Export Control

How does export control impact travel outside the United States?

Travel outside the United States can trigger the need for a federally issued license(s), depending on the proposed destination, what you plan on taking with you, the nature of the project associated with the travel, and with whom you work.
 

Who conducts Restricted Party Screenings? 

Central administrative units, departments, and colleges will coordinate with Export Control on centralized procedures for Restricted Party Screenings and identifying international collaborations, travel, services, and online study abroad requiring OFAC licenses. All individuals affiliated with the University who work with international persons and entities must confirm via Restricted Party Screening and consultation with Export Control that activities are permitted with collaborators.

What is a denied entity/person or restricted party?

The U.S. government maintains lists of individuals or entities with whom the University and its employees may be prohibited by law or require a license to export to or engage in certain transactions.

Does the University have an export control policy?

Yes. The University of Arizona, as outlined in its Export Control Policy, is committed to complying with U.S. export controls laws and regulations that apply to its activities, including the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), and the Office of Foreign Assets Control (OFAC) regulations.

How does the University of Arizona apply for an export control license?

Export Control applies for all export control licenses on behalf of the University. NOTE: Obtaining an export license may take several months and there is no guarantee that the U.S. government will approve a license request.

What is the PI’s responsibility with respect to export control?

Primary Investigators (PIs) are responsible for:

  1. Assisting Export Control in the identification of activities that may intersect with export control regulations;
  2. Maintaining a current export control training certification;
  3. Confirming with Export Control all project personnel have completed training and are cleared to access export-controlled items;
  4. Notifying Export Control of potential violations.

 

 

What are the exclusions and how do I know when they apply to research?

Research is not subject to export controls if it qualifies for at least one of three exclusions:

(1) Fundamental research exclusion;

(2) Public domain exclusion; and

(3) Education Information Exclusion.

What is the Fundamental Research Exclusion?

The Fundamental research exclusion is a broad-based general legal exclusion to protect technical information (but not tangible items) involved in research from being controlled by export controls. In other words, research qualifying as “fundamental research” is not subject to export controls.

What is the Public Domain Exclusion?

The public domain exclusion applies to information that is published and that is generally accessible or available to the public through:

What is the Educational Information Exclusion?

The educational information exclusion covers commonly taught in courses listed in catalogues and associated teaching laboratories of academic institutions in the United States.

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