Export Control Guidance
The Department of Commerce Export Administration Regulations (EAR) and the Department of State’s International Traffic in Arms Regulations (ITAR) restrict the export of certain technology or technical data, such as military applications or commercial applications that may also have value in a military context, oversees and to foreign nationals working in or visiting the United States. In some circumstances, the Health Science Center may be required to obtain prior approval from the appropriate agency before allowing foreign nationals to participate in research, collaborate with a foreign company, or share research results with foreign nationals. The Treasury Department’s Office of Foreign Assets Control (OFAC) regulates trade embargoes, sanctions, and travel restrictions and restricts exportation of information and research articles to embargoed entities and persons.
These regulations, in place for more than two decades, carry a range of potential penalties, including fines and imprisonment, for individuals who violate them. This page provides guidance to the Health Science Center faculty, students, and staff so that they may recognize when the regulations may apply and when an export or OFAC license may be required in connection with research. In case of questions, contact either Melanie Zuñiga Rapp, Manager, COI & Research Integrity, x2-6838 or firstname.lastname@example.org or Gary Sertich, Legal Affairs, x7-6182 or email@example.com.
Health Science Center Guidance on U. S. Export Control Regulations (PDF).
This memo, issued by Dr. Andrea Giuffrida, Vice President for Research, provides an overview of the federal laws and regulations on export controls as they may relate to Health Science Center research Activities.
EXPORT ADMINISTRATION REGULATIONS (EAR)
- U. S. Department of Commerce Export Policies
- EAR Database (maintained by the Bureau of Industry and Security, Department of Commerce, this database is a complete collection of regulations relating to EAR. CFR Section 774 categories 0 through 9, contain detailed specifics about technologies.
- Commerce Control List (Alphabetical)
INTERNATIONAL TRAFFIC IN ARMS REGULATIONS (ITAR)
- Defense Trade Controls – Reference Library
Regulations (ITAR-22 CFR Parts 120-130; ITAR Amendments, Arms Export Control Act (AECA), Defense Trade Security Initiatives (DTSI)
Licensing (Country-related, COMSAT, Notices/Initiatives/Statements, Guidelines/Instructions, Licensing forms)
Miscellaneous (Notifications and Reports to Congress, remarks by the Assistant Secretary)
- 22 CFR Section 121.1
Title 22 of the Code of Federal Regulations, Foreign Relations; Chapter 1, Department of State, Section 121.1, The U. S. Munitions List (General)
OFFICE OF FOREIGN ASSETS CONTROL (OFAC)
- OFAC Sanctions Program and Country Summaries
- OFAC List of Specially Designated Nationals and Blocked Persons
- U. S. Department of Commerce
- U. S. Department of State – Directorate of Defense Controls
- U. S. Department of Treasury – Office of Foreign Assets Control
OTHER USEFUL RESOURCES
- Council on Governmental Relations (COGR)
Export Controls & Universities: Information & Case Studies
- Export Control Researcher’s Guide (from the University of Pennsylvania)