects may have export restrictions on particular items, equipment, technology, and data. Additionally, the research may have restrictions on the participation of foreign nationals and/or freedom to publish the results of the research. When this is the case, the Office of Sponsored Research will assist those involved in the research with compliance with federal regulations.
If you think your research project might be subject to export control restrictions, please fill out and submit the .
After submission, the Office of Sponsored Research will provide a determination or request additional information if needed.
Additional Questions
These guidelines are designed to ensure that the College complies with all relevant export control regulations while conducting its educational and research activities. Compliance with export control regulations is mandatory for all faculty, staff, and students. For questions or further assistance, contact the Office of Sponsored Research, the Office of the Dean of the Faculty/VPAA, or the Office of the General Counsel/VP for Human Resources.