Export Control Compliance
About export controls
"Export controls" refers to regulations used by the federal government to control the export of information or items for reasons related to national or economic security and foreign policy.
In academia, these laws may impact researchers if the project involves:
- restrictions on publishing research results (other than normal patent reviews);
- working with company confidential technical information;
- working with confidential information on how to use equipment;
- shipping equipment or materials to a foreign country;
- working with a country subject to a U.S. boycott; or
- working with an individual or organization on the list of supporters of terrorism.
Export control compliance includes the following elements:
Education and training of researchers, administrators, and others
Free training resources:
- http://www.bis.doc.gov/seminarsandtraining/seminar-training.htm
- University of Maryland Export Control Guidance: http://www.umresearch.umd.edu/ORAA/export_control_guidance/
Delineation of roles and responsibilities of key components and key personnel
Sponsored Projects Administration is to:
- identify potential restricted areas in proposals and solicitations and assist with modifying them to prevent later issues;
- identify suspect clauses in awards and contracts and try to get them modified;
- take all other reasonable steps to help assure compliance with export control regulations; and
- keep the principal investigator informed about the status of the negotiations.
The Compliance Director
- assist Sponsored Projects Administration and researchers in complying with export control regulations;
- provide educational opportunities for the University community; and
- obtain export control licenses, if needed.
Tools
- List of dual-use (both civilian and military use) items and technologies subject to the Export Administration Regulations: use the GPO Export Administration Database [the list is in Part 774, categories 0 through 9]
- List of specifically military items and technologies subject to the International Traffic in Arms Regulations (ITAR): use the Department of State's updated, consolidated regulations [the list is in Part 121.1]
- List of boycotted countries (from the Treasury Department's Office of Foreign Assets Control)
- List of organizations possibly engaged in proliferation of weapons of mass destruction (entity list)
- List of individuals and entities that support terrorism (specially designated nationals list)
Background information and other resources
- Introduction to Commerce Department Export Controls
- Council on Government Regulations: Educational materials on export controls
- Association of American Universities: Export Controls
- Massachusetts Institute of Technology: Export Controls
- University of Maryland: Export Control Guidance
- Pennsylvania State University Policy on Compliance with Federal Export Regulations and Guidance on Ensuring Compliance with Export Control Policy
- Lawrence Berkeley National Lab: Export Control Manual