Understanding Export Controls and Compliance
This content provides essential information on export controls, including what constitutes an export, deemed exports, export control questions, federal agencies involved, fundamental research exceptions, and situations where export controls should be a concern. It emphasizes the importance of compliance to regulations and the need for proper screening when dealing with international transactions.
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Be aware of Export Controls! April 21,2017 Katrin Duevel Research Compliance Officer
Exports Exports - Any item that is sent from the US to a foreign destination or a foreign national is an export Deemed Exports - Any release of technology or information subject to the export regulations to a foreign national while inside the U.S. (i.e., on campus) is deemed to be an export to the home country of the foreign national. Does not apply to foreigners with: A permanent residence ( Green Card ) U.S. citizenship Status as a protected person
Export Control Questions What is being exported? Where to? (country/institution/individual) What for? (Purpose) When?
Federal Agencies US Department of State International Traffic in Arms Regulation (ITAR) US Munitions List (USML) US Department of Commerce, Bureau of Industry and Security (BIS) Export Administration Regulation (EAR) Commerce Control list (CCL) Examples for dual use items: Chemicals, microorganism, toxins, software, sensors, electronics, lasers, drones .
Federal Agencies (cont.) US Department of Treasury Office of Foreign Assets Controls (OFAC) Economic and trade sanctions Specially Designated Nationals list (SDN), individuals, groups and entities
Fundamental Research Exception Fundamental research Research in science, engineering and mathematics the results of which ordinarily are published and shared broadly within the research community Not considered fundamental research Restrictions placed on the dissemination of research results Restrictions on methods used during the research Proprietary research, industrial development, design, production, and product utilization Harvard does not accept sponsor restrictions on publication of research results.
When should you be concerned about export controls? Using export-controlled technology in your lab Shipping items, software or information internationally (Tip: ship directly from vendor) Teaching courses abroad or online Foreign travel International collaborations or partnerships Paying someone in another country for items or services It is very important to know who you re dealing with and to have your export control officer perform a Restricted Party Screening .
Heads Up Export control questions in GMAS Alerts Export Control Administrator Possible GMAS approval function More outreach and training (CITI training now available)
Reach out! FAS/SEAS: Katrin Duevel, Kduevel@fas.harvard.edu, p: 617 496 7658 Global Support Services: Krister Anderson, krister_anderson@harvard.edu p.: 617 496 1702 https://www.globalsupport.harvard.edu/ Material Transfer Agreements (MTA), OTD http://otd.harvard.edu/faculty-inventors/resources/material- transfer-agreements/ Further Information: Office for the Vice Provost for Research: Export Controls http://vpr.harvard.edu/pages/export-controls-policies-and- procedures
