Export Controls & Sanctions

Export control laws regulate how certain items, technology, software and services may be transferred or shared with foreign persons or destinations. These regulations are administered by federal agencies under laws such as the Arms Control Act and the Export Control Reform Act and focus on items with military applications or both military and commercial uses.

An export occurs when all three of the following elements are present:

1. Controlled item, technology or service
2. Transfer or release
3. Foreign person or destination

Export Controls in University Research

Universities frequently collaborate with international partners and share information with foreign persons. While most university activities do not involve controlled technology, certain transfers of physical items, software or technology outside the United States, or to foreign persons within the United States, may constitute an export and be subject to federal regulations.

Economic sanctions are administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC). These regulations govern the transfer of goods and services to and from certain countries, organizations and individuals.

Sanctions may apply to individuals and organizations that are:

• Located in comprehensively sanctioned destinations.
• Subject to sectoral or targeted sanctions.

Restricted Parties

Interactions with sanctioned individuals, organizations or other restricted parties may require government authorization. Depending on the nature of the activity, additional review may be necessary before research, collaborations, transactions or other engagements can take place.