General Information on Export Controls

This page provides guidance to University faculty, students, and staff so that they may recognize when export regulations may apply and when an export or OFAC license may be required in connection with research.

Quick Reference for Determining Potential Application of Export Control Laws for Research Projects

For the EAR (Export Administration Regulations),

• The Buereau of Industry and Security, contains the regulations regarding commercial applications that may also have value in a military context overseas and to foreign nationals working in or visiting the US;
• Commerce Contol List (CCL) contains Export Control Classifications.
• The Bureau of Industry and Security U.S. Dept. of Commerce is the home page of the BIS (formerly the BXA).

For the ITAR (International Traffic in Arms Regulations),

• The US Dept. of State, Directorate of Defense Trade Controls website,contains the regulations and other useful information regarding the restrictions on the export of certain technology or technical data, such as military applications.

The Code of Federal Regulations (CFR) citations to the regulations are as follows:

• The ITAR are published in the 22 CFR §§ 120-130

• The EAR are published in 15 CFR §§ 730-774.

• The CFR Web address is www.gpoaccess.gov/cfr/index.html.

In addition, faculty doing work with an embargoed country may be subject to Office of Foreign Assets Control (OFAC) regulations. These regulations affect nearly all transactions with those countries without regard to content or purpose. For a complete list of embargoed countries and prohibited transaction see: http://www.ustreas.gov/offices/eotffc/ofac/

POTENTIAL ISSUES WITH RESEARCH PROJECTS:

As ORPA reviews every research project, it examines the proposal and the accompanying documents for any potential issues within it that may present an export control issue that must be resolved before the researcher can proceed with the research project.

• Research Discussions Off-Campus
• Communications to foreign entities Off-Campus
• Deliverables to foreign sponsors or transfer of export-controlled material or information outside of the U.S.
• Receipt of export-controlled information
• Technology or equipment that is or could be related to munitions
• Restrictions on foreign nationals on reserch project
• Publication approval restrictions

UNIVERSITY OF ROCHESTER-RELATED MATERIALS:

• Government Control of Exported Technology or Items
• Export Controls Overview (Powerpoint Presentation)
• Export control laws and regulations document
• Export control laws and regulations document follow up
• Researcher's Export Control Checklist
  

For questions related to University of Rochester student, faculty and employee international travel, please consult with the Office for Global Engagement.

OTHER RESOURCES:

• Council on Governmental Relations (COGR)
  Export Controls & Universities: Information & Case Studies
• Massachusetts Institute of Technology (MIT)
  Export Controls - overall guidance

 

 

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