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Export Control

Who qualifies as a “bona fide employee” for ITAR purposes?

Export control regulations exempt disclosures of unclassified technical data in the United States by U.S. universities to foreign nationals where:
(1) the foreign national is the University’s bona fide full-time regular employee;
(2) the employee’s permanent abode throughout the period of employment is in the United States;
(3) the employee is not a national of an embargoed country; and

What is not subject to the deemed export rule?

For University research, there are three ways that technical information may qualify for an exclusion from the deemed export rule. Information is excluded if it:
  • Is published or disseminated in the Public Domain
  • Arises during, or results from, fundamental research
  • Is educational information released by instruction in catalog courses or associated teaching laboratories of academic institutions.

What is a deemed export?

A deemed export is the release or transmission in any form of export-controlled technology or software code within the U.S to anyone who is not a U.S. Person.

What is an export?

An export is the transfer of export-controlled data, items, equipment, materials, and software or providing a defense service to a non-U.S. Person or entity. An export can occur in a number of ways, such as; a physical shipment, hand-carrying an item out of the U.S., email transmission of data, presentations, discussions, or visually accessing export-controlled data.

What triggers an export control review?

  • 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

Can unfunded research be subject to export controls?

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

What activities at the UA are impacted by export control laws and regulations?

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.

What are export controls?

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.

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