ORAA

Export Control Activities

What kind of activities will Raise Export Control concerns?

    Exclusions and exemptions do not apply to all University activities. Export controls apply if the topic of the research appears on the U.S. Munitions List (ITAR) or is identified under one of the nine Categories in the Commerce Control List (EAR).  Other activities may be subject to sanctions and embargoes; that is, the export or transaction is prohibited with certain countries, entities and individuals.

    The following should be reviewed for export compliance. 

    • Research collaborations with foreign nationals and technical exchange programs
    • Shipping materials or equipment outside the United States
    • Working with sponsor’s proprietary, restricted or classified information
    • Projects performed abroad by UMCES personnel
    • Furnishing defense services to a foreign person within the United States
    • Transacting with embargoed or sanctioned countries or parties (including financial transactions)
    • Creating, receiving or working with encryption software
    • Providing use technology regarding controlled equipment to a foreign national

    In addition, any of the following will raise export control questions for your project:

    • Restrictions on publishing research results (other than normal patent reviews)
    • Restrictions on researcher participation (faculty, student, or others) based on country of origin or citizenship
    • Indications from the sponsor or others that export-controlled information or technology will be furnished for use in the research
    • The physical export of controlled goods or technology

    Remember, the need for review does not automatically translate to there being a problem.  It is much, much easier to address export control issues before the fact rather than after, so always err on the side of caution.