Export Control in a University Environment

• Publication, access, and dissemination restrictions in the sponsored research agreement
• Foreign party restrictions stated in the sponsored agreement
• International travel to countries subject to U.S. embargoes and sanctions
• Sponsor is providing export-controlled technology, technical data, or equipment
• Non-U.S. students or visiting scholars participating in a restricted project
• Project is sponsored by the federal government or defense contractor
• Project is military, space-related, or has other implications to national security
• Project will be conducted abroad or with a foreign sponsor or collaborator
• Sponsor /entity/research/collaborator is in Cuba, Iran, North Korea, Sudan, or Syria
• Any shipment of goods, services, information, or technology abroad

If export controls are applicable, the project could require a TCP (Technology Control Plan) and/or an export license prior to commencement of activity. If you need an export control review please contact us. For sponsored projects, please complete the EC checklist.

Yes, unfunded research may be subject to export controls, particularly international collaborations.

Export control laws and regulations affect various University activities including, but not limited to conducting research (sponsored and unsponsored), international travel, publishing research, procurement, hiring non-U.S. persons, sponsoring foreign persons (e.g., visiting scholars), collaborations with non-U.S. individuals or entities, international shipments, non-disclosure agreements, and certain services to embargoed or sanctioned countries.

Export controls are federal laws that govern the transmission of controlled items and associated technical data to foreign nationals. There are also federal regulations regarding providing services, traveling to, or working with individuals or entities from sanctioned or embargoed countries. These federal regulations not only affect items that are utilized by UA personnel, but can also affect whom the UA engages with on campus as well as around the world.

There are three primary agencies which govern export control laws and regulations: the U.S. Department of State Directorate of Defense Trade Controls; the U.S. Department of Commerce Bureau of Industry and Security; and the U.S. Department of Treasury Office of Foreign Assets Control.